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Privacy and Cookie Policy

Lavanis Engineering OOD Version 1.0 · Effective from 14 September 2026 · Last updated 14 September 2026



1. Who is responsible for your data

The controller of your personal data is:

Item

Detail

Legal name

  • Lavanis Engineering OOD (Лаванис Инженеринг ООД)

Company (UIC/EIK) number

  • 208803177

Registered address

  • 24 Simeonovsko Shose Blvd., Section A, floor 3, office 14, 1700 Sofia, Bulgaria

E-mail for data protection matters

  • info@lavanis.com

Telephone

  • +359 877 117 427

Website

  • lavanis.com

Lavanis has not appointed a Data Protection Officer. It is not required to do so under Article 37 GDPR, because it does not carry out large-scale systematic monitoring or large-scale processing of special categories of data. Data protection enquiries are handled at the address above.



2. Scope

This policy explains how Lavanis collects and uses personal data when you:

• visit lavanis.com;

• submit an enquiry, compatibility check or support request;

• register a business account or place an order;

• apply to become a distributor or partner;

• subscribe to updates;

• correspond with us by e-mail, telephone or through social media channels.

Lavanis sells only to business buyers. Even so, information about individuals acting for a business — a name, a work e-mail address, a direct telephone number — is personal data and is protected in the same way. This policy therefore applies to the individuals behind our business customers, not only to private individuals.

This policy does not cover third-party websites we link to. Their own policies apply.



3. What personal data we collect

Category

Examples

Source

Identity and contact data

  • Name, position, company name, business e-mail, telephone - From you

Business verification data

  • VAT identification number, company registration number, trade or agricultural producer registration, business address - From you; verified against VIES and public registers

Order and transaction data

  • Order and invoice numbers, products, quantities, prices, delivery address, order history, correspondence - From you and generated by us

Payment data

  • Payment method, bank account details for transfers, the last four digits and card type for card payments, transaction reference and authorisation result - From you and from our payment service provider. We never receive or store full card numbers, expiry dates or security codes.

Technical and compatibility data

  • Machine make, model, year, ECU part number, serial numbers, fault codes, photographs of ECU labels and engine plates, diagnostic logs - From you

Support and warranty data

  • Fault descriptions, RMA records, test results, correspondence - From you and generated by us

Acceptance and consent records

  • Date, time, IP address, the version of the Terms accepted, the text of the checkout confirmation accepted, account identifier - Generated automatically

Website usage data

  • IP address, device and browser type, operating system, referring URL, pages viewed, time on page, approximate location derived from IP, cookie identifiers - Collected automatically — see section 9

Marketing data

  • Subscription status, preferences, opening and click activity in e-mails - From you and generated automatically

Special categories of data. We do not seek and do not knowingly process data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning sex life or sexual orientation. Please do not include such information in enquiries or in photographs you send us.

Photographs. Photographs submitted for compatibility verification are expected to show equipment, labels and data plates. Please avoid including people, faces, number plates or documents in the frame.



4. Why we use your data, and on what legal basis

#

Purpose

Data used

Legal basis

Retention

1

Responding to enquiries and compatibility checks

Identity, contact, technical

Art. 6(1)(b) — steps at your request prior to a contract; or Art. 6(1)(f) legitimate interest in responding to business enquiries

12 months from last contact

2

Verifying business status and eligibility to buy

Business verification

Art. 6(1)(b) contract; Art. 6(1)(c) legal obligation (VAT); Art. 6(1)(f) legitimate interest in restricting sales to businesses

Life of the account + 5 years

3

Processing and fulfilling orders, delivery, invoicing

Identity, contact, order, payment, technical

Art. 6(1)(b) — performance of the contract

Life of the contract, then per row 6

4

Warranty, returns, RMA and technical support

Order, support, technical

Art. 6(1)(b) contract

Warranty period + warranty period + 3 years

5

Recording acceptance of the Terms and of the intended-use confirmation

Acceptance and consent records

Art. 6(1)(f) — legitimate interest in evidencing the contract and in establishing, exercising and defending legal claims. See section 5.

5 years

6

Accounting, tax and statutory record keeping

Identity, order, payment, invoices

Art. 6(1)(c) — legal obligation under the Accountancy Act, the VAT Act and the Tax and Social Insurance Procedure Code

Invoices and accounting records: 10 years from the end of the reporting period (Art. 12 Accountancy Act)

7

Customs and export compliance

Identity, order, business verification

Art. 6(1)(c) legal obligation; Art. 6(1)(f) legitimate interest in compliance with restrictive measures

5 years

8

Website operation, security, fraud and abuse prevention

Technical, usage

Art. 6(1)(f) — legitimate interest in a secure and functioning website

12 months

9

Analytics and measurement

Usage, cookie identifiers

Art. 6(1)(a) consent (given through the cookie banner)

Per section 9

10

Marketing e-mails to subscribers

Contact, marketing

Art. 6(1)(a) consent; or Art. 6(1)(f) legitimate interest for existing customers as to similar products, per Art. 261 Electronic Communications Act, always with an opt-out

Until you unsubscribe, then retained indefinitely, minimal data only on a suppression list

11

Distributor and partner applications

Identity, contact, business verification

Art. 6(1)(b) pre-contractual steps

12 months if unsuccessful

12

Establishing, exercising or defending legal claims

Any of the above as relevant

Art. 6(1)(f) legitimate interest; Art. 9(2)(f) where applicable

Until the relevant limitation period expires

Where we rely on legitimate interests, we have assessed that our interest is not overridden by your rights and freedoms. You may request a summary of that assessment at info@lavanis.com.



5. Acceptance and intended-use records — what we log and why

When you place an order you must confirm that you are buying as a business and that you accept the intended-use restrictions in our Terms. Because that confirmation is the basis on which we sell a regulated category of product, we keep a record of it.

What we record: the date and time, your account identifier, the version number of the Terms and of the confirmation text you accepted, and the order to which it relates.

Why: to evidence what was agreed, to demonstrate that we sell only to business buyers on stated terms, and to establish, exercise or defend legal claims. Legal basis: Article 6(1)(f) GDPR.

How long: 5 years from the date of the order. This period is set by reference to the general five-year limitation period under Article 110 of the Bulgarian Obligations and Contracts Act and is reviewed annually.

Your rights: you may object to this processing under Article 21 GDPR. Because the record exists to defend legal claims, we may decline an objection or an erasure request in respect of it, and we will explain why if we do.



6. Who we share your data with

We do not sell personal data and we do not share it for third-party marketing.

We share data with the following categories of recipient, each acting either as our processor under a written agreement meeting Article 28 GDPR, or as an independent controller where indicated:

Recipient category

Purpose

Role

  • Website hosting and infrastructure provider — SiteGround, Hosting the website, backups, security - Processor
  • Payment service provider — Stripe Payments Europe, Limited, Card payment processing, fraud checks - Independent controller for its own compliance purposes
  • Bank — UniCredit Bulbank - Bank transfers, settlement - Independent controller
  • Carriers and couriers — DHL - Delivery, tracking, customs presentation - Independent controller
  • Customs authorities and brokers - Export and import formalities - Independent controller / legal obligation
  • Accounting and tax service provider - Bookkeeping, invoicing, statutory filings - Processor
  • Professional advisers — lawyers, auditors - Legal advice, dispute handling, audit - Independent controller
  • Public authorities - Where required by law, court order or a lawful request - Independent controller

We also submit VAT identification numbers to the VIES service operated by the European Commission for validation. That is a verification lookup and does not transfer your other data. In the event of a sale or reorganisation of our business, data may be transferred to the acquirer, subject to the same protections.



7. Transfers outside the EU/EEA

Some of our service providers may process data outside the European Economic Area.

Where that happens, we rely on one of the following safeguards under Chapter V GDPR:

• an adequacy decision of the European Commission for the country concerned; or

• the Standard Contractual Clauses adopted by Commission Implementing Decision (EU) 2021/914, supplemented where necessary by additional technical and organisational measures following a transfer impact assessment.



8. How we protect your data

We apply technical and organisational measures appropriate to the risk, including encryption in transit (TLS), access control on a need-to-know basis, separate administrative accounts, multi-factor authentication where available, regular backups, patching of the website platform, and written processing agreements with our providers.

No system is completely secure. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we notify the Commission for Personal Data Protection within 72 hours of becoming aware of it, and we notify you directly without undue delay where the risk is high.



9. Cookies and similar technologies

9.1 What we use

A cookie is a small file stored on your device. We also use similar technologies such as local storage and pixels. This section covers all of them.

9.2 Your choices

When you first visit lavanis.com you are shown a cookie banner.

• Strictly necessary cookies are set without consent. They are required for the website to function — session management, load balancing, security, and remembering your cookie choice itself. There is no opt-out, but they are not used for tracking.

• All other categories — analytics, functional preferences and marketing — are set only after you give consent. Nothing in those categories is loaded before you choose. Rejecting is as easy as accepting: the banner offers "Accept all", "Reject all" and "Preferences" at the same level.

• You can change or withdraw your choice at any time through the Cookie settings link in the website footer. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

• Your consent record is stored for 6 months and you are asked again when it expires or when we introduce a new cookie in a consented category.

Browser controls can also block or delete cookies. Blocking strictly necessary cookies will break parts of the site.



9.3 Cookies we set

 

9.3 Cookies we set



PHPSESSID

  • Provider: Lavanis / website infrastructure
  • Purpose: Stores a user's unique session identifier and is used to maintain the user's session while navigating the website.
  • Category: Strictly necessary
  • Type: HTTP cookie
  • Duration: 7 days

_ga

  • Provider: Google Analytics
  • Purpose: Used to distinguish users and support website analytics, including visitor and session measurement.
  • Category: Analytics
  • Type: HTTP cookie
  • Duration: 1 year 1 month 4 days

ga*

  • Provider: Google Analytics
  • Purpose: Used to maintain Google Analytics measurement information and support the site's analytics reporting.
  • Category: Analytics
  • Type: HTTP cookie
  • Duration: 1 year 1 month 4 days

Additional statement:

Analytics cookies are placed only after the visitor has given consent through the cookie banner. Strictly necessary cookies may be set without consent where they are required for the operation and security of the website.

The cookie inventory may change as the website or its third-party services are updated. We periodically scan the website and update this section when the cookies used materially change.



9.4 What we do not do

We do not use cookies for cross-site behavioural advertising, we do not operate advertising pixels for third-party ad networks, and we do not participate in real-time bidding.



10. Automated decision-making

We do not make decisions producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing. VAT number validation through VIES is an automated check, but the decision whether to accept an order is taken by a person.



11. Children

Our website and products are directed at businesses and are not intended for children. We do not knowingly collect data from anyone under 18. If you believe a child has provided us with personal data, contact info@lavanis.com and we will delete it.



12. Is providing data mandatory?

Providing identity, contact, business verification, order and payment data is a contractual requirement and, in part, a statutory requirement for invoicing and VAT. Without it we cannot verify your eligibility to buy, conclude a contract or deliver a product.

Providing analytics consent and marketing consent is entirely voluntary and has no effect on your ability to buy from us.



13. Your rights

Under the GDPR you have the right to:

• access your personal data and receive a copy;

• rectification of inaccurate or incomplete data;

• erasure, where one of the grounds in Article 17 applies;

• restriction of processing in the circumstances set out in Article 18;

• data portability for data you provided to us, where processing is based on consent or contract and is carried out by automated means;

• object at any time to processing based on legitimate interests, on grounds relating to your particular situation, and at any time and without giving reasons to processing for direct marketing;

• withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of prior processing;

• lodge a complaint with a supervisory authority.

How to exercise them. Write to info@lavanis.com. We reply within one month of receipt. That period may be extended by two further months for complex or numerous requests; we will tell you within the first month if that applies and why. We may ask for information to verify your identity, but no more than is necessary. Requests are free of charge unless manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse, and we will explain the reason.

Limits. Some rights are qualified. In particular, we cannot erase invoices and accounting records before the statutory 10-year period expires, and we may retain acceptance records under section 5 where they are needed to establish, exercise or defend legal claims.

Supervisory authority. Commission for Personal Data Protection (Комисия за защита на личните данни) 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria Telephone +359 2 915 3518 · kzld@cpdp.bg · www.cpdp.bg

If you are in another EU or EEA country, you may also complain to your local supervisory authority.



14. Changes to this policy

We may update this policy. The version number and the "last updated" date at the top always show the current version. Where a change materially affects how we use your data, we notify you by e-mail or through a notice on the website before it takes effect. Previous versions are available on request.



15. Contact

Purpose

Contact

Data protection enquiries, rights requests and general enquiries

  • info@lavanis.com

Postal address

  • Lavanis Engineering OOD, 24 Simeonovsko Shose Blvd., Section A, floor 3, office 14, 1700 Sofia, Bulgaria