Privacy Policy
Last updated: 29 October 2026
This policy explains which personal data Inter Reception processes, why, on what legal basis and for how long.
1. Who we are
The controller of your personal data is Polaris Digital Platforms EOOD (company ID / EIK 208683849, VAT BG208683849), Kapitan Raycho Nikolov No. 34, Ruse 7000, Bulgaria ("Inter Reception", "we"). Privacy requests: [email protected]. We have not appointed a data protection officer; the address above handles all privacy matters.
2. Two different roles
- Account holders (our business customers). For account, billing and marketing data we are the controller.
- Visitors who talk to an avatar on a customer's website. For these conversations the business that installed the avatar is the controller and we act as its processor under a Data Processing Agreement. If you spoke with an avatar on a business's website, please first contact that business; if you write to us, we will forward your request to it.
3. What we process and why
| Data | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Account data (name, e-mail, phone, company, country) | Create and manage the account | Contract (Art. 6(1)(b)) | Life of the account; deleted or anonymised 30 days after the account is closed, unless the law requires us to keep it |
| Invoices and payment records | Billing, accounting and tax law | Legal obligation (Art. 6(1)(c)) | As required by Bulgarian accounting and tax law |
| Avatar conversations (text, voice, language, page context) | Let the avatar answer the visitor | On behalf of the business customer (processor) | Up to 12 months (leads up to 24 months), then deleted automatically; deleted earlier on the business's request and 30 days after its account is closed |
| Usage and security logs (IP address, device, errors); live-session usage records | Security, abuse prevention, usage metering | Legitimate interest (Art. 6(1)(f)) | Live-session usage records 90 days; IP addresses in security logs are masked after 12 months |
| Questions asked to the avatar on our own website (interreception.com) | Answer the visitor; improve our sales answers | Legitimate interest (Art. 6(1)(f)) | Stored without e-mail, phone, card, IBAN or ID numbers (masked automatically); at most 12 months |
| Messages you send us | Answer your request | Legitimate interest / contract | As long as needed to answer and document the request |
| Cookies and advertising identifiers | Measurement and remarketing | Consent (Art. 6(1)(a)) — only after you accept in the cookie banner | See the Cookie Policy |
4. Avatar conversations
The avatar is an AI system, not a human. In voice mode your microphone audio is converted to text for the avatar to answer. Please do not share special-category data (health, religion, etc.), ID numbers or payment card details with the avatar.
5. Recipients
We share data only with sub-processors needed to run the service (AI and avatar providers, payment processor, hosting, e-mail and bot protection). The current list is in the Data Processing Agreement. If you accept marketing cookies, Meta Platforms Ireland Ltd. receives the events described in the Cookie Policy (Meta Pixel). We and Meta are jointly responsible for collecting and sending these events; Meta processes them further as its own controller. We do not sell personal data.
6. Transfers outside the EU/EEA
Some sub-processors are located outside the EU/EEA, notably in the United States. Transfers rely on the EU Standard Contractual Clauses or an adequacy decision / certification such as the EU–US Data Privacy Framework. For persons in Türkiye, the safeguards required by KVKK Art. 9 are applied.
7. Your rights
Under GDPR (Arts. 15–22) and KVKK (Art. 11) you may request access, correction, deletion, restriction, portability, object to processing, and withdraw consent at any time. Account holders can download a copy of their data and close their account themselves under My account. Otherwise write to [email protected]; we answer within one month.
8. Complaints
You may complain to the Bulgarian Commission for Personal Data Protection (CPDP, www.cpdp.bg) or your local supervisory authority; persons in Türkiye may apply to the Personal Data Protection Authority (KVKK).
9. Children
The service is not directed at children under 16.
10. Changes
We will update the date above when this policy changes and notify account holders of material changes by e-mail.