Privacy & Cookies Policy

Last updated: 20 July 2026

This Privacy & Cookies Policy explains how Lux Surface Group EOOD, trading as Leather Floors Bulgaria by Lux Surface Group, processes personal data and how cookies and similar technologies may be used on the Leather Floors Bulgaria website.

1. Who We Are

The data controller is:

Lux Surface Group EOOD
Trading as Leather Floors Bulgaria by Lux Surface Group

UIC / EIK: 208757783
VAT number: BG208757783
Registered address: 15 Aleksandar Matrosov Street, 4204 Tsaratsovo, Bulgaria
Email: office@leatherfloors.bg
Telephone: +359 883 456 557
Website: leatherfloors.bg

Lux Surface Group EOOD has not appointed a formal Data Protection Officer. Privacy-related enquiries and requests should be sent to office@leatherfloors.bg.

2. How We Receive Personal Data

We may receive personal data when you:

• contact us by email, telephone, messaging service or social media;

• book a consultation through our external Google Calendar booking page;

• request samples, product information or a quotation;

• discuss an active or prospective project with us;

• provide a physical business card or otherwise share professional contact details;

• place an order or provide information needed for invoicing and delivery;

• communicate with us during an active project or professional relationship.

Our website does not currently contain an enquiry form, customer account, online checkout, newsletter subscription, embedded map or embedded social-media feed.

Most website buttons relating to samples, projects or enquiries direct visitors to the Contacts page. The Request a Consultation button leads to an external Google Calendar booking page.

3. Personal Data We May Process

Depending on the nature of the enquiry, project or order, we may process:

• name and surname;

• email address and telephone number;

• company name, professional role and business contact details;

• company registration and VAT details;

• billing, delivery or project address;

• project name or reference;

• project descriptions, measurements, quantities and requested products;

• drawings, plans, photographs or other project materials voluntarily provided to us;

• correspondence and meeting information;

• sample requests and selected materials;

• quotations, proforma invoices, invoices, payments and order history;

• delivery and logistics information;

• professional contact details obtained in the context of a relevant business interaction.

The Google Calendar booking page currently requests a first name, surname and email address. A telephone number may be provided optionally. A Google Meet link may be created for the booked consultation.

We do not currently record telephone calls, Google Meet sessions, audio consultations, video consultations or screen-sharing sessions.

4. Why We Process Personal Data

We process personal data where necessary to:

• respond to enquiries and provide requested information;

• arrange consultations;

• prepare samples and quotations;

• assess the requirements of a specific project;

• take steps requested before entering into a contract;

• process and manage orders;

• issue proforma invoices and invoices;

• receive and reconcile payments;

• coordinate delivery;

• communicate about active or prospective projects;

• maintain necessary business and accounting records;

• comply with legal and regulatory obligations;

• establish, exercise or defend legal claims;

• maintain the security and proper administration of our business.

Depending on the circumstances, the legal basis may be:

• taking steps at your request before entering into a contract;

• performance of a contract;

• compliance with a legal obligation;

• our legitimate interests in responding to relevant business enquiries, maintaining professional relationships, administering projects and protecting our legal rights;

• consent, where the law specifically requires it.

5. Business Communications and Follow-Up

We do not currently use personal data for newsletters, bulk marketing or automated promotional campaigns.

We may send individual follow-up communications where a person has:

• requested information;

• asked for samples or a quotation;

• provided contact details in the context of a relevant business discussion;

• expressed an interest in Leather Floors Bulgaria;

• become involved in an active or prospective project.

Such communications will be limited to the subject and reasonable context of the original interaction.

You may ask us to stop further follow-up communications at any time by contacting office@leatherfloors.bg.

6. Special Categories of Personal Data

We do not require or intentionally collect special categories of personal data, sometimes referred to as sensitive personal data, through general enquiries.

Please do not send health information, genetic or biometric data, information concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, sex life or sexual orientation, identity documents, or other unnecessary sensitive details through:

• email;

• SMS;

• telephone or messaging services;

• video-conferencing or chat services;

• social media;

• booking services;

• any other communication channel.

If we receive special-category data that is not necessary for the relevant enquiry, we will not use it and will delete copies under our control without undue delay, unless its temporary retention is required by law or is necessary to establish, exercise or defend a legal claim.

7. Who May Receive or Access Personal Data

Access is limited to persons and organisations that reasonably require the information for the relevant purpose.

These may include:

• authorised representatives or personnel of Lux Surface Group EOOD;

• Google Workspace and other cloud-based productivity providers;

• domain registration, DNS and web-address forwarding providers;

• selected AI-assistance providers used for limited business administration, subject to access controls, data minimisation and human review;

• device and cloud-storage providers;

• our external accounting service provider;

• our invoicing service provider;

• our bank and relevant payment-service providers;

• courier or logistics companies where delivery is arranged through an external provider;

• legal, accounting, insurance or other professional advisers;

• public authorities where disclosure is required by law.

Where a courier or logistics provider is used, we may provide the recipient’s name, telephone number, delivery address and other information reasonably necessary to complete the delivery.

Where delivery is performed directly by Lux Surface Group EOOD, the delivery information remains within the company.

We do not ordinarily share end-client contact details with manufacturers or suppliers. Manufacturers may receive product specifications, quantities and other non-personal information required to prepare the order.

We do not sell personal data.

8. Cloud Services and International Processing

Some of our technology and cloud-service providers operate internationally and may process information through infrastructure located in different countries.

Where personal data is transferred outside the European Economic Area, we will use service providers and arrangements intended to provide a lawful level of protection, such as an applicable adequacy decision, approved contractual safeguards or another transfer mechanism recognised by data-protection law.

9. How Long We Retain Personal Data

We retain personal data only for as long as reasonably necessary for the relevant purpose and any applicable legal, accounting, contractual or claims-related requirement.

Our current retention approach is:

Unsuccessful enquiries, sample requests and quotations

Information relating to an enquiry, sample request or quotation that does not result in an order may be retained for up to 24 months after the last meaningful communication, unless a longer period is required by law or necessary in connection with a legal claim.

Projects and orders

Project and order records may be retained for up to 10 years where necessary for accounting, tax, contractual or legal purposes.

Routine correspondence and duplicate contact information may be deleted earlier where it is no longer needed.

Professional contacts

Professional contact details may be retained while there is an active or reasonably anticipated business relationship, including where the contact may be relevant to future projects or may contact us again.

Information will not be retained indefinitely where there is no longer a legitimate business or legal reason to keep it.

Special-category data

Unnecessary special-category data will be deleted without undue delay, subject to the limited legal exceptions explained above.

10. Security

We use reasonable technical and organisational measures intended to protect personal data against unauthorised access, disclosure, alteration, loss or misuse.

These measures may include:

• password-protected devices and accounts;

• two-factor authentication;

• controlled access to business systems;

• secure cloud services;

• device security and encryption;

• limiting access according to business need;

• human review of business communications and AI-assisted output.

No electronic system or method of communication can be guaranteed to be completely secure. Please avoid sending unnecessary confidential or sensitive information through ordinary communication channels.

11. Your Data-Protection Rights

Depending on the circumstances and applicable law, you may have the right to:

• request access to your personal data;

• request correction of inaccurate or incomplete information;

• request deletion of personal data;

• request restriction of processing;

• object to processing based on legitimate interests;

• object to direct marketing;

• request data portability where applicable;

• withdraw consent where processing is based on consent;

• lodge a complaint with a supervisory authority.

Privacy-related requests may be submitted to:

office@leatherfloors.bg

Where we have reasonable doubts about the requester’s identity, we may ask for additional information that is reasonably necessary to confirm their identity before acting on the request.

We will respond within the time limits required by applicable law.

GDPR recognises rights including access, correction, erasure, restriction, objection and portability, and allows additional identity information to be requested where reasonable doubts exist.

12. Complaints

You have the right to lodge a complaint with the Bulgarian supervisory authority:

Commission for Personal Data Protection — CPDP
2 Prof. Tsvetan Lazarov Blvd.
Sofia 1592, Bulgaria
Email: kzld@cpdp.bg
Website: cpdp.bg

The CPDP is Bulgaria’s independent supervisory authority for compliance with the GDPR and the Bulgarian Personal Data Protection Act.

13. Automated Decision-Making

We do not currently use automated decision-making or profiling that produces legal or similarly significant effects concerning website visitors, clients or professional contacts.

14. Children

The website is intended primarily for adult, professional and business audiences. It is not specifically directed at children.

We do not knowingly request personal data from children through the website. If we become aware that unnecessary personal data concerning a child has been provided to us, we will take reasonable steps to delete it.

Cookie Policy

15. What Cookies Are

Cookies are small text files or similar technologies that may be stored on a device when a website is visited. They may support essential website functionality, security, user preferences or website measurement.

16. Cookies Used on This Website

The Leather Floors Bulgaria website is built and hosted using Google Sites.

Google uses cookies and similar technologies to deliver and secure its services, remember certain choices and analyse how its services are used. Information about a visitor’s use of the website may therefore be processed by Google in accordance with Google’s own privacy and cookie terms.

Google Sites displays a cookie consent notice to relevant visitors in the European Union. Where non-essential cookies are used, visitors may be given the option to accept or reject them.

Lux Surface Group EOOD does not use advertising, remarketing or third-party advertising cookies on this website.

17. Google Analytics

Google Analytics is used on the Leather Floors Bulgaria website to help us understand how visitors use the site and to improve its content, navigation and performance.

Depending on the visitor’s cookie choices, Google Analytics may process technical and usage information such as pages viewed, referral source, device and browser information, approximate geographic information and interactions with website content.

We do not use Google Analytics for personalised advertising or remarketing.

Google Sites displays a consent dialog to relevant visitors in the European Union. Visitors may accept or reject non-essential cookies. If analytics cookies are rejected, information about website visits and activity may be incomplete.

User-level and event-level Analytics data is configured to be retained for up to 14 months. Standard aggregated reports may remain available for longer within Google Analytics.

Google confirms that when Analytics is used on a Google Site, relevant EU visitors are shown a consent dialog with options to accept or reject non-essential cookies.

18. Embedded Content and Third-Party Tools

The website does not currently embed:

• Google Maps;

• YouTube or other video services;

• Google Forms;

• Instagram or LinkedIn feeds;

• live-chat widgets;

• payment or checkout services;

• newsletter tools;

• advertising pixels.

The website includes external links to services such as:

• Google Calendar;

• Google Meet;

• Instagram;

• LinkedIn.

When you follow an external link, you leave the Leather Floors Bulgaria website. The relevant third-party service may process information and use cookies under its own privacy and cookie policies.

Lux Surface Group EOOD does not control the cookies or privacy practices of external websites and services.

19. Managing Cookies

You may use the Google Sites cookie notice, where displayed, to accept or reject non-essential Google cookies.

You can also manage or delete cookies through your browser settings. Blocking certain cookies may affect how some website functions operate.

20. Changes to This Policy

We may update this Privacy & Cookies Policy when:

• our website changes;

• new services or technologies are introduced;

• our business processes change;

• legal or regulatory requirements change.

The current version will always be published on this page, together with the date of the latest update.

21. Contact Us

For questions about this Privacy & Cookies Policy or the way we process personal data, contact:

Lux Surface Group EOOD
Leather Floors Bulgaria by Lux Surface Group
Email: office@leatherfloors.bg
Telephone: +359 883 456 557