This is a courtesy English translation of the Bulgarian original (Политика за поверителност). In case of any discrepancy, the Bulgarian version prevails.
Privacy and Cookie Policy
www.ninorai.com
Навиа Систем ДПК (Navia Sistem DPC) („Controller“, „We“, „Company“) highly values the privacy of your personal data. This privacy and cookie policy („Policy“) contains information about the purposes of and the ways in which we use your personal data in connection with the provision of our services („Services“) in the SEO platform for AI-generated content Ninorai („Platform“) with web address (URL): www.ninorai.com
Please read this Policy carefully in order to understand how we collect, use, protect and process your personal data in accordance with the applicable legislation, including the General Data Protection Regulation (EU) 2016/679 („GDPR“), the Bulgarian Personal Data Protection Act („PDPA“) and the applicable European legislation.
1. Definitions
„Platform“, „Website“, „Site“ – a set of web pages and related content accessible on the Internet, identified by the common domain name www.ninorai.com .
„Personal data“ – any kind of information relating to an identified or identifiable person.
„Cookies“ – small files that a site or service provider stores in the memory of your device through the browser you use (if you have allowed this).
„Personal data controller“ – a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
„User“ – a representative, employee or agent of a business registered as a user of the services on the Platform.
2. Controller
The personal data controller is the company Навиа Систем ДПК, entered in the Commercial Register at the Registry Agency with UIC (ЕИК) 208893566, with registered office and management address: Burgas 8000, 15 Odrin St., fl. 4
3. What data do we process and for what purposes?
We collect the information provided by you through filling in registration, contact and other forms on the Platform when creating a user account, when paying for the services, when browsing the website or when otherwise using the services of the Platform. All mandatory data fields are marked as such and must be filled in, while the remaining ones are marked as voluntary and are not mandatory to fill in.
Depending on the services used, we may process the personal data listed in the table below for the purposes stated and on the legal basis for their processing, within the periods for their retention.
|
Purpose |
Personal data |
Legal basis |
Retention period |
|
Registration and account management data |
|
The processing is necessary for the performance of a contractual obligation towards you. Your consent |
The data is retained until the moment you withdraw your consent through an explicit written request for termination of the contract and deletion of the registration. |
|
Access and security data |
|
The processing is necessary for the performance of a contractual obligation we have towards you. Legitimate interest. |
No longer than necessary to achieve the purposes for which the data was collected. |
|
Data for the management of subscriptions, payments and invoicing |
|
Performance of a contractual obligation towards you. Your explicit consent. |
No longer than necessary to achieve the purposes for which the data was collected. |
|
Data entered into the AI system |
|
Performance of a contractual obligation towards you. Your explicit consent |
Personal data collected through cookies and similar technologies will be processed until you change your cookie preferences. |
|
Marketing purposes |
|
Your explicit consent |
Personal data necessary for marketing purposes will be processed until the moment you withdraw your consent to receive such communication. |
4. How do we use the collected information?
Any information we collect from you may be used in the following ways:
- For registration and account management;
- For providing AI SEO functionalities;
- For content generation and optimization;
- For automated SEO analyses;
- For technical support and information security;
- For managing subscriptions and payments;
- For fulfilling legal obligations;
- For marketing where a legal basis exists;
- For improving the services
5. Is your personal information disclosed to third parties?
The collected personal data is not sold, exchanged or in any other way transferred to third parties, except in the cases specified. The information may be provided to contractors, subcontractors and other trusted partners who work on assignment from us on the basis of contractual relations and under confidentiality agreements. However, these companies do not have the right to share this information independently.
Third parties and services that the Platform uses or may use:
- Hosting and storage: Hetzner Online GmbH (Germany, EU) – servers, databases and file storage of the Platform;
- Network security and CDN: Cloudflare, Inc. – protection and acceleration of traffic to the Website;
- AI model providers: Anthropic PBC (text generation), OpenAI and fal.ai (image generation), Voyage AI (vector representations of content) – process content entered by the User solely for the provision of the Services;
- Payments: Stripe, Inc. – processing of payments and subscriptions (card data is processed only by the payment provider and is not stored by us);
- Email: Google Ireland Ltd. (Google Workspace) – transactional and service emails;
- Traffic analytics (when activated and after your consent): Google Analytics 4, Microsoft Clarity.
Information may be provided to law enforcement authorities if requested and where this is necessary for compliance with the law, with the Terms and Conditions for the use of the website and our services, or for the protection of the rights, property or safety of the Controller and of other persons. Any collected information that does not constitute personal data or does not contain classified information may be provided to third parties for marketing, advertising or other purposes.
6. AI processing and automated decision-making
The Platform uses AI models for:
• generation of SEO texts;
• keyword analysis;
• automated recommendations;
• language modeling and editing.
The AI functionalities may include automated processing of entered data, but they are not used for making legally significant decisions within the meaning of Art. 22 GDPR.
Users should not enter:
(a) special categories of personal data;
(b) company information constituting a trade secret;
(c) data without a legal basis for processing.
The Controller may use external AI providers and cloud infrastructure for the provision of the services.
7. Do we use cookies?
We use cookies for the provision of the services on the Platform. Cookies usually do not contain information that personally identifies a user, but the personal data we store about you may be linked to the information stored in and obtained from cookies. The following types of cookies are used on the Platform:
- „Essential cookies“.
These are necessary for the normal provision of the services of the Platform, for example for identifying a given user when using our services and for saving part of the site’s code and other relevant purposes.
- „Performance and functionality cookies“
These cookies are not mandatory for accessing and using the Website, but they allow us to personalize the online experience of each user while using our web pages. Through them we remember your preferences so that you do not need to enter information you have already provided every time. For example, when you enter your credentials for access to our services.
- „Advertising cookies“
These cookies use information about the way each user uses our Site – the pages they visit or the way they respond to advertisements, if any. - „Third-party cookies“ – Google Analytics, plugins, etc., stored by a domain different from the domain of the visited page, which help us track the traffic of the Website, and other cookies related to external systems and sites integrated into the site. They provide data about location, browser, browser version and others.
You have the possibility to change your cookie preferences at any time by changing the options of your browser. To block cookies in a specific browser, learn more here:
- Managing cookies in Google Chrome
- Managing cookies in Firefox
- Managing cookies in Internet Explorer
- Managing cookies in Safari
- Managing cookies in Brave
Refusing cookies may lead to limited functionality or the inability to use the Services.
8. How do we store and protect your personal information?
The Controller complies with the requirements of the PDPA and the GDPR regarding the collection, use and protection of personal data and applies all necessary technical and organizational measures recognized by the applicable data protection law in order to protect all data it may store and/or process. We do not operate or store personal data outside the European Economic Area. The Platform’s data is stored on servers rented by us in a data center of Hetzner Online GmbH in Germany (EU), and the backups are encrypted.
We do not transfer the collected personal information to a country or jurisdiction that does not have the same high requirements for the protection of personal data comparable to the laws of the Republic of Bulgaria or the European legislation.
In the event of a transfer of personal information and data outside the borders of the EU, we guarantee a high level of data protection through Standard Contractual Clauses (SCC) or other instruments recognized by the applicable law.
We apply appropriate measures to protect your personal data from accidental loss and unauthorized access, use, alteration or disclosure. Procedures are in place designed to protect the information from loss, misuse and unlawful disclosure. Although we work hard to protect your personal data, we cannot guarantee that our actions will prevent every unauthorized attempt to access, use or disclose personal data. Nevertheless, if you believe that there is a threat to the security of your personal data, please contact us immediately using the contact details specified in section 14 of the Privacy Policy.
We apply additional information security measures, including access control, strict technical protection and reliable practices for the collection, storage and processing of the information. The processing of personal data is secured with modern technical means.
Payments are processed by Stripe. The payment operator Stripe applies its own Privacy Policy in its capacity as an independent personal data controller.
We use the information provided to us by you (other than customer data) to manage, maintain, improve and provide all the features of the Service you have requested. We process customer data only in accordance with the instructions provided by you as a user.
If you wish to access or change any personal data we hold about you, or request that we delete any information about you that we have obtained through the use of our services, you can contact us at any time through the contact form on our Website or by sending an email to us at: [email protected]. Upon receipt of a request, we will block or delete all information we hold about you from our database. You can update, edit or delete your account information at any time from your customer account.
Please note that although the changes you make are reflected immediately in the active user databases or within a reasonable period of time, we may retain all information you provide for the prevention of fraud, abuse or other legal obligations, or where we believe we have a legitimate reason to do so. If you refuse to provide us with certain personal data, we may be prevented from providing some of the features of the selected Service.
9. Retention periods
The data is retained while the account is active, or otherwise we retain it for a limited period of time for as long as we need it in order to fulfill the purposes for which we originally collected it, unless otherwise provided by law. We will retain and use the information that is necessary to comply with our legal obligations, resolve disputes and enforce our agreements, part of the periods for which are: (a) Payment information is retained for 10 years in accordance with accounting and tax laws; (b) Transaction information is retained for 10 years in accordance with the general limitation period established for civil claims.
10. Supervisory authority
The supervisory authority for personal data protection in Bulgaria is the Commission for Personal Data Protection (CPDP), with address: Sofia, postal code 1592, 2 Prof. Tsvetan Lazarov Blvd., and consumer telephone line: 02/91-53-555. More information about personal data protection can be found on the website of the CPDP – with web address (URL) www.cpdp.bg.
11. Changes to the Privacy Policy
Changes to the personal data privacy rules are published on the site with the date of the last update reflected in them, as well as through communication with the Users where this is required by law. In the event that you do not agree with the changes, you should discontinue the use of the Website and the Services.
12. Your rights
By virtue of the applicable legislation, you have the legally recognized right, free of charge, at any time to object to the processing of your personal data by sending an explicit request through the Website or to the following email address: [email protected].
You have the right to receive access to the personal data we store about you, in a structured, commonly used and machine-readable format, by sending an explicit request or to the following email address: [email protected].
You have the right to request the transfer of your personal data to another controller by sending an explicit request or to the following email address: [email protected].
In the event that part of the information we store about you is incorrect or inaccurate, you have the right to correct it by changing the information contained in your account, by sending an explicit request or to the following email address: [email protected].
You have the right to request the erasure of your personal data by sending an explicit request or to the following email address: [email protected]. This does not apply to those personal data which we are obliged to keep by law.
You have the right to request the imposition of a restriction on the processing of your personal data with regard to individual operations of collecting, processing and sharing them, by sending an explicit request or to the following email address: [email protected].
You have the right to request that third parties who have access to your data be notified of the restrictions, the erasure or the prohibition of processing of your data, so that those third parties delete all links to and copies of your personal data.
We will respond to your request or inform you in writing of the actions taken in connection with the request within two months of receiving the request. This period may be extended by one more month where necessary due to the complexity or the number of the requests, of which you will be duly notified.
13. Minimum age
We do not collect or process personal data provided by minors.
14. Contact us
If you have any questions about this Policy, you can contact us using the contact details below:
„Навиа Систем“ ДПК
Burgas 8000, 15 Odrin St., fl. 4
email: [email protected]
Effective as of 2 August 2026.
Навиа Систем ДПК | 2026 ©