Политика за поверителност / Privacy Policy
Privacy Policy
1. Data controller
, operator of apartmentforsalebulgaria.com.
Controller location: United States
Privacy contact: admin@apartmentforsalebulgaria.com
2. Scope
This policy explains data processing when you visit the website, use pages monitored by the internal statistics system, send an inquiry or private-viewing request, and when the website is technically maintained and protected.
3. What the internal statistics system records
| Category | Information that may be recorded |
|---|---|
| Visit | date/time, page viewed, landing page, page title and site-language version |
| Source | direct visit, search engine, social network, referring website/domain and campaign UTM parameters |
| Search term | only when the referring service actually provides it or when a campaign provides a term such as utm_term; Google normally does not reveal an organic search phrase to the destination website |
| Approximate location | country only when the server or CDN already provides a country code; this plugin does not send the visitor's IP address to an outside geolocation service |
| Device | device type, browser, operating system, browser language and time zone |
| Interactions | clicks, outbound links, video play/pause/completion and approximate scroll depth (25%, 50%, 75%, 90%) |
4. IP addresses and visitor identifier
The web server necessarily receives an IP address in order to deliver a page. The statistics system does not store the raw IP address in its statistics table. To estimate unique visitors for one day, the IP address and User-Agent are processed temporarily and transformed with a protected HMAC function into a pseudonymous hash. The hash changes each day and is not designed for long-term cross-day tracking.
Separately, standard server security/diagnostic logs may temporarily contain IP addresses according to the hosting configuration. Those logs are used only as necessary for security, troubleshooting, abuse prevention and service operation.
5. Purposes and legal basis
Internal statistics are used to measure interest in the property, determine which pages and language versions are useful, understand traffic sources, detect technical problems and protect the site from abuse. Where the GDPR applies, this processing relies on the controller's legitimate interests under Article 6(1)(f), subject to necessity, proportionality and data-minimisation principles. Where applicable law requires prior consent for a particular technology, legitimate interests are not used to override that requirement.
6. Cookies and local storage
Apartment Visitor Statistics does not use analytics cookies and does not create a tracking identifier in localStorage. If you explicitly exclude this browser from statistics, one functional preference cookie, avs_optout=1, is stored for up to one year solely to remember that choice. It is not used for analytics or advertising.
WordPress or other site functions may use strictly necessary cookies. If a separate third-party service is enabled (for example Google Analytics, an advertising pixel, or an embedded service requiring consent), its own disclosure and consent requirements apply in addition to this policy.
7. Inquiries, contact and private viewings
If you voluntarily submit a form, email or private-viewing request, the website may process your name, email address, telephone number, message, preferred date/time and any other information you choose to provide. The information is used to answer you, arrange a viewing, communicate about the property and take steps at your request before a possible transaction. The legal basis may be Article 6(1)(b) GDPR (pre-contractual steps at your request) and/or Article 6(1)(f) GDPR (legitimate interests in handling inquiries, security and reasonable record keeping).
8. Recipients and sale of data
Statistics data are stored in the website's own WordPress database and are accessible only to authorised administrators and technical providers when required for hosting, maintenance or security. Internal statistics data are not sold, and this plugin does not send them to Google Analytics, advertising networks or data brokers.
9. United States hosting and international transfers
The website and its database are hosted on server infrastructure in the United States. Information submitted by visitors in the EU/EEA may therefore be stored in or accessed from a country outside the EU/EEA. Where GDPR Chapter V requires an international-transfer mechanism, the controller applies the legally applicable mechanism and appropriate safeguards for the relevant hosting/provider relationship. Information about the safeguards applicable to a particular transfer may be requested using the privacy contact above.
10. Retention
Internal statistics events are automatically deleted after 90 days. Inquiry and viewing-request data are ordinarily kept for up to 12 months after the last substantive communication, unless a longer period is required for a contract, legal obligation, accounting purpose, or establishment/exercise/defence of legal claims. Server logs are kept only for the period needed for security and diagnostics under the active technical configuration.
11. Automated decision-making and profiling
The internal statistics system is not used to make decisions that produce legal effects concerning a visitor or similarly significantly affect a visitor. This plugin does not perform advertising profiling.
12. Your rights
Where the GDPR applies, depending on the circumstances you may have rights of access, rectification, erasure, restriction, data portability, objection to processing based on legitimate interests, and withdrawal of consent where processing is based on consent. Requests may be sent to admin@apartmentforsalebulgaria.com.
Because the statistics system does not retain raw IP addresses and rotates its pseudonymous hash daily, the controller may in some cases be technically unable to link a particular statistics record to a specific person. Additional identifying data will not be collected solely to re-identify an anonymous/pseudonymous statistics record.
13. Objection / browser opt-out
This browser is currently excluded from internal statistics.
Enable anonymous statistics for this browser
14. Security
Reasonable technical and organisational measures are used, including restricted administrative access, field minimisation, no raw IP storage in the statistics database, daily rotation of the pseudonymous identifier and automatic retention cleanup. No Internet system can guarantee absolute security.
15. Children
The website is intended for people seeking information about real property and is not directed at children. The internal statistics system is not intended to knowingly collect children's personal data.
16. Supervisory authority
If you believe your data-protection rights have been infringed, you may lodge a complaint with a competent supervisory authority. In Bulgaria, the supervisory authority is the Commission for Personal Data Protection (CPDP), 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria; email: kzld@cpdp.bg.
17. Changes to this policy
This policy may be updated if website functions, service providers, retention periods or applicable legal requirements change. The current version will always be published on this page.