Privacy notice

Who is responsible

Simeon Vanov and Borislav Ivanov, individuals in Bulgaria, are joint data controllers for Belot Coaching. They operate the service as individuals rather than an incorporated company. Questions and rights requests: support@belotcoaching.bg. Postal contact through Simeon Vanov: Timok Street 20, apartment 10, Sofia 1202, Bulgaria.

Simeon coordinates rights requests, technical protection, suppliers and retention. Borislav coordinates user information and publication/moderation context. Both jointly decide purposes, legal bases and material changes. You may exercise your rights against either controller; this internal allocation does not limit your rights.

Data, purposes and legal bases

• Sign-in and account: identifiers, email, name and session information from your chosen sign-in provider; you choose your public username in the application itself. We use what is necessary to provide and protect your requested account on the basis of performing the service contract. We do not receive your external account password.
• Learning: exercises, answers, selected cards/bids, mistakes, results, progress and action times. We save these to provide practice and your history on the same contractual basis.
• Service reports: authorised operators and experts also use saved learning records, completion history and service-derived activity to support learners and assess teaching content, on the basis of our legitimate interest in maintaining and improving the coaching service. These reports can relate to your account and are separate from optional statistics permission; refusing browser statistics does not erase saved answers or prevent them from contributing to these reports. You may object to this use through support@belotcoaching.bg.
• Games and sharing, when you use those features: invitations, participants, notifications, actions, history, selected publications and comments. The basis for requested play and publication is performing the service contract. Moderation and abuse prevention rely on our legitimate interest in protecting participants and the service, or an applicable legal obligation. Public publications may display your username, selected replay and comments. Visitors can copy or forward them. Withdrawal prevents new public access through us but cannot recall copies already received.
• Security and support: technical request/error logs, IP/browser information and correspondence. We rely on our legitimate interest in a secure, working service and preventing abuse; for rights requests and other legal requirements, we fulfil the applicable legal obligation.
• Optional statistics: only with your permission, Google Analytics measures browser visits and interactions. Google receives technical information and coarse page/action context, rather than names, email addresses or free-text answers supplied by us. We do not add these optional browser statistics to your Belot Coaching profile.
• Interaction replay: with separate permission, Microsoft Clarity reconstructs page interactions and heatmaps. This is not a camera or microphone recording. We restrict recording of private pages and mask sensitive elements; that does not automatically anonymise every item of data.

Information comes from you, your actions, browser and chosen sign-in provider. Necessary account data enables sign-in and saved progress; without it those features cannot work. Public learning materials remain accessible. Refusing optional measurement does not prevent practice or saving your answers. Practice scores support learning and are not automated decisions with legal or similarly significant effects.

Recipients and processing outside the EEA

Authorised operators and necessary hosting, email, technical-support and recovery providers have access as required. We use VPS hosting from SuperHosting and a self-hosted mail system. Your selected external sign-in provider also processes information under its terms; Google is offered for sign-in; another provider is involved only if it is available at sign-in and you choose it. With the relevant permission, recipients also include Google Analytics and Microsoft Clarity. Microsoft also processes information under its own Clarity terms. We do not sell your personal data.

External providers may process information outside the EEA, including in the United States. Their published terms describe applicable standard contractual clauses and, where relevant, adequacy decisions. For information about the safeguards relating to your data, contact support@belotcoaching.bg. See Google Privacy, Google's processing terms, Microsoft Privacy and the Clarity information. We do not represent that every copy stays in Bulgaria.

Retention

Account information and saved learning support your account and the history we maintain for you, until closure or a valid erasure request. Related summaries and operational records are assessed at closure. The Google Analytics event setting is 14 months; aggregates and other provider data can have different retention. Clarity retention varies by data type, as described in its information.

Security logs, correspondence and information needed for legal obligations or claims are retained for the relevant necessary purpose with restricted access. After closure, a restricted account identifier may remain only as needed to prevent continued access or restoration of erased data; that need is reviewed as the relevant credentials and backups expire. Recovery backups are not necessarily deleted immediately with an active account. Periods differ between systems; we do not promise that all logs and backups disappear after 30 days. On request we explain what limited information remains, why and for how long.

Your rights and contact

You can close your account and start personal-data deletion from Profile, with fresh sign-in and a separate irreversible confirmation. Accepted closure stops protected access; deletion is in progress until app and sign-in-provider cleanup finishes, with retries when needed. It removes your profile, saved learning, identified usage, own comments and own public shares. Current games end; other players keep completed game history with your direct account link and name removed. Your external sign-in account is not deleted. Limited security/backup records, necessary shared history and text independently written by others can remain for the reasons explained here; contact us about any specific remaining personal information.

Subject to legal conditions, request access/a copy, correction, erasure, restriction or portability; object to legitimate-interest processing or withdraw consent. Email support@belotcoaching.bg; a special form is not mandatory. Identity checks will be proportionate. The normal response period is one calendar month, without a fee. If a permitted extension is necessary, we explain the reason within that first month. We explain the basis if we cannot fulfil a request in full.

You can complain to Bulgaria's Commission for Personal Data Protection or the competent authority where you live, work or believe an infringement occurred, and seek a judicial remedy. Accounts are for people aged 18+; we do not routinely collect birth dates or identity documents to verify age. Contact us if you believe a minor has an account.