Privacy Policy

Purposes and legal bases

We process your personal data only for the purposes below, each on the legal basis stated:

• Cookie-free, aggregate visitor and speed measurement (web only) — loaded only if you allow it; you can switch it off via "Cookie preferences" at the bottom of the page — your consent (GDPR Art. 6(1)(a)) — you can withdraw it at any time
• Where processing is based on consent, you can withdraw it at any time; withdrawal does not affect processing carried out before it.

Whether providing data is required (GDPR Art. 13(2)(e)): You are under no legal or contractual obligation to provide personal data to use this service. If you fill in a form, only its required fields are necessary to send your request; if you do not provide them, that request cannot be sent. Technical data sent by your browser or device when you view pages (e.g. your IP address) is necessary to deliver the service technically.

How long we keep your data

This service has no accounts; we keep no user record linked to you on our servers.

Technical logs and automatic backups kept by our hosting and database providers are retained for a limited period set by each provider's own retention cycle and are then deleted automatically. These copies are not used to provide the service.

International transfers

Our hosting provider, Vercel Inc. (United States), may process technical data such as your IP address when delivering the service. Where data is transferred outside the European Economic Area, we rely on the European Commission's Standard Contractual Clauses (GDPR Art. 46(2)(c)) contained in the provider's data processing addendum: vercel.com/legal/dpa The providers below (all headquartered in the United States) also receive limited data when the relevant feature is used; for each, our basis for transfers outside the EEA is the European Commission's Standard Contractual Clauses in the provider's published data processing addendum (GDPR Art. 46(2)(c)):

• Vercel Web Analytics and Speed Insights (Vercel Inc., United States) — visitor and page-speed measurement, web only: technical data such as the page visited, referring address, browser/device type, country and page load times is collected without setting cookies and turned into aggregate statistics. The legal basis is your consent (GDPR Art. 6(1)(a); ePrivacy Art. 5(3)): the tool is loaded only if you allow it in the banner at the bottom of the page, and you can withdraw consent at any time via the "Cookie preferences" link in the same place. The data may be transferred to the United States; the transfer mechanism is the European Commission's Standard Contractual Clauses in the provider's data processing addendum (GDPR Art. 46(2)(c)). vercel.com/legal/dpa

KVKK Art. 9 requires an adequacy decision or appropriate safeguards for transfers abroad; the standard contract announced by the Turkish Authority and the notification to the Authority fall within it. The hosting provider's (Vercel Inc., United States) published data processing addendum contains the EU standard contractual clauses (GDPR Art. 46(2)(c)); whether those clauses satisfy KVKK Art. 9 (the Authority's standard contract and notification duty) is subject to legal review. For users in the EU the basis is GDPR Art. 46.

Children's data (GDPR Art. 8)

Vignette EU is not offered to anyone under 16; this is our own minimum age of use (a product decision). On the age of digital consent, GDPR Art. 8 sets the EU-level default at 16; Member States may set a lower age in their own law, and Bulgaria, where the controller is established, has set it below 16 (ЗЗЛД Art. 25в). Because this service is not offered to anyone under 16, there is no parental-consent route and we do not knowingly collect personal data from anyone under 16.

Vignette EU has no accounts. A parent or guardian who believes a child has sent us data can write to us through our contact page; we delete the data without undue delay.

Your rights and how to complain

Under the GDPR you have the following rights over your data:

• Access (GDPR Art. 15), rectification (Art. 16), erasure (Art. 17) and data portability (Art. 20).
• Restriction of processing (Art. 18): while you contest the accuracy of your data, if processing is unlawful, or while your objection is being assessed, your data is only stored and not otherwise used.
• Objection (Art. 21): you can object, on grounds relating to your particular situation, to processing based on legitimate interests (e.g. security, moderation); we then stop unless we demonstrate compelling legitimate grounds.
• You can send your requests via vignette.tobulgaria.org/destek; we reply within one month at the latest (GDPR Art. 12(3)).

Complaint to a supervisory authority (GDPR Art. 77): as the controller is established in Bulgaria, the lead authority is the Bulgarian Commission for Personal Data Protection — Комисия за защита на личните данни (КЗЛД), cpdp.bg. You may also complain to the data protection authority of the EU country where you live or work.

Users in Türkiye may also complain to the Turkish Personal Data Protection Board under Art. 14 of Law No. 6698 (KVKK) (www.kvkk.gov.tr).