Full Privacy Policy

Last updated August 30, 2023

What Information Do I Collect?

Personal information you disclose to me

In Short: I collect personal information that you provide to us. I collect personal information that you voluntarily provide to me when you express an interest in obtaining information about me or my products and Services when you participate in activities on the Services, or otherwise when you contact us.

Sensitive Information

I do not process sensitive information.

All personal information that you provide to me must be true, complete, and accurate, and you must notify me of any changes to such personal information.

Information automatically collected

In Short: Some information such as your Internet Protocol (IP) address and/or browser and device characteristics-is collected automatically when you visit my Services.

 I automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use my Services, and other technical information. This information is primarily needed to maintain the security and operation of my Services and for my internal analytics and reporting purposes.

Like many businesses, I also collect information through cookies and similar technologies. You can find out more about this in my Cookie Notice: LINK

The information I collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information my servers automatically collect when you access or use my Services and which I record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
• Device Data. I collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. I collect location data such as information about your device’s location, which can be either precise or imprecise. How much information I collect depends on the type and settings of the device you use to access the Services. For example, I may use GPS and other technologies to collect geolocation data that tells me your current location (based on your IP address). You can opt out of allowing me to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

How Do I Process Your Information?

In Short: I process your information to provide, improve, and administer my Services, communicate with you, for security and fraud prevention, and comply with the law. I may also process your information for other purposes with your consent.

I process your personal information for a variety of reasons, depending on how you interact with my Services, including:

• To request feedback. I may process your information when necessary to request feedback and to contact you about your use of my Services.
• To protect my Services. I may process your information as part of my efforts to keep my Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. I may process information about how you use my Services to better understand how they are being used so I can improve them.
• To save or protect an individual’s vital interest. I may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

What Legal Bases Do I Rely on to Process Your Information?

In Short: I only process your personal information when I believe it is necessary and I have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil my contractual obligations, to protect your rights, or to fulfil my legitimate business interests.

If You Are Located in the EU or UK, This Section Applies to You.

The General Data Protection Regulation (GDPR) and UK GDPR require me to explain the valid legal bases I rely on in order to process your personal information. As such, I may rely on the following legal bases to process your personal information:

• Consent. I may process your information if you have given me permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Legitimate Interests. I may process your information when I believe it is reasonably necessary to achieve my legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, I may process your personal information for some of the purposes described in order to:
  • Analyse how my Services are used so I can improve them to engage and retain users
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how my users use my products and services so I can improve user experience
• Legal Obligations. I may process your information where I believe it is necessary for compliance with my legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend my legal rights, or disclose your information as evidence in litigation in which I am involved.
• Vital Interests. I may process your information where I believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

If You Are Located in Canada, This Section Applies to You.

I may process your information if you have given me specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, I may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If I have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

When and with Whom Do I Share Your Personal Information?

In Short: I may share information in specific situations described in this section and/or with the following third parties.

 I may need to share your personal information in the following situations:

• Business Transfers. I may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of my business to another company.
• Business Partners. I may share your information with my business partners to offer you certain products, services, or promotions.

Do I Use Cookies and Other Tracking Technologies?

In Short: I may use cookies and other tracking technologies to collect and store your information.

I may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how I use such technologies and how you can refuse certain cookies is set out in my Cookie Notice: https://slavikaloferov.com/cookies.

How Long Do I Keep Your Information?

In Short: I keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

I will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require me to keep your personal information for longer than 2 years.

When I have no ongoing legitimate business need to process your personal information, I will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then I will securely store your personal information and isolate it from any further processing until deletion is possible.

How Do I Keep Your Information Safe?

In Short: I aim to protect your personal information through a system of organisational and technical security measures.

I have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information I process. However, despite my safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so I cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat my security and improperly collect, access, steal, or modify your information. Although I will do my best to protect your personal information, the transmission of personal information to and from my Services is at your own risk. You should only access the Services within a secure environment.

Do I Collect Information from Minors?

In Short: I do not knowingly collect data from or market to children under 18 years of age. 

I do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If I learn that personal information from users less than 18 years of age has been collected, I will deactivate the account and take reasonable measures to promptly delete such data from my records. If you become aware of any data I may have collected from children under the age of 18, please contact me at [email protected].

What Are Your Privacy Rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting me by using the contact details provided in the section ‘HOW CAN YOU CONTACT ME ABOUT THIS NOTICE?’ below.

I will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe I am unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing Your Consent

If I am relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting me by using the contact details provided in the section ‘How Can You Contact Me About This Notice?’ below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies and Similar Technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of my Services. You may also opt out of interest-based advertising by advertisers on my Services. For further information, please see my Cookie Notice: https://slavikaloferov.com/cookies.

If you have questions or comments about your privacy rights, you may email me at [email protected].

Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, I do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that I must follow in the future, I will inform you about that practice in a revised version of this privacy notice.

Do California Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits my users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) I disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which I shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to me using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. To request the removal of such data, please contact me using the contact information provided below and include the email address associated with your account and a statement that you reside in California. I will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all my systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a ‘resident’ as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as ‘non-residents’.

If this definition of ‘resident’ applies to you, I must adhere to certain rights and obligations regarding your personal information.

What Categories of Personal Information Do I Collect?

I have collected the following categories of personal information in the past twelve (12) months:

 I will use and retain the collected personal information as needed to provide the

Services or for:

• Category C-2 years
• Category G-2 years
• Category K-2 years

I may also collect other personal information outside of these categories through instances where you interact with me in person, online, or by phone or mail in the context of:

• Receiving help through my customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of my Services and to respond to your inquiries.

How Do I Use and Share Your Personal Information?

More information about my data collection and sharing practices can be found in this privacy notice and my Cookie Notice: https://slavikaloferov.com/cookies.

You may contact me by email at [email protected], or by referring to the contact details at the bottom of this document.

If you are using an authorised agent to exercise your right to opt-out I may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.

Will Your Information Be Shared with Anyone Else?

I may disclose your personal information with my service providers pursuant to a written contract between me and each service provider. Each service provider is a for-profit entity that processes the information on my behalf, following the same strict privacy protection obligations mandated by the CCPA.

I may use your personal information for my own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be ‘selling’ of your personal information.

I have not disclosed, sold, or shared any personal information with third parties for a business or commercial purpose in the preceding twelve (12) months. I will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights With Respect to Your Personal Data

Right to Request Deletion of the Data — Request to Delete

You can ask for the deletion of your personal information. If you ask me to delete your personal information, I will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, my compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right, to Be Informed – Request to Know

Depending on the circumstances, you have a right to know:

• whether I collect and use your personal information;
• the categories of personal information that I collect;
• the purposes for which the collected personal information is used;
• whether I sell or share personal information to third parties;
• the categories of personal information that I sold, shared or disclosed for a
• business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal
• information; and
• the specific pieces of personal information I collected about you.

In accordance with applicable law, I am not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

I will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

I do not process consumers’ sensitive personal information.

Verification Process

Upon receiving your request, I will need to verify your identity to determine you are the same person with whom I have the information in my system. These verification efforts require me to ask you to provide information so that I can match it with the information you have previously provided us. For instance, depending on the type of request you submit, I may ask you to provide certain information so that I can match the information you provide with the information I already have on file, or I may contact you through a communication method (e.g. phone or email) that you have previously provided to us. I may also use other verification methods as the circumstances dictate.

 I will only use the personal information provided in your request to verify your identity or authority to make the request. To the extent possible, I will avoid requesting additional information from you for the purposes of verification. However, if I cannot verify your identity from the information already maintained by us, I may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. I will delete such additional information as soon as I finish verifying you.

Other Privacy Rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorised agent to make a request under the CCPA on your behalf. I may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
• You may request to opt-out from future selling or sharing of your personal information with third parties. Upon receiving an opt-out request, I will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact me by email at [email protected], or by referring to the contact details at the bottom of this document. If you have a complaint about how I handle your data, I would like to hear from you.

Do Virginia Residents Have Specific Privacy Rights?

In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

‘Consumer’ means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

‘Personal data’ means any information that is linked or reasonably linkable to an identified or identifiable natural person. ‘Personal data’ does not include de-identified data or publicly available information.

‘Sale of personal data’ means the exchange of personal data for monetary consideration.

If this definition of ‘consumer’ applies to you, I must adhere to certain rights and obligations regarding your personal data.

The information I collect, use and disclose about you will vary depending on how you interact with me and my Services. To find out more, please visit the following links:

• Personal data I collect
• How I use your personal data
• When and with whom I share your personal data

Your Rights with Respect to Your Personal Data

• Right to be informed whether or not I am processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with me Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)

I have not sold any personal data to third parties for business or commercial purposes. I will not sell personal data in the future belonging to website visitors, users, and other consumers.

Exercise Your Rights Provided Under the Virginia CDPA

More information about my data collection and sharing practices can be found in this privacy notice and my Cookie Notice: https://slavikaloferov.com/cookies.

You may contact me by email at [email protected], by submitting a data subject access request, or by referring to the contact details at the bottom of this document.

If you are using an authorised agent to exercise your rights, I may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.

Verification Process

I may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorised agent, I may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, I will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. I will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to Appeal

If I decline to take action regarding your request, I will inform you of my decision and the reasoning behind it. If you wish to appeal my decision, please email me at [email protected]. Within sixty (60) days of receipt of an appeal, I will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.

Do I Make Updates To This Notice?

In Short: Yes, I will update this notice as necessary to stay compliant with relevant laws.

 I may update this privacy notice from time to time. The updated version will be indicated by an updated ‘Revised’ date and the updated version will be effective as soon as it is accessible. If I make material changes to this privacy notice, I may notify you either by prominently posting a notice of such changes or by directly sending you a notification. I encourage you to review this privacy notice frequently to be informed of how I am protecting your information.

How Can You Contact Me About This Notice?

If you have questions or comments about this notice, you may email me at [email protected] or contact me by post at:

Slavi Kaloferov

How Can You Review, Update, or Delete the Data I Collect from You?

Based on the applicable laws of your country, you may have the right to request access to the personal information I collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.