NovoraLux Privacy Notice

1. Who we are

NovoraLux is operated by:

“ВАРНА СЕО АЙДЖЪНСИ” ООД
English name: Varna SEO Agency Ltd.
Registration No.: 207046109
Address: ul. Petko Todorov 62, Varna, 9000, Bulgaria
Email: agency@varnaseoagency.com

For the personal data covered by this Privacy Notice, Varna SEO Agency Ltd. acts as the data controller unless we tell you otherwise.

2. Scope of this notice

This Privacy Notice currently covers the NovoraLux early-access and waitlist experience, including information you provide when you join early access, select a user type and product path, optionally provide a website URL, optionally subscribe to NovoraLux marketing emails, or optionally answer later product-research questions.

NovoraLux is still under development. This notice does not imply that website scanning, migration, reconstruction, hosting or other future product features are currently available.

3. Personal data we may collect

Information you provide directly

When you join early access, we may collect:

• your email address;
• your user type;
• the selected Move Existing or Create New path;
• an optional website URL on the Move Existing path;
• whether you separately chose to receive NovoraLux marketing.

Optional later research may ask for information such as country, language, managed-site count, migration or email-migration interest, expected timeframe, willingness-to-pay information or white-label interest. Those questions are optional and may not be available yet.

Attribution and technical information

We may record limited source, medium, campaign, campaign content, referring site or page, and landing page/path information. We may also process limited technical or security information necessary to operate and protect the website, such as request or security logs.

4. How we collect personal data

We generally receive personal data directly from you, from approved campaign/referral information when you reach the site, and from technical systems needed to deliver, secure and operate the website. Information provided for one purpose is not treated as unrestricted permission for unrelated use.

5. Why we use your personal data

A. Early-access administration

We may use your information to record and manage your registration, understand which type of NovoraLux user you may be, assess interest in testing or future access, invite suitable users to relevant opportunities, and provide information genuinely necessary to administer the requested early-access relationship.

Recommended legal basis for publication: our legitimate interests under Article 6(1)(f) GDPR in operating and evaluating a voluntary pre-launch early-access programme and responding to people who asked to participate. This remains subject to qualified-counsel review before final legal sign-off.

B. Optional NovoraLux marketing

If you separately opt in, we may use your email address for NovoraLux product news, newsletters, relevant website or migration content, launch communications and occasional promotional offers.

Legal basis: consent under Article 6(1)(a) GDPR and applicable electronic-marketing rules. Joining early access does not require marketing consent, and NovoraLux marketing consent does not constitute consent to Varna SEO Agency promotional marketing.

C. Website URL submitted with Move Existing

If you optionally provide a URL, we may use it to understand your potential migration use case and early-access demand.

Submitting a URL through the waitlist does not authorize NovoraLux to crawl, scan, scrape, screenshot, analyze, reconstruct, import or migrate that website.

D. Attribution and product planning

Limited source, campaign, referral and landing-page information may be used to understand how people discover NovoraLux, evaluate acquisition channels and improve the early-access experience.

E. Optional product research

If you choose to answer optional post-signup questions, we may use them for product research, planning and early-access prioritisation. Participation is voluntary.

6. Early-access messages and marketing are separate

Joining early access allows us to send communications reasonably necessary to administer the programme you requested, such as registration confirmation, relevant status information, testing invitations or access instructions where applicable. These are different from optional recurring marketing communications.

7. Marketing consent and double opt-in

Where offered, the NovoraLux marketing checkbox is optional, not selected by default and not required for early access. We may use a double opt-in process to verify marketing subscriptions.

If you do not complete marketing double opt-in, your underlying NovoraLux early-access registration remains valid. You may withdraw marketing consent at any time.

8. Website URLs and third-party/client websites

You should only provide a URL where you have a legitimate reason to identify that website in connection with your NovoraLux enquiry, for example a site you own, an organization you represent, or a client site you legitimately manage. Providing a URL does not prove ownership or grant permission for technical scanning or migration.

9. Cookies, local storage and similar technologies

For the initial early-access implementation, NovoraLux intends to avoid non-essential persistent client-side tracking for first-touch attribution where technically practical.

At this stage we do not intend the waitlist to rely on advertising cookies, cross-site advertising identifiers, behavioural profiling, fingerprinting, Meta advertising pixels, LinkedIn advertising pixels, Google Ads advertising cookies or persistent marketing-attribution storage unless separately reviewed and disclosed.

If actual implementation introduces analytics, advertising or other non-essential cookies or device storage, this notice and relevant consent controls must be updated before those technologies are enabled.

10. Data minimisation

We aim to collect only information reasonably relevant to early-access and product-research purposes. Email and user type form the basic registration; the Move Existing URL is optional; later research is optional.

11. How long we keep personal data

We retain personal data only for as long as reasonably necessary for the stated purposes and applicable legal, security or compliance requirements.

Active early-access records are generally expected to be retained for up to 24 months after the last meaningful interaction, unless you become a customer, request deletion where applicable, or we determine the information is no longer needed earlier.

Submitted URLs are generally kept no longer than the corresponding early-access record. Attribution and optional research information may be retained with that record or aggregated/anonymised earlier.

If you unsubscribe from marketing, we may retain limited information needed to record that preference and avoid accidental resubscription.

12. Deletion

You may ask us to delete personal data relating to you. Where the GDPR right to erasure applies, we will delete relevant information unless we have a lawful reason to retain some of it, such as a legal obligation, legal claims, a minimal marketing suppression record, or permitted security/abuse-prevention needs.

13. Your data-protection rights

Depending on applicable law and circumstances, you may have rights of access, rectification, erasure, restriction, objection, data portability and withdrawal of consent.

To exercise a privacy right, contactagency@varnaseoagency.com.

14. Complaints

You may contact us first atagency@varnaseoagency.com. You also have the right to lodge a complaint with a competent data-protection supervisory authority.

Bulgarian supervisory authority: Commission for Personal Data Protection (CPDP), 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria.

15. Service providers and processors

We may use trusted service providers for hosting/infrastructure, databases/storage, transactional email, marketing email, website security/anti-abuse and analytics if later deployed.

This notice intentionally does not name vendors that have not yet been finally selected or deployed. The processor/subprocessor inventory must be reconciled before the relevant production gate.

16. International transfers

Some service providers later selected may process personal data outside Bulgaria or the EEA. Where international transfers occur, we will assess applicable requirements and use an appropriate legal mechanism where required. Exact transfer arrangements depend on processors actually selected.

17. Security

We use reasonable technical and organisational measures appropriate to the nature of the information and risks involved. No online service can guarantee absolute security, and NovoraLux does not claim that security incidents are impossible.

18. Automated decision-making

The W3 early-access implementation is not intended to make decisions producing legal or similarly significant effects through solely automated processing.

19. Required and optional information

• Email address is required.
• User type is required.
• Move Existing / Create New path is derived from your interaction.
• Website URL on Move Existing is optional.
• Post-signup research, where offered, is optional.
• NovoraLux marketing consent is optional.

20. Changes to this Privacy Notice

We may update this notice when the product, data processing, service providers, analytics/cookie technology or legal requirements change. The production version will display its effective or last-updated date.

21. Contact us

Varna SEO Agency Ltd.
“ВАРНА СЕО АЙДЖЪНСИ” ООД
Registration No. 207046109
ul. Petko Todorov 62
Varna, 9000
Bulgaria

Email:agency@varnaseoagency.com