Privacy policy

Last updated: July 9, 2026
This Privacy Policy applies to all users of the tvorzi.com and tvorzi.com.ua websites (and their language versions), including citizens of Ukraine and residents of the European Union and European Economic Area, subject to the General Data Protection Regulation (GDPR) and the Ukrainian Law on Personal Data Protection.
1. WHO WE ARE
Company (Controller): "ТВОРЦИ Архитектура, Проектиране, Дизайн" OOD (also referred to as "TVORZI – Architecture, Design & Planning" Ltd)
Unified Identification Code (EIK): 208326822
Registered address: Република България, гр. Варна, п.к. 9002, р-н Приморски, бул. Цар Освободител № 44, ет. 2, ап. 4
Email: Tvorzi.com@gmail.com
Phone: +359 884 624 081
Websites: tvorzi.com, tvorzi.com.ua (and language versions /ru, /en, /bg)
We are the data controller responsible for personal data collected through our websites and through our advertising forms on Meta platforms (Facebook and Instagram). As the Company is registered in Bulgaria (EU), processing of personal data is governed primarily by the GDPR. At the same time, because our websites also target residents of Ukraine and process personal data of Ukrainian citizens, we also comply with the requirements of the Ukrainian Law of 01.06.2010 No. 2297-VI "On Personal Data Protection" (the "Law-2297") insofar as such processing is concerned.
2. WHAT DATA WE COLLECT
We collect the following categories of personal data:
  • Identity data: name
  • Contact data: phone number
  • Questionnaire data (quiz on tvorzi.com.ua): answers to questions about project parameters (development type, project goal, approximate area, timeline, preferred communication format) — this data does not constitute a special category of personal data
  • Technical and usage data: IP address, browser type, pages visited, date and time of visit, device identifiers — collected via the Meta Pixel (both websites) and Google Analytics 4 (tvorzi.com only)
We do not collect special categories of personal data (concerning race, political opinions, health, etc.) and do not knowingly collect data from individuals under 16 years of age without the consent of their legal representative.
3. LEGAL BASIS FOR PROCESSING
In accordance with Article 6 GDPR and Article 11 of Law-2297, we process personal data on the following legal bases:
  • Consent (Art. 6(1)(a) GDPR): when you submit a form on the website or complete the quiz, you provide explicit consent to the processing of the submitted data for the purpose of contacting you. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
  • Legitimate interests (Art. 6(1)(f) GDPR): to measure advertising effectiveness and to communicate with individuals who have expressed genuine interest in the Company's services, where this does not override your fundamental rights.
  • Performance of a contract (Art. 6(1)(b) GDPR): where a consultation or design contract is initiated at your request.
4. HOW WE USE YOUR DATA
We use personal data for the following purposes:
  • Contacting you regarding a request for an architectural design consultation
  • Developing a project concept based on your quiz answers
  • Responding to your inquiries
  • Measuring advertising campaign performance and optimising advertising
  • Complying with legal obligations
We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects on you.
5. DATA SHARING AND THIRD PARTIES
We may share personal data with the following categories of recipients:
  • Meta Platforms, Inc. / Meta Platforms Ireland Limited (Facebook/Instagram): we use the Meta Pixel (tracking code installed on both websites, ID 1286316686163507) and the Meta Conversions API (CAPI), which sends website events — including hashed contact data, IP address, and User-Agent data — directly from the server to Meta. This enables us to measure advertising effectiveness and optimise campaigns. Meta's privacy policy: facebook.com/privacy/policy
  • Google LLC / Google Ireland Limited (Google Analytics 4): Google Analytics 4, installed via Google Tag Manager, is used only on tvorzi.com (not on tvorzi.com.ua) to analyse site traffic. Google's privacy policy: policies.google.com/privacy
  • Tilda Platform Cloud Services Co. LLC (UAE) / Tilda Publishing Ltd. (Ireland, EU representative): the platform hosting our websites and through which form and quiz submissions are received. Acts as a data processor under its own privacy policy: tilda.cc/privacy
  • Receipt of submissions: data submitted through website forms is delivered to the email address Tvorzi.com@gmail.com and stored within Tilda's built-in form system; we do not use a separate CRM.
  • Public authorities: where required by applicable law, court order, or regulatory obligation.
We do not sell your personal data to third parties.
6. INTERNATIONAL DATA TRANSFERS
Your data may be processed outside Ukraine and the European Economic Area (EEA), including in the United States (Meta Platforms, Google LLC) and the UAE (Tilda). Where such transfers occur, the following safeguards apply:
  • Standard Contractual Clauses (SCCs) approved by the European Commission;
  • EU-U.S. Data Privacy Framework (DPF) — the adequacy decision adopted on 10 July 2023, applicable to certified US recipients including Meta and Google (as of the date of this Policy, the decision was upheld by the General Court of the EU on 3 September 2025; an appeal remains pending before the Court of Justice of the EU);
  • Data of EU residents is, per Tilda's own representations, processed and stored within EU borders.
7. COOKIES AND TRACKING TECHNOLOGIES
Our websites use cookies and similar technologies:
  • Essential cookies: required for the website to function. No consent is required for these.
  • Marketing cookies and pixels:Meta Pixel — on both websites (tvorzi.com and tvorzi.com.ua) — tracks page views and user actions to optimise Meta advertising;
  • Google Analytics 4 / Google Tag Manager — on tvorzi.com only — tracks site traffic.
In addition to browser-side cookies, we use server-side tracking (Meta Conversions API), which transmits certain event data (hashed contact details, IP address) directly from the server to Meta, in parallel with the Meta Pixel.
On your first visit to our websites, you will be presented with a cookie consent banner allowing you to accept or decline non-essential cookies. You can change your preferences at any time via the link in the website footer. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
8. DATA RETENTION
We retain personal data only as long as necessary:
  • Lead and inquiry data: up to 36 months from the date of collection, or until a deletion request is made;
  • Technical and analytics data: up to 26 months;
  • Data required for legal compliance (including accounting): as required by applicable law, generally up to 10 years under the Bulgarian Accountancy Act.
After the retention periods expire, data is deleted or anonymised.
9. YOUR RIGHTS
Under GDPR, you have the following rights, exercisable free of charge:
  • Right of access (Art. 15) — obtain a copy of your personal data;
  • Right to rectification (Art. 16) — correct inaccurate or incomplete data;
  • Right to erasure / "right to be forgotten" (Art. 17);
  • Right to restriction of processing (Art. 18);
  • Right to data portability (Art. 20);
  • Right to object (Art. 21), including to direct marketing;
  • Right to withdraw consent (Art. 7(3)) at any time;
  • Right to lodge a complaint with a supervisory authority. In Bulgaria: the Commission for Personal Data Protection (CPDP), cpdp.bg.
Under Law-2297, a data subject in Ukraine also has the right to apply to the Ukrainian Parliament Commissioner for Human Rights (currently performing the functions of the personal data protection authority) or to a court.
We respond to requests within 30 days (extendable to 90 days for complex cases, with notice). To exercise your rights, contact us at: Tvorzi.com@gmail.com
10. SECURITY AND DATA BREACHES
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or alteration. No method of internet transmission is entirely secure.
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of it (GDPR Art. 33), and where the breach is likely to result in a high risk to you personally, we will notify you directly without undue delay (GDPR Art. 34).
11. CHILDREN'S PRIVACY
Our services are not directed at individuals under 16 years of age. We do not knowingly collect data from minors without the consent of a legal representative. If you believe a minor has submitted data to us, please contact us and we will delete it promptly.
12. CHANGES TO THIS POLICY
We may update this Privacy Policy periodically. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date.
13. CONTACT US
For questions, requests, or complaints regarding this Policy or our data processing:
"ТВОРЦИ Архитектура, Проектиране, Дизайн" OOD (also referred to as "TVORZI – Architecture, Design & Planning" Ltd)
Email: Tvorzi.com@gmail.com
Websites: tvorzi.com · tvorzi.com.ua