Privacy and Cookies

How KAGAMI Ltd. processes your personal data when you use kagami.bg.

01Who processes your data

The controller of personal data for the services, subscriptions, the Academy and the forms on kagami.bg is KAGAMI Ltd. (КАГАМИ ЕООД), UIC 103141758, registered office and address of management: Varna, 84 General Gurko St., email office@kagami.bg, telephone +359 888 922 262.

For donations through podari.eu, for the free trainings for non-governmental organisations and social professions, and for the Children's Library, the controller is the East Accelerator Foundation (Фондация „Източен Акселератор“), UIC 206227494. KAGAMI Ltd. provides the technical environment for them as a processor acting on behalf of the foundation.

02What data we collect

Service order: name, email, optionally a phone number; for a company — name, UIC and VAT no.; the service you chose, your note and the consents you ticked.
Email enquiries and contact forms: name, email and your message.
Invoicing and payment: the data needed for the invoice. Payment is by bank transfer; we do not receive or store card numbers.
Documents and data you give us to work on for a service — see section 4.
Technical data: IP address, browser type and server log entries needed for the security and operation of the site.

03Why we process it

Purpose	Legal basis (Art. 6(1) of the General Data Protection Regulation)
Replying to an order and steps prior to the contract	Taking steps at your request prior to entering into a contract — point (b)
Performing a service or subscription	Performance of a contract — point (b)
Invoices and accounting	Legal obligation — point (c)
Replying to an enquiry that is not an order	Legitimate interest in replying to you — point (f)
Site security (server logs)	Legitimate interest — point (f)
Working with a cloud AI model on your data	Your explicit consent for the specific task — point (a) (see section 4)

We do not use your data for advertising and we do not profile.

04Your data and artificial intelligence

By default we process your documents and data with AI locally, on our own hardware in Varna. They are not sent to external cloud services.
We use a cloud AI model only with your explicit written consent for the specific task. In that case the data is de-identified as far as the task allows, we use a provider with a data processing agreement and with processing in the European Union where available, and we tell you in advance who the provider is.
We do not train models on your data.

05Who we share data with

We do not sell personal data. We share it only with providers without whom the service cannot work:

SuperHosting.bg — hosting of the site and mail (servers in the EU).
Cal.com — the meeting scheduling system, if you book a slot through it.
Accountant and bank — for invoices and payments.
Public authorities — only when the law requires it.

The “Share” buttons are plain links — they do not load social network scripts and do not send them any data until you click them.

Log in with Google, Facebook or LinkedIn

You can log in to kagami.bg with your Google, Facebook or LinkedIn account instead of an e-mail link. The provider then sends us only: your name, your e-mail and an identifier by which it recognises you to us (with Google and LinkedIn — also whether the e-mail is verified). We use them to recognise you at your next log-in and to connect the log-in with your profile by e-mail. Legal basis: the contract or the steps before it that you ask for (Art. 6(1)(b) GDPR).

We never post anything on your behalf, we do not read friends, contacts or posts, and we do not keep the access keys (tokens) the provider gives us — they are used only at the moment of log-in and then discarded. We keep only the provider's name and the identifier while you have a profile; when you delete the profile, we delete them. The provider learns that you logged in to kagami.bg under its own privacy rules.

Draft for legal review · 03.10.2026.

06Cookies and browser storage

The site does not use advertising or analytics cookies and therefore does not show a consent banner.

What	Why	Where and how long
`kgm_mode`	Remembers whether you are viewing the HUMAN or the AGENT view	In your browser's storage until you clear it; it is not sent to us

You can delete this storage at any time from your browser settings.

07How long we keep the data

The general rule: we keep your data until you ask us to delete it. When you ask, we anonymise it — we remove everything by which you could be identified. Only aggregate figures for statistics remain (for example, how many orders we had for a given service), which are no longer personal data.

Exception — invoices and accounting documents: we keep them for the periods required by the Accounting Act (Zakon za schetovodstvoto), even if you ask for deletion, because the law obliges us to. After that we anonymise them.
Server logs (IP address, browser type) — up to 90 days, then deleted automatically.
The Children's Library has its own, shorter retention periods — they are described next to the “I have a question” form.

To request deletion, write to office@kagami.bg. We reply within one month.

08Your rights

You have the right of access to your data, to rectification, erasure, restriction of processing, portability and objection. Where processing is based on consent, you can withdraw it at any time. Write to us at office@kagami.bg — we reply within one month.

You have the right to lodge a complaint with the Commission for Personal Data Protection (CPDP; Komisia za zashtita na lichnite danni): Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd · cpdp.bg.

09Children

The services and orders on kagami.bg are for adults. The Children's Library is used without registration and without collecting data about children. When a child under 14 wants to ask a question, the data is processed only after the consent of a parent or guardian.

10Contact and changes

KAGAMI Ltd. (КАГАМИ ЕООД) · UIC 103141758 · Varna, 84 General Gurko St. · office@kagami.bg · +359 888 922 262

If this policy changes, we publish the new version here, with a number and a date.

Version: draft v0.1 · 03.10.2026 · pending legal review.