Privacy Policy
Last updated: 12 September 2026
1. Data Controller
The controller responsible for the processing of personal data through this website and in connection with the products and services offered by Radio Albena is:
Raymundus Ummels
operating as Radio Albena
Ul. Stara Planina 16
9630 Obrochishte
Bulgaria
Email: raymond@radioalbena.com
Phone: +359 897 965 709
2. General Information
Radio Albena respects your privacy and processes personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection legislation.
Personal data is processed only where necessary to:
- operate and secure this website;
- process orders and payments;
- provide software and digital downloads;
- issue order, payment and contractual information;
- manage software licences where applicable;
- arrange setup and support appointments;
- provide remote setup and configuration services;
- respond to customer enquiries;
- comply with legal, accounting and tax obligations.
Depending on the purpose, processing is based on:
- Article 6(1)(b) GDPR – performance of a contract or steps requested before entering into a contract;
- Article 6(1)(c) GDPR – compliance with a legal obligation;
- Article 6(1)(f) GDPR – legitimate interests, including website security, fraud prevention and efficient customer support;
- Article 6(1)(a) GDPR – consent, where consent is required.
3. Data Processed When Visiting the Website
When you visit the Radio Albena website, technically necessary information may be processed automatically.
This may include:
- IP address;
- date and time of access;
- requested page or file;
- browser type and version;
- operating system;
- referring website;
- technical error information;
- security and server log information.
This information is used to provide and protect the website, detect technical problems and prevent misuse or attacks.
The legal basis is Article 6(1)(f) GDPR.
Technical log data is retained only for as long as reasonably necessary for security, maintenance and troubleshooting purposes, unless longer retention is required in connection with a security incident or legal obligation.
4. Orders and Purchases
When you purchase a product or service, we may process:
- first and last name;
- email address;
- billing address;
- country;
- telephone number where provided or required;
- ordered products or services;
- order number;
- purchase date;
- payment status;
- transaction information;
- invoice and receipt information;
- licence information where applicable.
These data are processed to fulfil your order and perform the contract under Article 6(1)(b) GDPR.
Information required for accounting, tax or legal purposes is retained for the applicable statutory retention period.
5. SureCart
Radio Albena uses SureCart to operate its online store, manage orders and provide digital products.
SureCart may process information including:
- customer contact information;
- order information;
- purchased products;
- payment status;
- transaction identifiers;
- IP address and technical information.
SureCart processes relevant customer data on behalf of Radio Albena for the operation of the online store.
Payment-card information is handled through the relevant payment provider and is not normally made available to Radio Albena in full.
Processing is necessary for performance of the contract under Article 6(1)(b) GDPR and, where applicable, for legitimate operational and security interests under Article 6(1)(f) GDPR.
6. PayPal
Radio Albena currently uses PayPal as a payment provider.
When PayPal is selected, information necessary to process the payment may be transferred to or collected directly by PayPal.
This may include:
- name;
- email address;
- billing information;
- transaction amount;
- order reference;
- payment status.
Radio Albena does not receive your PayPal password or full payment-card details.
PayPal also processes certain information as an independent data controller in accordance with its own privacy policy.
The processing of payment information is necessary for performance of the contract under Article 6(1)(b) GDPR.
7. OttoKit Automations
Radio Albena uses OttoKit to automate certain processes connected with orders and services.
These may include:
- sending post-purchase information;
- sending legal and contractual documents;
- sending setup booking links;
- triggering product-related workflows.
For these purposes, OttoKit may process information such as:
- customer name;
- email address;
- purchased product;
- order information;
- workflow-related technical data.
Only information necessary for the relevant automation is used.
The legal basis is Article 6(1)(b) GDPR where the automation is necessary to fulfil the purchase or service contract.
8. Appointment Booking with FluentBooking
Radio Albena uses FluentBooking to arrange appointments for setup and support services.
When you book an appointment, we may process:
- name;
- email address;
- selected service;
- appointment date and time;
- information provided in booking forms;
- messages relating to the appointment.
These data are processed to organise and provide the requested service under Article 6(1)(b) GDPR.
Where FluentBooking is connected to an external calendar, email or other integration, the information necessary for that integration may also be processed by the relevant provider.
9. Remote Setup Services
Radio Albena setup services may be carried out using Chrome Remote Desktop, SSH, PuTTY or similar administration tools.
The customer initiates or authorises the remote connection.
During a remote session, information stored on the customer’s computer or server may become visible where necessary to perform the requested work.
Radio Albena accesses only those systems and information reasonably necessary to provide the agreed service.
Remote setup sessions are not normally recorded.
Where Google services are used for Chrome Remote Desktop, Google’s applicable privacy terms also apply to Google’s processing of technical connection data.
10. Passwords and Access Credentials
Where possible, customers should enter confidential passwords themselves during a remote setup session.
If passwords, API keys or other credentials must temporarily be provided to Radio Albena, they are used only to perform the requested service.
This may include:
- VPS or root credentials;
- administrator accounts;
- AzuraCast credentials;
- SFTP credentials;
- Streamer or DJ accounts;
- API keys.
Customers are strongly advised to change temporary passwords after the setup has been completed.
Radio Albena does not intentionally retain such credentials longer than necessary to provide the agreed service.
11. Customer Support and Communication
If you contact Radio Albena by email, telephone or another communication method, we process the information necessary to respond to your request.
This may include:
- name;
- email address;
- telephone number;
- order number;
- content of your message;
- screenshots;
- technical information or log files supplied by you.
Where your enquiry relates to an existing contract, processing is based on Article 6(1)(b) GDPR.
Other enquiries may be processed on the basis of Article 6(1)(f) GDPR.
Correspondence is retained only for as long as necessary for support, contractual documentation or the establishment, exercise or defence of legal claims.
12. Evidence of Contractual Consent
Radio Albena may retain information necessary to demonstrate which contractual terms and declarations were accepted when an order was placed.
This may include records relating to:
- acceptance of Terms & Conditions;
- information concerning the right of withdrawal;
- consent to immediate delivery of digital content;
- acknowledgement of the loss of the right of withdrawal for digital content where legally applicable;
- requests to begin a setup service during the withdrawal period.
This information may be retained where necessary to comply with legal obligations or document the contract.
The legal basis is Article 6(1)(c) GDPR and, where applicable, Article 6(1)(f) GDPR.
13. Cookies
Radio Albena uses cookies and similar technologies for the operation of the website.
Strictly necessary cookies may be used for functions including:
- shopping cart;
- checkout;
- login;
- security;
- appointment booking;
- cookie preference management.
Optional cookies requiring consent will only be used after valid consent has been obtained.
Detailed information about cookies is provided in our separate Cookie Policy.
14. Recipients of Personal Data
Where necessary, personal data may be provided to service providers involved in operating the website and fulfilling customer contracts.
These may include:
- hosting and server providers;
- SureCart;
- PayPal;
- OttoKit;
- booking and calendar services;
- email service providers;
- remote-support providers;
- professional tax or legal advisers;
- competent public authorities where legally required.
Only data necessary for the relevant purpose is disclosed.
Radio Albena does not sell customer personal data to advertisers.
15. International Data Transfers
Some service providers may process data outside Bulgaria or outside the European Economic Area.
Where personal data is transferred outside the EEA, such transfers will only take place where a lawful transfer mechanism is available.
Depending on the provider, this may include:
- an adequacy decision of the European Commission;
- the EU-U.S. Data Privacy Framework where applicable;
- Standard Contractual Clauses approved by the European Commission;
- another legally recognised transfer mechanism.
16. Data Retention
Personal data is retained only for as long as necessary for the relevant purpose or as required by law.
In particular:
- order, invoice and payment records are retained for applicable accounting and tax periods;
- contractual records may be retained for as long as necessary to establish or defend legal claims;
- booking information is retained for as long as required for the appointment and reasonable follow-up support;
- customer-support correspondence is deleted when no longer required;
- temporary access credentials are not retained longer than necessary after completion of the service;
- technical logs are deleted when their security or operational purpose no longer applies.
Where a statutory retention obligation exists, data will be retained until that obligation expires.
17. Your Rights Under the GDPR
Subject to the conditions provided by law, you have the right to:
- request access to your personal data;
- request correction of inaccurate or incomplete information;
- request deletion of your personal data;
- request restriction of processing;
- receive your data in a portable format where applicable;
- object to processing based on legitimate interests;
- withdraw consent at any time where processing is based on consent.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Requests concerning your personal data may be sent to:
Radio Albena may request reasonable information to verify your identity before disclosing or deleting personal data.
18. Right to Lodge a Complaint
You have the right to lodge a complaint with a competent data protection supervisory authority if you believe that your personal data has been processed unlawfully.
The Bulgarian supervisory authority is:
Commission for Personal Data Protection (CPDP / КЗЛД)
2 Prof. Tsvetan Lazarov Blvd.
1592 Sofia
Bulgaria
Email: kzld@cpdp.bg
Website: www.cpdp.bg
The official CPDP contact information currently confirms this address and email.
You may also contact another supervisory authority where permitted under the GDPR.
19. Automated Decision-Making
Radio Albena does not itself use solely automated decision-making that produces legal effects concerning customers or otherwise significantly affects them.
Payment providers may carry out their own automated fraud, security or risk checks under their respective privacy policies.
20. Data Security
Radio Albena takes appropriate technical and organisational measures to protect personal data against:
- unauthorised access;
- loss;
- misuse;
- alteration;
- accidental disclosure.
No internet-based system can guarantee absolute security.
Customers are responsible for keeping their own passwords confidential and should change temporary credentials after remote setup sessions.
21. Changes to This Privacy Policy
Radio Albena may update this Privacy Policy where:
- website functionality changes;
- new services or service providers are introduced;
- processing activities change;
- legal requirements change.
The current version will always be published on this page.
22. Contact
For questions concerning this Privacy Policy or the processing of your personal data, please contact:
Radio Albena
Raymundus Ummels
Ul. Stara Planina 16
9630 Obrochishte
Bulgaria
Email: raymond@radioalbena.com
Phone: +359 897 965 709
