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Company Violina 2013 Ltd. BG202831878, headquartered at 9 Pavlikeni Street, Pernik, with CEO Violina Borisova, processes personal data as a data controller within the scope of its main activity. This includes providing fitness services to association members and ensuring accompanying services from authorized partners of the sports club. The process involves the collection and processing of personal data such as names, phone numbers, email addresses, and similar information from both the company itself and its authorized partners. These data are stored and processed for the purpose of providing specific fitness services and accompanying services. It is explicitly emphasized that the company collects and processes personal data only for specific, concrete, and necessary purposes related to the provision of its services. In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, relating to the protection of personal data, Violina 2013 Ltd. requests your explicit consent to guarantee your rights. As part of this process, the company may provide aggregated statistical data on clients, sales, traffic, and related data for the websites of trusted third parties.

It is important to note that these statistical data are depersonalized and do not contain any personal information.

Violina 2013 Ltd. collects and processes personal data for the purpose of providing, developing, and personalizing its website, as well as its fitness services and products. These data are also utilized for conducting research, creating statistics, and ensuring care for clients. Specifically, Violina 2013 Ltd. gathers personal information for the purposes of personal communication, responding to inquiries, and fulfilling requests from clients. Such information may include names, email addresses, IP addresses, and phone numbers. These data are used for direct contact, conducting market research, providing information, and collecting feedback on upcoming products, services, and promotions through email, phone, Viber, and other means.

If you submit inquiries for services or send materials through our website or application, it may be necessary for us to contact you for additional information needed for the processing or fulfillment of your orders and requirements. Your personal information will be kept confidential and will not be disclosed to third parties without your prior consent, except where required by legal norms or necessary for the execution of your order and the improvement of the services provided.

The website and application may use various technologies that allow Violina 2013 Ltd. to collect specific technical information, such as your IP address, the operating system of your computer, the type of internet browser, and the addresses of connected websites. This information is used to enhance the services offered.

When using our website, we collect technical information from you.

Every time you visit the website, mobile application, or other internet services, the system automatically generates and records specific information.


This includes categories such as:

a/ Data in log files: Our servers automatically record information sent by your browser when visiting the website or using the mobile application. This information includes IP address, activity on visited websites, searches, browser type and settings, date and time of the request, as well as data about "cookies" and devices.

b/ Cookie data: We use "cookies" or similar technologies to capture data, which can be session-based (lasting until you close the browser) or persistent (lasting until deleted by you or your browser).

They are used, for example, to store language preferences and settings.

c/ Device information: In addition to the data in log files, we collect information about the device you use to access the website.

This includes device type, operating system, settings, and unique identifiers that help us understand the system's operation in case of crashes. The collection of this information depends on the type of device and its settings.

Information Regarding the Provision of Our Services

When performing certain services, such as issuing a club card or generating an invoice, it may be necessary for you to provide us with personal data. This information is utilized for the creation and execution of the contract between us and for the provision of our fitness services.

If you link your profile to ours on Facebook, Google, or other third-party services, we may obtain information from these profiles, such as friend lists or contacts.

The information provided by these services depends on the settings and privacy statements of each individual; therefore, it is advisable to carefully review these settings.

We gather information regarding your utilization of our services, combining it with previously collected data, aiming to measure, comprehend, and report on your experience with our services for continual improvement in their quality.

For the normal functioning of our website and in alignment with business logic, we conduct basic analysis of your user behavior. In this context, we utilize tools such as Google Analytics, Facebook Pixel, and CAPI/conversion API/. Before obtaining your consent, we have deactivated advertising functionalities in Google Analytics, Facebook Pixel, and CAPI/conversion API/, taking steps to anonymize your IP address.

This approach is directed towards minimizing the volume of collected information to what is necessary for measurement, ensuring that these data are not used for purposes other than analysis. This ensures the protection of our legitimate interest in the normal operation of the services provided by us.

Information on the execution of selection, delivery, and reporting of advertisements

Our business strategy is based on providing free access to the content of our website and application, funded by us. We collect and process information, combined with previously collected data, for the purpose of selection and delivery of relevant advertisements, as well as measuring their delivery and effectiveness. This includes analyzing previous interests in selected ads, processing user behavior data when displaying ads, frequency of broadcasting, time and place of display, and user reactions, including clicks and purchases.

By accepting a request for account registration or confirming an order for a service or product, the user expressly consents to the processing and transfer of their personal data for:

a/ Inclusion of user ratings and opinions in marketing research through electronic means, such as email or messenger.

b/ Receiving electronic messages for products, services, and other advertising messages on all owned devices.

c/ Receiving personalized advertising adapted to the user's preferences, based on the assessment of their behavior data.

d/ Receiving personalized trade offers tailored to the user's behavior and preferences, through email, mail, or messenger. For this process, data on the user's purchases, participation in advertising campaigns, and website usage may be analyzed and used to predict their interests.

e/ Receiving non-personalized advertising, including information about current products, services, initiatives, and other advertising messages.

Information on Personalization and Profiling

We collect and process data regarding the use of our services with the aim of providing personalized advertising and/or content in various contexts, such as on other websites and mobile applications at a later time. Typically, we utilize your behavior and consumption of content on our website or mobile application to draw conclusions about your interests. These conclusions are then employed to guide future choices in delivering personalized advertising and/or content.

This is how we target and retarget you.

Information Gathered in the Context of Collaborative Projects with Third Parties

We may utilize your personal data to keep you informed about games and promotional offers related to us, as well as to clubs that are our partners. For this purpose, we collect your personal data to provide you with information about initiatives, promotions, games, offers, and more, both from us and from third parties that are our partners. To achieve these objectives, we may employ tools from third parties.

Information about Personalized Marketing

In order to send you current and valuable information about our initiatives, we collect data such as your email or other contact methods like Viber, Skype, Messenger profile, or other communication platforms. We will not spam you, as we also dislike spam.

Purposes of Data Processing and Storage

Violina 2013 Ltd processes and stores provided personal data solely for the purpose of fulfilling its contractual obligations. This involves handling user requests and delivering its services.


Additionally, the data is processed for the following purposes:

a/ In the context of pre-contractual relationships, in accordance with Article 6, paragraph 1, letter "b" of the Regulation;

b/ For the performance of already established contractual obligations, in accordance with Article 6, paragraph 1, letter "b" of the Regulation;

c/ For non-personalized advertising, in accordance with Article 6, paragraph 1, letter "a" and Article 7 of the Regulation;

d/ For personalized advertising, in accordance with Article 6, paragraph 1, letter "a" and Article 7 of the Regulation;

e/ For conducting personalized assessments of information, in accordance with Article 22, paragraph 2, letter "c," Article 6, paragraph 1, letter "a," and Article 7 of the Regulation;

f/ For marketing purposes, in accordance with Article 6, paragraph 1, letter "e";

g/ For retargeting related to marketing purposes, remarketing, or optimization, in accordance with Article 6, paragraph 1, letter "e" of the Regulation.

Data Retention Period

Personal data is stored and processed during the period in which the user's profile is active and until 1 year after its deactivation or deletion. They are also retained as long as necessary for the provision of our services. Upon receiving a relevant deletion request, the information is promptly destroyed.


For delivery purposes, when requested by the user, Violina 2013 Ltd may provide the respective personal data to courier companies or national postal operators. In connection with this, the user may receive SMS messages or calls from these organizations.

Rights Regarding Personal Data

To use your rights regarding personal data, please use the CONTACT FORM on the website ( or send your request to or via mail to the

management address provided above. Requests should be made in a manner that allows the identification of the requester. For some rights, technical options, such as an unsubscribe button, may be provided. The administrator will respond or address the request within one month of receiving

According to the General Data Protection Regulation (GDPR),

data subjects have the following rights:

  1. Information: The right to be informed by the data controller about the processing of their personal data and to be notified in case of a security breach.

  2. Access and Withdrawal of Consent: The ability to request access to their personal data and to withdraw their consent for processing at any time.

  3. Correction: The right to request correction of inaccurate or outdated personal data.

  4. Deletion ("Right to be Forgotten"): The option to request the deletion of their personal data, with exceptions specified in the regulation.

  5. Limitation of Processing: The right to request limitation of processing of their personal data in certain situations.

  6. Data Portability: The ability to receive their personal data in a structured, widely used format and transfer it to another controller.

  7. Objection to Processing: The right to object to the processing of their personal data, including in the case of direct marketing.

  8. Not to be Subject to Automated Profiling-based Decisions: The right not to be subject to decisions based solely on automated profiling.


To exercise these rights, the data subject should use the CONTACT FORM on the website or send the request to A response from the administrator will be provided within one month

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