Privacy Policy
PRIVACY POLICY
of “Smart Innovative Technologies” Ltd.
applicable to the website scelender.smartit.bg
For “Smart Innovative Technologies” Ltd. (hereinafter referred to as “the Company”, “Smart IT”, “we”, “us”, or “our”), the protection of your personal data is of paramount importance.
This Privacy Policy explains how and on what legal basis we collect, use, and protect personal data when you visit our product website https://scelender.smartit.bg/ (the “Website”), submit a contact or demo request form, or otherwise interact with us in connection with our software product SmartCheck – a lending management software solution for credit businesses. We strictly adhere to all applicable data protection laws, including the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”).
I. Introduction
In this Privacy Policy, “Smart IT”, “we”, “us”, and “our” refer to “Smart Innovative Technologies” Ltd., while “you”, “your”, and “user” refer to visitors of our Website https://scelender.smartit.bg/ and/or any person who submits a contact or demo request through the Website.
This Privacy Policy explains and governs:
- how and when we collect your personal data and what information we collect;
- how and why we use your personal data; and
- your rights to control your personal data.
Please read this Privacy Policy carefully. By accessing and using our Website and services, you confirm that you have read this Policy, that you understand it, and that you agree to be bound by it. If you do not agree, you must immediately discontinue using our Website.
We may amend this Policy from time to time in order to comply with applicable laws and regulations or to respond to changing business requirements. We encourage you to review this page periodically for the latest information on our privacy practices. Whenever we make significant changes, we will notify you through a visible notice on our Website.
II. General Information
1. Definitions
For the purposes of this Policy, the following terms shall have the meanings set out below:
“Personal Data”
Any information relating to an identified or identifiable natural person which, alone or in combination with other information, can lead to the identification of that person.
“Data Subject”
A living natural person who is identified or identifiable by means of the personal data being processed.
“Processing of Personal Data”
Any operation or set of operations performed on personal data, including but not limited to collection, storage, analysis, modification, or destruction.
“Data Controller”
“Smart Innovative Technologies” Ltd. acts as the data controller with respect to the personal data collected through this Website. We determine the purposes and legal basis for processing your data and are responsible for the security and protection of your personal data.
“Data Processor”
A third party that processes your personal data on our behalf, in accordance with our explicit instructions, and after verifying that the processor meets GDPR requirements.
“Digital Assets”
The website https://scelender.smartit.bg/, all associated landing pages, and any web applications available through the Website.
2. Who We Are
“Smart Innovative Technologies” Ltd. is a technology company engaged in the development and maintenance of innovative software products and information systems, including SmartCheck – a comprehensive lending management software solution designed for credit and financial businesses.
The Website https://scelender.smartit.bg/ is a product marketing website providing information about the SmartCheck software. We do not offer financial services or process credit applications through this Website. No end-user financial data is collected or processed here.
3. Contact Information
“Smart Innovative Technologies” Ltd.
Registered office: Bulgaria, Sofia 1324, Lyulin District, Lyulin 7 Residential Complex, Jawaharlal Nehru Blvd., No. 28, ATC Silver Center Building, 2nd Floor, Office 72–74
Phone: 0700 20 140
Website: https://smartit.bg/
4. Data Protection Officer
Our appointed Data Protection Officer (DPO) can be reached at:
5. What Personal Data We Collect and Why
The Website collects personal data through the following means:
a) Contact and Demo Request Form
When you submit a contact or demo request form on our Website, we collect the following data:
- Full name
- Email address
- Country
- Phone number
- Company name
This data is collected and processed for the purpose of responding to your inquiry and/or scheduling a product demonstration. The legal basis for this processing is our legitimate interest in responding to business inquiries (Article 6(1)(f) GDPR), or, where applicable, the performance of pre-contractual steps taken at your request (Article 6(1)(b) GDPR).
b) Website Analytics and Tracking
Our Website uses analytics and tracking tools (such as Google Analytics) to collect anonymised or pseudonymised data about how visitors interact with the Website. This may include:
- IP address (anonymised)
- Browser type and version
- Pages visited and time spent
- Referring website
- Device type and operating system
This data is used to analyse Website performance, improve user experience, and support marketing activities. The legal basis for analytics processing is your consent, obtained through our cookie consent mechanism upon your first visit to the Website. You may withdraw your consent at any time through our Cookie Settings.
c) Cookies
Our Website uses cookies. Please refer to our Cookie Policy for detailed information on the types of cookies used, their purpose, and how you can manage your preferences.
Summary of personal data processing:
| Personal Data | Purpose of Processing | Legal Basis |
| Full name, email, country, phone number, company name | Responding to contact/demo requests; pre-contractual communication | Legitimate interest / Pre-contractual steps (Art. 6(1)(b)(f) GDPR) |
| Anonymised website usage data (via analytics tools) | Website performance analysis; improving user experience; marketing analytics | Consent (Art. 6(1)(a) GDPR) |
| Cookie data | Website functionality; analytics; marketing tracking | Consent (Art. 6(1)(a) GDPR) |
6. How Long We Retain Your Personal Data
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:
- Contact and demo request data: retained for a maximum of 12 months from the date of submission, unless a business relationship is established, in which case data is retained for the duration of that relationship and any applicable statutory retention periods thereafter.
- Analytics data: retained in accordance with the retention settings of the analytics provider (e.g. Google Analytics default retention periods), and in any case for no longer than 26 months.
- Cookie data: retained for the periods specified in our Cookie Policy.
After the expiration of the applicable retention periods, personal data will be securely deleted or anonymised.
7. Will Your Personal Data Be Shared with Third Parties?
“Smart Innovative Technologies” Ltd. does not sell or rent your personal data to third parties.
Your data may be shared with the following categories of recipients, who process it on our behalf as data processors:
- Analytics and tracking service providers (e.g. Google LLC, as provider of Google Analytics), operating under appropriate data processing agreements and standard contractual clauses;
- Email and communication service providers used to manage and respond to contact form submissions;
- IT infrastructure and hosting providers maintaining the Website and its systems;
- Other companies within the Management Financial Group (MFG), where relevant and under joint controller or data sharing agreements, solely for internal administrative and business purposes.
Where data is transferred to service providers outside the European Union (e.g. Google Analytics), such transfers are carried out under appropriate safeguards, including Standard Contractual Clauses approved by the European Commission (Article 46 GDPR).
“Smart Innovative Technologies” Ltd. does not otherwise transfer personal data to third countries or international organisations outside the European Union.
8. How We Protect Your Personal Data
We apply appropriate technical and organisational measures to ensure the security of your personal data, in accordance with the requirements of the GDPR and applicable Bulgarian data protection legislation. These measures include:
- Encrypted data transmission (SSL/TLS);
- Access controls and authentication measures;
- Regular security assessments of our systems;
- Data minimisation practices – we collect only the data necessary for the stated purposes.
The Company has appointed a Data Protection Officer who oversees data protection compliance and supports the safeguarding of your personal data.
9. Automated Decision-Making and Profiling
“Smart Innovative Technologies” Ltd. does not engage in automated decision-making, including profiling, that produces legal or similarly significant effects on visitors to this Website. The Website is a product marketing website and does not process data for credit assessment or any automated scoring purposes.
III. Your Rights
As a data subject whose personal data is processed by “Smart Innovative Technologies” Ltd., you have the following rights under the GDPR:
a. Right to Information
You have the right to be informed about the essential characteristics of the processing of your personal data, including its purpose, duration, legal basis, and the recipients of your data.
b. Right of Access
You may request confirmation of whether we process personal data about you and, if so, access to that data, including a copy of the personal data being processed.
c. Right to Rectification
If we are processing inaccurate or incomplete personal data about you, you may request its correction or completion at any time.
d. Right to Erasure (“Right to be Forgotten”)
You may request the deletion of your personal data where:
- the data is no longer necessary for the purposes for which it was collected;
- you withdraw your consent and there is no other legal basis for processing;
- you believe the data has been processed unlawfully.
Note that certain legal obligations may prevent immediate deletion in some cases.
e. Right to Restriction of Processing
You have the right to request that we restrict the processing of your personal data in certain circumstances, for example while we verify the accuracy of data you have contested.
f. Right to Data Portability
Where processing is based on your consent or on a contract, and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, and machine-readable format.
g. Right to Object
You have the right to object to the processing of your personal data based on our legitimate interests, including any profiling based on those interests. You may also object at any time to processing for direct marketing purposes.
h. Right to Withdraw Consent
Where processing is based on your consent (e.g. analytics cookies), you may withdraw that consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
i. Right to Lodge a Complaint
If you believe that the processing of your personal data violates applicable data protection law, you have the right to lodge a complaint with the Commission for Personal Data Protection (CPDP):
- Address: Sofia 1592, Prof. Tsvetan Lazarov Blvd.
- Tel: +359 2 91-53-518
- Email: [email protected]
- Website: https://www.cpdp.bg/
How to Exercise Your Rights
To exercise any of the above rights, please contact us using one of the following methods:
- By email (with electronic signature): [email protected]
- By post or courier: Bulgaria, Sofia 1324, Lyulin District, Lyulin 7 Residential Complex, Jawaharlal Nehru Blvd., No. 28, ATC Silver Center Building, 2nd Floor, Office 72–74
- By phone: 0700 20 140 (followed by written confirmation using one of the above methods)
- In person at the Company’s registered address (with valid ID or notarised power of attorney for authorised representatives)
We will respond to your request within 30 calendar days of receipt, free of charge. In complex cases, this period may be extended by a further two months, and you will be notified accordingly.
IV. Cookies
Our Website uses cookies and similar tracking technologies. By continuing to use the Website after accepting our cookie notice, you consent to the use of cookies as described in our Cookie Policy.
You may manage or withdraw your cookie consent at any time through the Cookie Settings option available on the Website. Please note that disabling certain cookies may affect the functionality or performance of the Website.
For full details on the cookies we use, their purpose, and retention periods, please refer to our Cookie Policy, which is available at: https://scelender.smartit.bg/cookie-policy
V. Updates to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. The date of the most recent revision will be indicated at the top of this page. We encourage you to review this Policy periodically.
Where changes are material, we will provide a prominent notice on the Website.
Last updated: May 2026 | “Smart Innovative Technologies” Ltd. | [email protected]