Effective date: [DATE]
This Privacy Policy explains how [FULL REGISTERED COMPANY NAME], trading as IT Cactus (“IT Cactus,” “we,” or “us”), handles personal data when you visit itcactus.com, contact us, submit Campaign Onboarding information or purchase our services.

1. Who is responsible for your data

The data controller is:

[FULL REGISTERED COMPANY NAME]
[REGISTERED ADDRESS, BULGARIA]
Email: hello@itcactus.com
EIK/UIC: [EIK/UIC]

2. Information we handle

Depending on how you use the site, we may handle:

• contact details such as your name, business email address and telephone number;
• business details such as company name, website URL, niche, target market and competitor URLs;
• information you enter in Campaign Onboarding, including optional notes;
• messages you send us and our replies;
• order, invoice and payment-status information supplied by Stripe. Stripe processes card details through its own payment page; IT Cactus does not receive your full card number;
• basic technical and security information generated when you use the website.

Please do not send special-category or sensitive personal data through the website or onboarding form.

3. Why we use the information and our legal grounds

We use information to:

• respond to enquiries and prepare requested proposals — steps taken at your request before a contract;
• take payment, provide the Trial or monthly service, communicate about delivery and prepare reports — performance of a contract;
• issue and retain invoices and business records — compliance with legal obligations;
• protect the website, prevent fraud and resolve disputes — our legitimate interests, balanced against your rights;
• send marketing messages only where permitted and, where required, with your consent. You may opt out of marketing at any time.

4. Who may receive information

We share information only as needed with providers that help operate the service, such as:

• Hostinger — website hosting and related infrastructure;
• Stripe — payment checkout, payment processing and subscription management;
• [FORM PROVIDER: Fluent Forms / WPForms / OTHER] — receiving contact and onboarding submissions;
• [BUSINESS EMAIL PROVIDER] — business email and customer communications;
• [LIVE-CHAT PROVIDER, IF INSTALLED] — customer support conversations;
• [ANALYTICS PROVIDER, ONLY IF INSTALLED AND ENABLED] — website usage measurement.

We may also disclose information where necessary to comply with law, respond to valid legal requests, or establish or defend legal claims. We do not sell personal data.

5. International transfers

Some service providers may process data outside the European Economic Area. Before publication, IT Cactus will identify the actual providers and describe the applicable transfer safeguards, such as an adequacy decision or Standard Contractual Clauses, where required. [CONFIRM PROVIDER LOCATIONS AND TRANSFER MECHANISMS.]

6. How long we keep information

We keep enquiry and campaign information only for as long as needed to handle the enquiry, provide the service, maintain a customer relationship and address disputes. We retain accounting and tax records for the periods required by law. [SET A PRACTICAL RETENTION PERIOD FOR UNSUCCESSFUL ENQUIRIES AND CAMPAIGN FILES; confirm statutory record periods with the company’s accountant.]

7. Your rights

Depending on the circumstances, you may ask to access, correct, delete or restrict use of your personal data, object to certain processing, request a portable copy, or withdraw consent where processing is based on consent. To exercise a right, email hello@itcactus.com. We may need to verify your identity before responding.

You may complain to the competent data-protection supervisory authority. For IT Cactus, the Bulgarian Commission for Personal Data Protection (CPDP) is the relevant supervisory authority, subject to your right to contact another competent authority where applicable.

8. Cookies and similar technologies

[VERIFY BEFORE PUBLICATION.] IT Cactus does not intentionally use analytics or advertising cookies unless they are enabled on the website. The website and its providers may use strictly necessary technologies for security and core functions such as forms. If we enable analytics, advertising or other non-essential cookies, we will update this notice and request consent where required before those technologies are used.

9. Security and automated decisions

We use reasonable technical and organisational measures to protect personal data. We do not use the information described in this Policy to make decisions about you solely by automated means that produce legal or similarly significant effects.

10. Changes and contact

We may update this Privacy Policy when our services or data practices change. The current version will be posted on this page with its effective date. Questions or requests: hello@itcactus.com.