Privacy policy

1. Contact details of the data controllers

1.1 The data controller is the entity that determines the means and purposes of the Processing of Personal Data.

---

2. Description of the processing of personal data

The applicable conditions may differ.

2.1 Purpose and legal bases of the processing

2.1.1 Personal data of users and clients

Your Personal Data is collected for the following purposes, each resting on a specific legal basis within the meaning of the General Data Protection Regulation (GDPR):

• To produce and deliver the services you order on the Website, as well as to manage the client relationship and respond to your requests. Legal basis: the performance of the contract entered into with you (or the pre-contractual measures taken at your request).
• To comply with FENCHELL's legal, accounting and tax obligations (in particular the preparation and retention of invoices and accounting documents). Legal basis: compliance with the legal obligations to which FENCHELL is subject.

FENCHELL does not send any newsletter, prospecting communication or marketing message, and does not compile any list for that purpose. No processing is therefore based on consent for commercial or advertising purposes.

2.1.2 Processing of personal data

The Personal Data concerning you that is collected and processed for the purposes described above is:

• For Clients purchasing legal and para-legal services such as Company Formation: surname, first name, company name, telephone number, postal address, a copy of the passport or identity card.
• For Clients purchasing services such as Action Plans, NNN Contracts or SMS, and other services that are not related to Company Formation: surname, first name, company name, telephone number, postal address.

2.1.3 Identity document (passport / identity card)

2.2 Recipients of your Personal Data

Your Personal Data is intended for FENCHELL's authorised internal departments. It may also be disclosed, strictly to the extent necessary for the provision of the services and for compliance with our obligations, to the following categories of recipients:

• our IT hosting provider (located within the European Union);
• our management providers and tools (in particular accounting solutions and business software) whose data is kept within the European Union;
• where applicable, the platforms or partners necessary for the performance of the service you have ordered. Where the service involves Amazon, the data concerned is, where applicable, shared with a European Amazon entity (for example Amazon EU S.à r.l., Luxembourg).

As FENCHELL's services are tailored, the precise list of providers involved varies according to the service taken out. For this reason, these providers are not listed by name in this policy: each Client is informed individually, after signing a dedicated contract, of the providers actually involved in their file. A GDPR-compliant data processing agreement is concluded with each of these providers.

Finally, FENCHELL may disclose your Personal Data to third parties where such disclosure is required by law, a regulatory provision or a court decision, or if such disclosure is necessary to ensure the protection and defence of its rights.

2.3 Location and transfers of your Personal Data

As a rule, your Personal Data is hosted and stored within the European Union, in Germany, with our hosting provider Hetzner Online GmbH. All the tools, providers and solutions used by FENCHELL (hosting, accounting solutions, business software) keep the data within the European Union. Where the performance of a service involves Amazon, the data concerned is, where applicable, processed by a European Amazon entity (for example in Luxembourg).

The only exception concerns the Google Analytics 4 audience measurement, used only after obtaining your consent. Any data transfers to Google LLC (United States) on that basis are governed by the EU–US Data Privacy Framework, to which Google LLC is certified, as well as by the European Union's standard contractual clauses.

Should this situation change, FENCHELL would inform the data subjects beforehand and would only carry out such a transfer in compliance with the appropriate safeguards provided for by the GDPR.

2.4 Retention period of your Personal Data

---

3. Your rights

In accordance with the regulations in force, you have a right of access to and rectification of your Personal Data and the right to request its erasure (right to be forgotten), the right to object to the processing of your Personal Data and the right to obtain the restriction or portability of your Personal Data to the extent that this is applicable, subject to the legitimate grounds or legal obligations that FENCHELL may justify for retaining your Personal Data.

Clients also have an online client area enabling them, in particular, to retrieve and export their data, and to request the deletion of their account.

These rights may also be exercised directly at the email address contact@fenchell-team.com, or by sending a request by registered letter with acknowledgement of receipt to Fenchell Capital OOD, bul. Maritsa 95, 4000 Plovdiv, Bulgaria. You may be asked to provide proof of identity.

Requests for erasure and objections to processing may, where applicable, prevent you from obtaining delivery of the Services and products you have purchased on the Website https://www.fenchell.com/.

Automated decision-making and profiling: FENCHELL does not carry out any fully automated decision-making producing legal effects concerning you, nor any profiling (scoring, advertising targeting, automatic refusal).

In addition, you have the right to lodge a complaint with a supervisory authority concerning the way in which FENCHELL collects and processes your Personal Data. As FENCHELL is established in Bulgaria, its sole lead supervisory authority is the Bulgarian Commission for Personal Data Protection (Комисия за защита на личните данни — CPDP / КЗЛД):

---

4. Data security and confidentiality

FENCHELL strives to take all necessary precautions to protect the confidentiality and security of the Personal Data collected and processed, and to prevent that Personal Data from being altered, damaged, destroyed, or accessed by unauthorised third parties.

Please note that FENCHELL does not control all the risks associated with the operation of the Internet and that there may be risks related to the use and operation of the Website https://www.fenchell.com/.

5. Cookies

The use of cookies and other trackers on the Website is the subject of a dedicated policy, which sets out in particular their purpose, their retention period and the arrangements for managing your consent. To find out more, see our Cookies policy.

6. General information