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GENERAL TERMS AND CONDITIONS

ADOPTED ON 30.03.2025

I. SUBJECT

Art. 1. (1) These General Terms and Conditions are intended to regulate the relations between "DANUBE COMMUNICATION" Ltd., UIC: 208055812, with its registered office and management address in the Republic of Bulgaria, Sofia, "Ekzarch Yosif" St. No. 93, hereinafter referred to as the "Provider," and the users, hereinafter referred to as "Clients" or "Users," of the platform https://alain-soral.com/, hereinafter referred to as the "Platform."

(2) Information in accordance with the Electronic Commerce Act and the Consumer Protection Act:

  1. Provider's Name: "DANUBE COMMUNICATION" Ltd.
  2. Registered Office and Management Address: Republic of Bulgaria, Sofia, "Ekzarch Yosif" St. No. 93.
  3. Address for Business Operations and for Submitting Consumer Complaints: Republic of Bulgaria, Sofia, "Ekzarch Yosif" St. No. 93.
  4. Correspondence Details: Republic of Bulgaria, Sofia, "Ekzarch Yosif" St. No. 93, email: [email protected]
  5. Public Register Entry: UIC 208055812
  6. VAT Registration Number: BG 208055812
  7. Regulatory Authorities:
Consumer Protection Commission

Address: Sofia, "Vrabtcha" St. No. 1, Floors 3, 4, and 5,

Phone: +359 2 933 0565;

Fax: +359 2 988 42 18

Hotline: 0700 111 22; *2211

E-mail: [email protected]

Website: www.kzp.bg

Commission for Personal Data Protection

Address: Sofia, "Prof. Tsvetan Lazarov" St. No. 2,

Phone: +359 2 915 35 19; +359 2 915 35 55

Fax: +359 2 915 35 25

E-mail: [email protected]

Website: www.cpdp.bg

III. CHARACTERISTICS OF THE PLATFORM

Art. 2. https://alain-soral.com/ is a platform for providing video content, accessible at the Internet address https://alain-soral.com/, through which Users have the opportunity to enter into agreements for the purchase of one-time viewing of video content or for purchasing a monthly subscription to the Platform, granting access to an unlimited number of videos offered by the Provider, including the following:

  • Register and create an account to use the Provider's Platform;
  • Freely browse the types of videos without access to their content, additional textual information, prices, and terms of use;
  • Freely access video content designated by the Provider;
  • Enter into agreements with the Provider for a one-time purchase or monthly subscription for services offered on the Platform;
  • Make electronic payments related to the agreements concluded through the Platform;
  • Receive information about new content or services offered by the Provider on the Platform;
  • Make electronic statements related to the conclusion or execution of contracts with the Provider through the interface of the https://alain-soral.com/ website, accessible online;
  • Be informed of their rights under the law, primarily through the Platform's interface;
  • Exercise their right of withdrawal, where applicable, under the Consumer Protection Act.

Art. 3. The Provider ensures the delivery of the paid content within the Platform and guarantees the rights of Users, Clients, and Registered Users as provided by law, in accordance with good faith, established practices, consumer protection, and commercial law standards.

Art. 4. (1) Users enter into an agreement with the Provider for the purchase of video content through the Platform at https://alain-soral.com/. The contract is concluded in English by accepting the General Terms and Conditions and is stored in the Provider's database within the Platform.

(2) Under the agreement concluded with Clients, the Provider undertakes to organize the delivery and seamless access to the purchased content specified by the Client through the Platform's interface.

(3) Clients pay the Provider a fee for the provided services in accordance with the terms published on the Platform. Fees are specified in euros, including value-added tax (VAT). In the event of a technical error in the pricing of services, the Provider shall promptly notify the Client of the correct price and has the right to cancel an order due to an incorrect price listing.

(4) Depending on the payment method chosen by the Client, additional transaction fees may apply, determined by the payment service provider, which are the Client's responsibility, including currency conversion charges.

Art. 5. (1) Users, Clients, Registered Users, and the Provider agree that all statements between them regarding the conclusion and execution of contracts may be made electronically, through electronic declarations as defined by the Electronic Document and Electronic Signature Act and Article 11 of the Electronic Commerce Act.

(2) It is presumed that electronic statements made by Users, Clients, and Registered Users on the Platform are performed by the persons specified in the registration data provided by them, and they have entered the respective username and password for access.

III. REGISTRATION FOR USING THE PLATFORM

Art. 6. (1) To use the services provided through the Platform, Users, Clients, and Registered Users must have a device connected to the internet that allows browsing and video content playback.

(2) Browsing the Platform (services, features, prices, terms of service, payment methods, policies, rules, etc.) is completely free and accessible.

(3) Registration on the Platform is required to request and use the services.

Art. 7. (1) Registration is free and can be completed by any natural person.

(2) A successful registration requires a username, password, and a valid email address.

(3) Registration data may be used in case of violations of these General Terms and Conditions or applicable national and European legislation to identify the responsible party.

(4) The data is also used to contact the Client in case of technical issues and to resolve problems arising during service provision and use.

Art. 8. (1) When registering, the User is required to provide accurate and up-to-date information and to update it promptly if any changes occur.

(2) The username and password are determined by the User.

(3) The User declares that they have read and understood these General Terms and Conditions and policies, agree to their content, and unconditionally commit to complying with them.

(4) The Provider is not responsible for incorrectly entered data that may affect the User's ability to use the Platform and access its content.

(5) The User must not share their username and password with third parties.

Art. 9. Upon successful registration, the User gains the status of a Registered User and receives full access to the Platform's functionalities, including the ability to request the offered services.

IV. PAYMENT, BILLING, AND CHANGES

Art. 10. Subscription and VOD Content.

(1) By accepting these Terms, creating an account on the Platform, providing a Payment Method, and completing a purchase from the Provider, you agree to pay the specified price for the selected service.

(2) The Provider will charge the first fee to your Payment Method for the chosen subscription or VOD content at the beginning of your selected billing period.

(3) Upon successful payment for the requested service, an invoice for the payment will be issued. If explicitly requested, the invoice will be sent to the email address provided during registration. The amount on the invoice will be displayed in Bulgarian Lev (BGN), converted from its Euro equivalent at the time of payment based on the current exchange rate.

Art. 11. VOD (Video on demand).

(1) All prices listed on the Platform for VOD content represent an offer, and if you make a purchase, it becomes final, forming a binding contract for providing the VOD content upon completion of the purchase.

(2) The contract for each VOD content item automatically terminates at the end of the applicable viewing period. This does not affect your ongoing agreement for other content or services on the Platform, including an active Subscription.

Art. 12. Subscription.

(1) The subscription price is charged at the time of activation for a period of one calendar month and will automatically renew each period unless you explicitly cancel the Subscription and take active steps to terminate it.

(2) The billing period may change due to issues with your Payment Method, such as an expired bank card, subscription plan changes, or if the subscription started on a day that does not exist in the next month.

(3) If you cancel your Subscription, your profile on the Platform will display information about the remaining paid usage period and the final date after which access to paid content will be discontinued.

Art. 13. Changes in Subscription and VOD Content Pricing.

(1) The Provider may modify the price of Subscriptions and VOD content on the Platform and will notify you of any price changes in accordance with these Terms of Use and applicable law.

(2) We may change the price of your Subscription or VOD content for the following reasons:

  1. To reflect costs for improvements, including new or enhanced features and functionalities or improvements in content delivery;
  2. Due to significant changes in production, licensing, or content acquisition costs;
  3. Due to costs arising from events beyond our control, such as fire, flood, or storm, which impact the operation of the Platform or your access to the Content;
  4. Due to costs arising from our compliance with legal or regulatory requirements, such as mandatory laws applicable to us and our agreement with you, or when we are subject to a court order or ruling;
  5. Due to changing market conditions or increased costs of doing business, including costs related to utilities and suppliers, personnel expenses (including salaries), administrative costs and customer service expenses, government or regulatory fees, levies, and taxes related to licensing, copyright royalties, and obligations for investments in audiovisual products.
  6. Because we provide the Platform continuously, we may introduce price changes for other unforeseen reasons, as long as such changes are reasonable and legally permitted.
  7. Price changes will only take effect at the beginning of the next billing period. If you do not wish to continue the Subscription at the new price, you may cancel before the next billing period begins.

Art. 14. Platform Updates and Changes.

(1) We may make regular updates and changes to the Platform in order to:

  1. Ensure compliance with applicable laws and/or reflect changes in relevant laws and regulatory requirements, such as mandatory consumer protection laws;
  2. Perform temporary maintenance, fix errors, implement technical corrections, and make improvements, such as adapting the Platform to a new technical environment, migrating the Platform to a new hosting platform, or ensuring the Platform's compatibility with devices and software;
  3. Upgrade the Platform or release a new version for certain devices, modify the list of compatible devices and software (including removing certain older device types, models, operating systems, or categories that are no longer compatible), or discontinue the Platform's compatibility with certain devices or software, as well as introduce other changes or modifications to existing features and functionalities;
  4. Modify the structure, design, or layout of the Platform or any Subscription Plan, including renaming the Platform, rebranding, or changing, improving, expanding, and/or removing features and functionalities available on the Platform or as part of a specific Subscription Plan;
  5. Ensure the Platform's proper operation;
  6. Adapt the Platform to market conditions;
  7. Improve security;
  8. Anti-piracy measures;
  9. To adapt the Platform in cases where we have reorganized the way we manage our business, including in the event of a merger with another brand or service;
  10. Improve, maintain, or expand the quality and range of Content provided on the Platform, and the ways we deliver that Content.

(2) Additionally, we provide the Platform on an ongoing basis and cannot predict what changes may occur in the future. This means that we may make changes or additions to the Platform for reasons other than those stated above, provided that such changes are reasonable and permitted by applicable law.

(3) If changes under Articles 13 and 14 significantly impact your access or use of the Platform, we will notify you in advance, allowing you to terminate your contract. If such changes take effect during your current billing period, you may cancel your Subscription within 30 days of receiving our notification or 30 days after the change takes effect, whichever is later. If you cancel under these circumstances, you will receive a refund for the affected period and any unused prepaid amounts. If you do not object to the changes or cancel your Subscription within 30 days, we will assume your acceptance.

Art. 15. Unpaid Amounts

(1) You are responsible for all fees related to your Subscription or any VOD content.

(2) If your Payment Method fails due to expiration, insufficient funds, or other issues, and you do not update it or cancel the Subscription, the Provider reserves the right to suspend access to your Subscription and/or Account until a valid Payment Method is provided or to terminate your Subscription. Please note that we will notify you in advance only about upcoming Subscription billing 7 days before the charge.

V. CONTENT RATING

Art. 16.

The Platform offers Content that may not be suitable for all ages or viewers. Content types, genres, categories, and short summaries are provided as guidance to facilitate navigation, and all permitted Content is labeled with a rating and content descriptions where necessary. However, you may disagree with the way certain Content is rated, and some Content may be unrated and/or contain strong language, violent scenes, alcohol, tobacco, drug or substance use, nudity, sexual content, discriminatory behavior, fear-inducing elements, mature themes, or otherwise be considered mature content intended only for adults or for supervised viewing by minors.

Art. 17.

Content may provoke different reactions among different individuals. As is the case with many websites and content platforms, you may encounter Content that you find objectionable or believe to be inappropriate for certain members of your family.

Art. 18.

The Provider is not responsible for rated Content under Article 16 being accessed by groups of individuals for whom it is not intended.

VI. RIGHTS, OBLIGATIONS, AND WARRANTIES OF THE PROVIDER

Art. 19.

In connection with the execution of the service provision contract, the Provider has the right to:

  1. Receive compensation for the provided services;
  2. Modify the prices and parameters of the offered services and content or discontinue their provision;
  3. Request from the Client and process all data necessary for their successful identification and registration, as well as for verifying the information provided by the Client, along with any additional information required for the provision of services;
  4. Refuse to provide a service if the Client does not meet the requirements and conditions for entering into a contract;
  5. At its discretion and without prior notice, suspend or temporarily restrict Users', Clients', and Registered Users' access to services if there is evidence or suspicion that they are using the services in violation of applicable laws or the Terms of Use;
  6. Temporarily interrupt the provision of services or limit their parameters during scheduled maintenance, troubleshooting of technical issues, or resolving security-related problems;
  7. Independently assess the severity of violations and determine the necessity of suspending or terminating access to services;
  8. Establish Policies and Rules for the use of services.

Art. 20.

In connection with the execution of the service provision contract, the Provider is obliged to:

  1. Grant the Client access to manage services through the Platform's functionalities;
  2. Provide the services according to the selected plan and parameters;
  3. Offer technical support for the service, including sending notifications via email or in the Client's profile regarding service changes, improvement suggestions, the addition of new features, or transitioning to a plan with different parameters;
  4. Ensure appropriate conditions for the technical operation of the services;
  5. Maintain the services in proper technical condition;
  6. Provide, within its technical capabilities and circumstances, a high level of security;
  7. Not use collected and stored information for purposes other than those related to its operations.

Art. 21.

The Provider conducts its activities while applying the following guarantees:

  1. Strictly complies with the Terms of Use, Regulation (EU) No. 2016/679, and the applicable legislation regarding his business;
  2. Ensures that the provided services do not violate copyright and licensing rights of third parties;
  3. Takes immediate action in the event of technical security issues;
  4. Uses and stores collected personal and other data solely for operational purposes in accordance with applicable laws;
  5. Maintains a trusted staff with the necessary expertise, experience, and qualifications for its activities;
  6. Conducts periodic internal audits;
  7. Undergoes periodic external audits by independent auditors;
  8. Uses certified software and hardware, as well as secure and reliable technological systems in its operations.

VII. SUSPENSION AND TERMINATION

Art. 22.

The Provider may reject, deactivate, suspend, or terminate your Subscription, any VOD content purchase, access to the Platform (including any Content), and/or your account:

  1. (1) With reasonable prior notice, for any reason, provided that if you have an active Subscription, such termination will take effect at the end of the current Billing Period; or
  2. (2) Immediately upon notification if, after receiving a notice of violation of these Terms, you fail to remedy the breach, including cases where it is determined that you have provided inaccurate account or payment information, engaged in fraudulent activity related to a purchase or provided information, no longer meet the Eligibility Criteria, or otherwise violate these Terms. We may also immediately terminate the Subscription, any VOD content purchase, access to the Platform (including any Content), and/or your account, with or without notice, when required by applicable laws or regulations, by order or request of a regulatory, administrative, or judicial authority, or when failure to do so would result in a violation of our legal or regulatory obligations; or
  3. (3) With reasonable prior notice, in the event that we discontinue providing access to the Platform. If the date on which we cease providing the relevant Platform or Content occurs during your Subscription, we will refund you the amount you have prepaid, corresponding to the time during which you will not have access to the Platform and Content.

Art. 23.

In addition to the above and with prior notice, we may modify access or disable features for security reasons, to limit the impact of account sharing outside your household, or in cases of account misuse.

Art. 24.

If any of the above events occur, you must stop using the Platform (or the relevant part of it). If the Provider disables your Subscription and/or access to all or part of the Platform for a valid reason, you are required and agree not to attempt to access the Platform and Content by circumventing restrictions or through illegal means.

Art. 25.

(1) These General Terms and the Client's contract with the Provider on the Platform shall be terminated in the following cases:

  1. 1. In the event of liquidation or bankruptcy of the Provider;
  2. 2. Upon the death of the Client;
  3. 3. By mutual written agreement of the parties;
  4. 4. In cases of objective impossibility for either party to fulfill its obligations;
  5. 5. In case of seizure or sealing of equipment by government authorities;
  6. 6. Upon deletion of the Client's or Registered User's account on the Platform. In this case, contracts that have been concluded but not yet fulfilled shall remain in force and be subject to execution.

(2) If the contract is terminated due to the Client's fault, the payment made to the Provider will be considered a penalty and may be retained as compensation for damages caused to the Provider due to the Client's wrongful termination of the contract.

Art. 26.

The Provider has the right, at its discretion, without prior notice and without owing compensation, to unilaterally terminate the contract if it finds that the Client is using the Platform in violation of these General Terms, the laws of the Republic of Bulgaria and The European Union, generally accepted moral standards, or commonly accepted rules and practices in e-commerce.

VIII. RESTRICTIONS ON THE USE OF THE PLATFORM

Art. 27.

Please note that creating an unauthorized copy of any element or part of the Platform, including the Content or the underlying software, constitutes a copyright infringement.

Art. 28.

You have the right to access and display Content on the Platform solely for your non-commercial, personal, and entertainment use on compatible devices while your Subscription is active and in good standing, and only in accordance with these Terms.

Art. 29.

You are not allowed to:

  1. (1) Copy, reproduce, distribute, transfer, sell, license, publish, enter into a database, display, publicly perform, modify, create derivative works from, upload, edit, post, link to, frame, transmit, rent, lease, lend, sublicense, or otherwise use any part of the Platform, or attempt to interfere with the operation of the Platform;
  2. (2) Use any data mining tools, robots, viruses, worms, bugs, or other data collection and extraction tools on the Platform, frame any part of the Platform, or attempt to tamper with, hack, damage, or disrupt the management and/or security of the Platform;
  3. (3) Copy, extract data, scrape, or otherwise retrieve any Content or data for the purpose of training an algorithm, system, model, or artificial intelligence tool, a large language model, a machine learning model, or any other similar technology;
  4. (4) Use Content files or other elements of the Platform to create any kind of database;
  5. (5) Perform reverse engineering, copy, decompile, disassemble, extract source code, modify, adapt, capture, reproduce, publicly display, publicly perform, transfer, sell, license, create derivative works from or based on, republish, upload, edit, post, transmit, distribute, exploit, bypass, or otherwise translate, in whole or in part, the Platform or any Content, nor attempt or encourage or assist any other person to do any of the above actions; or
  6. (6) Circumvent, disable, or otherwise tamper with security technologies that protect Content, system resources, accounts, or any other part of the Platform, or attempt to assist another person in doing so. The use or distribution of tools designed to compromise security (such as password-cracking programs, hacking tools, or network probing tools) is prohibited.

Art. 30.

(1) If "DANUBE COMMUNICATION" Ltd. grants you permission to copy or download any part of the Platform, this permission is limited to viewing a single copy for non-commercial, personal, and entertainment use and requires you to retain all copyright, trademark, and other proprietary notices intact. The use of materials in another service or networked computer environment is prohibited.

(2) The permission mentioned in the previous paragraph is valid and lawful only if it is in written form and duly signed by the company's manager.

IX. DISPUTE RESOLUTION AND APPLICABLE LAW

Art. 30.

Our customer service department can resolve most customer issues quickly and satisfactorily. Please contact the customer support team of "DANUBE COMMUNICATION" Ltd.

Art. 31.

In the event of a dispute, claim, or disagreement, we would like to attempt to resolve these issues amicably with you. You may submit a notification to us in accordance with Chapter "X. RIGHT TO COMPLAIN".

Art. 32.

These Terms and any legal proceedings initiated in connection with disputes related to these Terms are subject to Bulgarian law. However, nothing in these Terms limits consumer protection rights that you may have under the mandatory laws of the country where you reside.

Art. 33.

As a consumer, you have the right to refer the matter to the competent court in your place of residence. You may also choose to file a complaint as a first step with the relevant consumer protection authority in the Service Area, the relevant EU or national consumer dispute resolution body, or, if you reside in the EEA, you may visit https://ec.europa.eu/consumers/odr to resolve a consumer dispute online outside of court.

X. RIGHT TO COMPLAIN

Art. 34.

(1) Every Client has the right to file a complaint with:

1. The Provider "DANUBE COMMUNICATION" Ltd.

1.1. All disputes arising from a contract entered into under these General Terms and Conditions shall be resolved by mutual agreement between "DANUBE COMMUNICATION" Ltd. and the Client. Complaints regarding the use of services (Subscription and/or VOD) provided by the Provider will be considered after a written document is submitted to the address: "DANUBE COMMUNICATION" Ltd., UIC: 208055812, registered office and address: Republic of Bulgaria, Sofia, 93 "Ekzarch Josif" Str.; or digitally signed with an electronic signature and sent to the email address [email protected]

1.2. Upon initiation of this procedure, the complainant will receive a response within 1 (one) month from the receipt of the complaint, unless a different response time is explicitly provided by applicable legislation.

1.3. This time frame and procedure do not apply to disputes, complaints, and requests related to the processing of personal data. Such requests are handled in accordance with the Provider's applicable Privacy Policy and in accordance with the timelines and requirements of Regulation (EU) 2016/679 and applicable legislation.

2. The Consumer Protection Commission, when the Client qualifies as a "consumer" within the meaning of the Consumer Protection Act.

2.1. The complaint should include: the name of the authority to which the complaint is submitted; the name, postal and/or email address of the complainant; the entity against whom the complaint is lodged, including the name/trading name of the trader or business entity, as well as its registered office or management address; the complainant's complaints and requests; the signature of the person submitting the complaint when submitted in paper form, or of their authorized representative; if the complaint is filed through a representative, a power of attorney must be provided; if the complaint is submitted electronically, it does not need to be signed with an electronic signature; evidence the complainant possesses – copies of receipts, invoices, contracts, and others on which the claim is based.

2.2. The complaint can be submitted on paper to the address: Consumer Protection Commission, Sofia, 1 Vrabcha St., 3rd, 4th, and 5th floors, phone: +359 2 933 0565; fax: +359 2 988 42 18, hot line: 0700 111 22; *2211; or electronically, in accordance with the rules of the E-Government Law to the email: [email protected].

(2) Dispute resolution through judicial procedures.

1. If no agreement is reached between the parties, the dispute will be referred for resolution to the competent Bulgarian court.

2. If the Client is a consumer within the meaning of the applicable consumer protection legislation and is established in a country other than the Republic of Bulgaria, the application of mandatory legal provisions in that country, for which no derogation is allowed and which are designed to protect consumer rights, is not affected by the choice of competent court in this section.

XI. PERSONAL DATA PROTECTION

Art. 35.

(1) The collection, storage, and processing of personal data is carried out in accordance with the Privacy Policy of "DANUBE COMMUNICATION" Ltd.

(2) The personal data provided by Clients and Registered Users are protected under the Personal Data Protection Act and General Regulation 2016/679, with the Provider processing them for the purposes and within the timelines specified in the Privacy Policy.

(3) The Provider has implemented all necessary technical and organizational measures to protect the personal data of individuals when using the Platform of "DANUBE COMMUNICATION" Ltd.

Art. 36.

(1) At any time, the Provider on the Platform has the right to request the Client or Registered User to authenticate and verify the accuracy of any information and personal data provided during registration.

(2) If, for any reason, the Client or Registered User has forgotten or lost their username and password, the Provider of the platform alain-soral.com has the right to apply the "Procedure for Lost or Forgotten Usernames and Passwords," available at: https://alain-soral.com/.

XII. AMENDMENT AND ACCESS TO THE GENERAL TERMS AND CONDITIONS

Art. 37.

These General Terms may be amended by the Provider of the Platform, who will notify all Registered Users, Users, and Clients in an appropriate manner.

Art. 38.

We have the right to change these Terms at any time for the following reasons:

(1) To improve the Terms, making them clearer or easier to understand, or to ensure that all our clients have the same Terms;

(2) For reasons beyond our control, or to comply with legal or regulatory requirements, such as mandatory laws applicable to us and our agreement with you, or when we are subject to a court order or decision;

(3) To provide you with additional information about the Platform,

(4) When we make changes to the Platform or any Subscription, including when we change the structure of our Platform or expand its scope by adding additional features, functionalities, Subscriptions, or Content;

(5) When we reorganize the way we manage our business, including merging with another brand or service; or

(6) For security reasons, including when we implement additional security checks or software to protect our Content or the Platform.

Art. 39.

Additionally, we provide the Platform on an ongoing basis, and we cannot predict what may change in the future. This means that we may make changes or additions to these Terms for reasons other than those listed above, provided these changes are reasonable and permitted by applicable legislation.

Art. 40.

If we change these Terms, we will notify you and give you the opportunity to review the new terms before they take effect, unless an update needs to be made quickly to reflect an urgent change to the Platform, or for reasons related to security, legal, or regulatory matters (in such cases, we will notify you of the changes as soon as possible).

Art. 41.

If we reasonably determine that any change to these Terms will significantly affect your legal rights or obligations, we will notify you in a reasonable time frame about these changes and explain how you can notify us if you refuse to accept the new terms.

Art. 42.

If you refuse to accept the new terms before they take effect, the version of the terms you accepted earlier will continue to apply to your use of the Platform until the end of your current Billing Period.

Art. 43.

If you do not refuse to accept such changes before they take effect, we will assume that you agree to them.

Art. 44.

The most current version of the Terms will always be available on the Platform from the date they take effect.

Art. 45.

Users, Clients, and Registered Users agree that all statements by the Provider on the Platform regarding changes to these General Terms will be sent to the email address provided by the Client or Registered User during registration and will receive a notification on the Platform. Clients and Registered Users agree that emails sent under this article do not need to be signed with an electronic signature in order to be effective.

XIII. LIABILITY

Art. 46.

Clients and Registered Users agree to indemnify and release from liability the Provider from any legal claims and other third-party demands (whether they are justified or not), for all damages and costs (including attorney fees and court expenses) arising from or related to:

1. Non-fulfillment of any of the obligations under this contract,

2. Violation of copyright, producer rights, broadcasting rights, or other intellectual or industrial property rights,

3. Unauthorized transfer of rights granted to Clients and Registered Users, for the duration and under the conditions of the contract,

4. False declaration of the presence or absence of consumer status as defined by the Consumer Protection Act.

Art. 47.

The Provider is not liable in case of force majeure, accidental events, internet problems, technical or other objective reasons, including orders from competent state authorities.

Art. 48.

(1) The Provider is not responsible for damages caused by Users, Clients, and Registered Users to third parties.

(2) The Provider is not liable for property or non-property damages, such as lost profits or suffered damages, caused to Users, Clients, and Registered Users in the process of using or failing to use the Platform and entering into agreements with the Provider.

(3) The Provider is not liable for the time during which the Platform was unavailable due to force majeure.

Art. 49.

The Provider is not liable in case of a breach of security measures on the technical equipment, leading to the loss, dissemination, access, restriction of access, or other similar consequences regarding information.

Art. 50.

Limitation of Liability of "DANUB COMMUNICATION" Ltd.:

(1) The Provider is not responsible to the Client or Registered User for damages resulting from the provision of incorrect, incomplete, or inaccurate data;

(2) The Provider is not liable for damages and lost profits resulting from the untimely request or failure to request by the Client to terminate, stop, or modify the services provided through the Platform;

(3) The Provider is not liable for damages and lost profits resulting from non-fulfillment of the Client's obligations under these General Terms, as well as for damages caused by the Client's failure to meet obligations according to the applicable Policies and Practices of "DANUB COMMUNICATION" Ltd. or the prevailing legislation;

(4) The Provider is not liable for damages and lost profits resulting from the non-provision of services or provision of services with worsened quality due to testing or maintenance aimed at improving or optimizing the provided services, provided that the Provider has notified Users, Clients, and Registered Users in advance by publishing information on the Application or through another appropriate method.

(5) The Provider is not responsible for poor quality and functionality of software products and hardware devices used by Users, Clients, and Registered Users;

(6) The Provider is not liable for the termination of access to services or deletion of services from the Client's profile due to non-payment of obligations as a result of actions or inactions of third parties and/or institutions;

Art. 51.

Users, Clients, and Registered Users bear full responsibility when using content that is subject to copyright and related rights protection.

XIV. INTELLECTUAL PROPERTY

Art. 52. Copyrights and Trademarks

(1) The Platform and all materials included within it are protected by copyright, patents, trademarks, trade secrets, or other legal rights. Any rights that do not belong to the Provider have been duly acquired from their respective owners, with the necessary agreements signed.

(2) You are not allowed to:

(а) Display any Content to a public audience or view it in a public space; or

(б) Attempt to bypass, avoid, disable, remove, deactivate, damage, or otherwise circumvent any encryption technology, rights signaling, or copy protection measures applied to the Content. Unauthorized copying, editing, display, broadcasting, or distribution of copyrighted material may result in severe criminal and civil penalties under applicable laws.

(3) Some symbols, logos, or other images in the Platform are protected as our registered or unregistered trademarks, trade names, and/or service marks ("Trademarks"). All other trademarks belong to their respective owners. The use of our or third-party Trademarks is not permitted except as included in the Platform and authorized under these Terms.

(4) We may collect data on Platform usage and other information to ensure that the Platform is being used in accordance with these Terms, as outlined in the Privacy Policy.

Art. 53. Copyright Infringement Notice

If you believe that any Content appearing anywhere on the Platform has been copied in a way that constitutes copyright infringement under the laws of the Service Area, please send the following information via email to [email protected]:

1. Your name, address, phone number, and email address;

2. A description of the copyrighted work that you claim has been infringed;

3. The exact URL or a description of the location where the allegedly infringing material can be found;

4. A statement from you asserting that you have a good-faith belief that the disputed use is not authorized by the copyright owner, their agent, or the law;

5. An electronic or physical signature of the person authorized to act on behalf of the copyright owner; and

6. A declaration from you that the information provided in the notice is accurate and that you are the copyright owner or authorized to act on behalf of the copyright owner.

XVI. OTHER TERMS

Art. 54.

(1) The Client and the Provider on the Platform undertake to mutually protect their rights and legal interests, as well as to keep confidential any trade secrets that have come to their knowledge in the course of executing the contract and these general terms.

(2) The Client and the Provider agree that during and after the expiration of the contract period, they shall not make public any written or verbal correspondence exchanged between them. Making correspondence public includes, but is not limited to, publishing it in print or electronic media, internet forums, personal or public websites, etc.

Art. 55.

In case of a conflict between these general terms and the provisions of a special agreement between the Provider on the Platform and the Client, the clauses of the special agreement shall prevail.

Art. 56.

The possible invalidity of any provision of these general terms shall not result in the invalidity of the entire contract.

Art. 57.

For any matters not regulated in these General Terms, related to their execution and interpretation, the laws of the Republic of Bulgaria shall apply.

Art. 58.

These General Terms and Conditions shall come into effect for all Registered Users and Clients of the Platform.

XV. DEFINITIONS

  1. "Provider" refers to "DANUBE COMMUNICATION" Ltd
  2. "Service" means an electronic service, typically provided for a fee, which consists of access to video content
  3. "Consumer" refers to any natural person who purchases goods or uses services that are not intended for commercial or professional activities, and any natural person who, as a party to a contract under the Consumer Protection Act, acts outside the scope of their commercial or professional activities
  4. "User" refers to any natural person who accesses the Platform but does not have the status of a Client or a Registered User
  5. "Registered User" refers to any person who has successfully completed the registration procedure on the Platform but has not purchased a service
  6. "Client" refers to any natural person who has purchased a monthly subscription or VOD content
  7. "Platform" refers to https://alain-soral.com/
  8. "Content" refers to any available video content on the Platform
  9. "Subscription" refers to the purchase of monthly access to video content on the Platform
  10. "VOD (Video on Demand)" refers to the purchase of access to specific video content from the Platform, which is not tied to a Subscription purchase
  11. "Force Majeure Event" refers to an unforeseen extraordinary circumstance at the time of concluding the general terms, which makes the provision of services objectively impossible
  12. "Malicious Actions" refer to actions or omissions that violate Internet ethics or cause harm to individuals connected to the Internet or associated networks. This includes sending unsolicited mail (spam, junk mail), overloading channels (flooding), gaining unauthorized access to resources (hacking), exploiting system vulnerabilities for personal gain or data extraction, conducting industrial espionage or sabotage, damaging or destroying systems or information databases (cracking), sending "Trojan horses" or installing viruses or remote control systems, disrupting the normal operation of other Internet users and associated networks, or engaging in any other actions that may qualify as a crime or administrative offense under Bulgarian law or other applicable legislation

Appendix 1

Standard Form for Exercising the Right of Withdrawal from the Contract:

(Complete and submit this form only if you wish to withdraw from the contract)

To "DANUBE COMMUNICATION" Ltd., UIC: 208055812, with registered office and management address: Republic of Bulgaria, Sofia, "Ekzarch Yosif" Str. No. 93, Email: [email protected]:

I hereby notify you that I withdraw from the contract I concluded for the provision of the following service ………………………...…………………………………… …………………………………………………………………………………………………...

Ordered on ……/……………/………..г. Received on ……/……………/………..г.
Consumer's Name: …………...………………………………………………………………
Consumer's Address: ………………………………………………………………………… …………………………………………………………………………………………………...

Date: ……./……………..…/…………. г.
Consumer's Signature (Physical or electronic one):

…………………..

Appendix 2

Information on Exercising the Right of Withdrawal from the Contract
Instructions for Withdrawal:
Right of Withdrawal from a Distance or Off-Premises Contract:
  • You have the right to withdraw from this contract without providing any reason within 14 days;
  • The withdrawal period is 14 days from the date on which you, or a third party designated by you (other than the carrier), take possession of the goods;
  • To exercise your right of withdrawal, you must notify us via the contact details provided on https://alain-soral.com/ with an unequivocal statement (e.g., a letter sent by post or email);
  • You may use the attached standard withdrawal form, but this is not mandatory. You can also electronically fill out and submit the standard withdrawal form or any other clear statement of withdrawal on our website https://alain-soral.com/. If you use this option, we will immediately send you a confirmation of receipt of the withdrawal on a durable medium (e.g., by email);
  • To comply with the withdrawal deadline, it is sufficient to send your withdrawal notification before the withdrawal period expires.
Effects of Withdrawal:
  1. 1. If you withdraw from this contract, we will refund all payments received from you, including delivery costs (if applicable), except for additional costs resulting from your choice of a delivery method other than the least expensive standard delivery method offered by us. The refund will be made without undue delay and no later than 14 days from the day we are informed of your decision to withdraw from this contract. We will process the refund using the same payment method you used for the initial transaction unless you have expressly agreed otherwise. In any case, you will not incur any fees as a result of the refund.
  2. 2. If you have requested to start using the services during the withdrawal period, you must pay us an amount proportional to what has been provided until the moment you informed us of your withdrawal from this contract, compared to the full coverage of the contract.

Personal Data Protection Policy of "DANUBE COMMUNICATION" Ltd.

"DANUBE COMMUNICATION" Ltd. processes your personal data with maximum security in relation to the contractual relationships between you and the company, and in accordance with the regulatory obligations arising from its activities.

"DANUBE COMMUNICATION" Ltd. collects and processes personal data only in compliance with local and European legislation. The processing is related to a specific purpose and cannot be carried out without limitation.

Regarding the purposes and grounds for processing personal data, "DANUBE COMMUNICATION" Ltd. acts as a data controller. In this capacity, "DANUBE COMMUNICATION" Ltd. is committed to implementing technical and organizational measures to ensure the protection of personal information.

This "Personal Data Protection Policy" provides information on the purposes, legal grounds, and methods of processing personal data, the categories of personal data processed, the categories of recipients to whom they may be disclosed, as well as your rights regarding the processing of your personal data.

Please carefully review the content of this policy, as it is a mandatory condition for your registration on our platform and for the provision of our services.

Policy Updates and Changes

To apply the most up-to-date protection measures and comply with current legislation, we will regularly update this Personal Data Protection Policy. We encourage you to regularly review the current version of this policy to stay informed about how we ensure the protection of the personal data we process.

This Personal Data Protection Policy was adopted on 30.03.2025

I. Information about the Personal Data Controller

"DANUBE COMMUNICATION" Ltd., UIC 208055812, with its registered office and management address in Republic of Bulgaria, city of Sofia, "Ekzarch Yosif" Str. No. 93, website: https://alain-soral.com/, e-mail: [email protected]

I.I Information about the Data Protection Officer

……………………………… e-mail: https://alain-soral.com/, tel.: ………

II. Information about the Competent Supervisory Authority

  1. Name: Commission for Personal Data Protection
  2. Registered office and management address: Sofia 1592, "Prof. Tsvetan Lazarov" Blvd. No. 2
  3. Correspondence address: Sofia 1592, "Prof. Tsvetan Lazarov" Blvd. No. 2
  4. Telephone: +35929153518
  5. Email: [email protected], [email protected]
  6. Website: www.cpdp.bg

III. Purpose and Scope of the Personal Data Protection Policy

This policy follows the territorial and material scope of Regulation (EU) 2016/679 and adopts its main objectives. It is applied by all our employees.

"DANUBE COMMUNICATION" Ltd. needs to collect and process personal data to carry out its activities lawfully, appropriately, and effectively. This applies to the personal data of employees, customers, and visitors to the website/platform.

IV. Categories of Personal Data, Purposes, and Legal Grounds for Processing

"DANUBE COMMUNICATION" Ltd. processes different categories of personal data for different subjects based on specific grounds according to the pursued purposes. In compliance with Articles 13 and 14 of Regulation (EU) 2016/679 and the principles of legality, fairness, transparency, and awareness, as well as for the convenience of data subjects, this section provides detailed information on the necessary aspects of data processing.

1. Categories of Personal Data Provided by the Data Subject – Natural Person:

Data Related to Physical Identity

  • Name and surname;
  • Personal Identification Number/Date of Birth – for invoices;
  • Contact details: email and phone number;
  • Address: permanent or current;
  • IP address.

Data Related to Economic Identity

  • Payments are processed through the Revolut platform, and we do not process our clients' banking data. We receive information from Revolut regarding successful or unsuccessful payments.

3. Purposes and Legal Grounds for Processing

The personal data obtained from the data subject – natural person – will be used for the provision of our services, in compliance with contractual obligations, legal requirements applicable to the administrator, and the protection of legitimate interests, including:

  • Creating a profile on the Controller's Platform;
  • Subscription payments;
  • Payments for VOD (Video on Demand);
  • Establishing and maintaining registers for accountability;
  • Financial and accounting reporting;
  • Issuing invoices;
  • Responding to data subject requests regarding their rights under Regulation (EU) 2016/679;
  • Marketing purposes;
  • Performing other functions as required by law or contractual obligations.

The processing of the specified categories of personal data provided by you is carried out on the basis of:

  • Article 6, paragraph 1, letter "c" of Regulation (EU) 2016/679 – legal obligations applicable to the controller, as stipulated in statutory and regulatory acts governing our activities, such as the Consumer Protection Act, the Corporate Income Tax Act, the Value Added Tax Act, the Accounting Act, and others.
  • Article 6, paragraph 1, letter "b" of Regulation (EU) 2016/679 – performance of a contract to which you (the data subject) are a party, as well as taking steps at the request of the data subject before entering into a contract. An example of such steps includes creating an account in our system.
  • Article 6, paragraph 1, letter "f" of Regulation (EU) 2016/679 – protection of legitimate interests.
  • The processing of certain personal data related to your physical identity, namely names and email address, for the purposes of direct marketing will only be carried out based on your freely given, specific, informed, and unambiguous consent, in accordance with Article 6, paragraph 1, letter "a" of Regulation (EU) 2016/679.

4. The Controller does not apply "automated individual decision-making, including profiling.

5. "DANUBE COMMUNICATION" Ltd. does not collect or process personal data solely for the purpose of identifying the subject when it pertains to:

  • Racial or ethnic origin;
  • Political, religious, or philosophical beliefs, or trade union membership;
  • Genetic data, data concerning sexual life or sexual orientation.

6. The Controller does not collect or process personal data of minors.

7. This policy does not apply to the processing of personal data of a data subject (natural person) within the scope of their purely personal activity or household-related matters.

V. Categories of Recipients of Personal Data

"DANUBE COMMUNICATION" Ltd. may provide your personal data to third parties, primarily to protect your interests and security in relation to the fulfillment of legal and contractual obligations or specific tasks. Personal data is not provided to third parties without ensuring that all technical and organizational measures for data protection have been taken, with strict control over the enforcement of these measures. Where applicable, we ensure that your data is processed only according to the instructions provided on behalf of the controller – "DANUBE COMMUNICATION" Ltd.

1. Recipients of Data, Outside the Controller:

Entities Requiring Information on a Legal Basis

  • State and municipal authorities, agencies, institutions, and other competent regulatory bodies, in accordance with their powers (ministries, directorates, agencies, commissions, etc.);
  • Judicial authorities (courts, prosecution offices, etc.);
  • Regulatory bodies (Commission for Personal Data Protection, Commission for Protection of Competition, Consumer Protection Commission, etc.);
  • Auditors and accreditation bodies;
  • Experts and judicial officers.

Entities Requiring Information on a Contractual Basis

  • Service providers (consultants, experts, accountants, appraisers, auditors, lawyers). Such data disclosure occurs only when there is a legitimate reason and based on a written agreement ensuring that recipients provide an adequate level of protection;
  • Companies providing cloud services – AWS.
  • Marketing agencies, only upon your explicit consent;
  • Entities contracted to maintain equipment, software, and hardware used for processing personal data and essential for the company's operations;
  • Courier companies.

2. Recipients of Data Within the Controller

  • Internal sharing among employees, with full compliance with the implemented technical and organizational security measures.

VI. Technical and Organizational Data Protection Measures

To ensure adequate protection of the data of its employees, clients, and partners, "DANUBE COMMUNICATION" Ltd. applies all necessary organizational and technical measures provided for in the Personal Data Protection Act and Regulation (EU) 2016/679, both in terms of data protection by design and data protection by default.

Data protection by design is implemented through appropriate technical and organizational measures introduced by "DANUBE COMMUNICATION" Ltd. before the start of personal data processing (during the stage of determining the purposes and means of processing) and ensuring their application throughout the entire data lifecycle.

Personal data protection is ensured through mechanisms that, by default, guarantee compliance with the following requirements:

  • Only the minimum amount of personal data necessary to achieve a specific purpose is processed, and only essential processing operations are performed;
  • Licensed software and electronic security certificates are used for system and internet platform/website protection;
  • Encrypted email services with paid, private domains are used. Documents containing personal data and classified information are not sent to public domain email addresses;
  • Only employees who need access to perform their official duties can access personal data;
  • Personal data is not shared with other employees unless necessary for fulfilling their job responsibilities;
  • Employees must handle data with care and responsibility during their work and while accessing the platform, ensuring that their devices are never left unattended;
  • The company's office does not store documents related to personal data processing. All information is entirely digital and stored in cloud systems, following cloud service providers' policies. However, due to legal obligations, certain documents containing personal data must be stored on paper, which is done in a designated, locked cabinet;
  • Cloud service access is secured through an HTTPS connection, and every employee is informed about IT and information security policies. Employees are notified of any updates relevant to their role;
  • For internal operations and customer data processing, we use cloud platforms that provide remote access with user-level permissions and strict data security policies;
  • Data access is granted to specific employees through a personal work account for completing a specific task;
  • If an employee leaves the company, they immediately lose access to all related data;
  • A password policy and user rights management system are in place;
  • Employees undergo training on the correct implementation of Regulation (EU) 2016/679 and the application of introduced technical and organizational measures and procedures;
  • Data is stored for the minimum period necessary to achieve processing objectives and is deleted afterward in compliance with relevant rules and procedures;
  • Data that is no longer legally required is irreversibly destroyed, with a deletion protocol;
  • Data access, transfer, or sharing is only allowed when a valid legal basis exists (e.g., contract, data subject's consent, or legal obligations);
  • Downloading, sharing, or storing any confidential data accessed by employees for work purposes is strictly prohibited on personal devices (e.g., laptops, tablets, mobile phones, cameras, or smartphones), nor can it be recorded in any way (e.g., photos, videos, screenshots, or other images);
  • Highest levels of information and hardware security are applied in accordance with Regulation (EU) 2019/881;
  • 24/7 system maintenance is conducted to minimize security breaches, data leaks, and identity fraud;
  • A full internal audit and system check is conducted every 12 months;
  • If there is evidence of a security breach, the service may be temporarily or permanently suspended to prevent unauthorized actions by third parties;
  • The controller ensures that data processors and any individuals acting under the controller's guidance process personal data only as instructed and for the specified purpose;
  • In case of a personal data security breach, the controller will promptly notify the competent supervisory authority (Commission for Personal Data Protection – CPDP) and, if necessary, the affected data subject.

"DANUBE COMMUNICATION" Ltd. reserves the right to implement additional security measures for employees when necessary. To ensure maximum security in data processing, transmission, and storage, additional protection mechanisms may be applied.

VII. Transfer of Data to Third Countries

No personal data is transferred to third countries, and no processing occurs outside the European Union. If such a transfer is required in the future, it will be done to enhance cybersecurity, with properly signed contracts and only after verifying the implementation of appropriate technical and organizational measures, as per Regulation (EU) 2016/679. The transfer will be carried out only if a low level of risk is demonstrated, in compliance with Regulation (EU) 2019/881.

VIII. Data Retention Period

"DANUBE COMMUNICATION" Ltd. generally ceases full processing of personal data for the specified purposes after the termination of contractual relationships or upon request by the data subject. However, data is not deleted before the expiration of the legally mandated retention periods, in accordance with the storage limitation principle.

Your personal data will not be deleted or anonymized if they are required for ongoing legal, administrative proceedings, or the resolution of a complaint. Data is retained no longer than necessary. Below are the retention periods for certain categories of particularly significant data..

1. Statutory Data Retention Periods:

  • Information required for account creation – up to 5 years;
  • Data processed based on the data subject's consent – until consent is withdrawn;
  • Under the Accounting Act – retention and processing of accounting data for 10 years, starting from the year following the last payment;

2. Retention Periods Determined by the Controller:

  • The system may integrate the ability to process data and logs collected from failed identification attempts and/or terminated registration processes – retained for up to 2 years from the occurrence.

IX. Data Subject Rights – For Individuals

1. Right to Information and Access.

You have the right to request:

  • Information about whether data concerning you is being processed, the purposes of such processing, the categories of data, and the recipients or categories of recipients to whom the data is disclosed;
  • A communication in an intelligible form containing your personal data being processed, as well as any available information about their source;
  • Information on the logic behind any automated processing of personal data related to you, at least in cases of automated decisions.

2. Right to Rectification.

In cases where we process incomplete or incorrect data, you have the right, at any time, to request:

  • Deletion, correction, or blocking of your personal data whose processing does not comply with legal requirements;
  • Notify third parties to whom your personal data has been disclosed of any deletions, corrections, or blocking, except where this is impossible or requires excessive effort.

3. Right to Erasure.

The right to erasure, or "the right to be forgotten," provides the ability, when you no longer wish your data to be processed and there are no legal bases for their storage, to request their deletion based on one of the following grounds:

  • Personal data is no longer necessary for the purposes for which they were collected or otherwise processed;
  • You withdraw your consent on which the data processing is based;
  • You object to the processing and there is no overriding legal basis for the continuation of processing;
  • Personal data have been processed unlawfully;
  • Personal data must be erased to comply with a legal obligation;

"The right to be forgotten" is not an absolute right. There are situations in which the controller may refuse to erase the data, namely when the processing of specific data is necessary for any of the following purposes:

  • Exercising the right to freedom of expression and information.
  • Archiving for purposes in the public interest, scientific research, historical research, or statistical purposes.
  • Establishing, exercising, or defending legal claims.

4. Right to object.

At any time, you have the right to object to the processing of your personal data where there is a legal basis for doing so. When the objection is justified, the personal data of the respective individual cannot be processed further.

5. Right to restrict processing.

You can request the restriction of the processing of personalized data if:

  • You dispute the accuracy of the data for the period during which its accuracy is being verified; or
  • Processing the data is without legal basis, but instead of deletion, you want their restricted processing; or
  • We no longer need this data (for a specific purpose), but you need it to establish, exercise, or defend legal claims; or
  • You have objected to the data processing while waiting for the administrator to verify the legality of the grounds.

6. Right to data portability.

You can request us to provide the personal data you have entrusted to us in an organized, structured, commonly used, and machine-readable format to another controller if:

  • We process the data based on the contract and the consent declaration, which can be withdrawn, or based on contractual obligations, and
  • The processing is carried out automatically.

7. Right to withdraw consent.

You have the right, at any time, to withdraw your consent for the processing of personal data if the processing is based on your consent. Such withdrawal does not affect the lawfulness of the processing based on the consent before its withdrawal.

8. Right to fill a complaint.

If you believe that we are violating applicable regulations, please contact us to clarify the issue. Of course, you have the right to file a complaint with the Commission for Personal Data Protection or with the respective court following the Administrative Procedure Code. As of May 25, 2018, you can also file a complaint with the regulatory authority within the EU.

9. Right to obtain compensation.

According to Article 39, paragraph 2 of the Bulgarian Personal Data Protection Act and Article 82, paragraph 1 of Regulation (EU) 2016/679, anyone who has suffered damages as a result of a breach of the provisions of Regulation (EU) 2016/679 has the right to obtain compensation through a lawsuit before the competent judicial authority.

X. Exercising Your Rights

Requests to exercise your rights should be submitted to one of the following email addresses – [email protected] They should be signed with a Qualified Electronic Signature (QES) or by another method verifying indisputably the will of the person submitting the request. We respond to your request within one month of its submission. When an objectively necessary longer period is required, for instance, to collect all requested data or when it significantly hampers our operation, this period can be extended with up to 30 days. In our decision, we grant or refuse access and/or the requested information, always providing a reasoned response.

The minimum information contained in the request (according to Art. 37v of the Bulgarian Personal Data Protection Act) should be as follows: name, address, Personal Identification Number (EGN)/Foreigner's Personal Number (FPN)/passport number, a description of the request, signature, and date of submission, mailing address/email (depending on the preferred form of receiving information), power of attorney.

Concerning the aforementioned rights: to information, to correction, the "right to be forgotten," to object, to restriction of processing, to not be subject to a decision based solely on automated processing, to withdraw consent, to file a complaint, and in view of the actions of the administrator in connection with these rights, a specific register is created to record all actions carried out.

The initial provision of a response to a submitted request is free of charge. In cases of excessiveness (repetition - more than 2/ two/ requests of the same substance within a period of 12/ twelve/ months) or apparent lack of merit in the requests from the same subject, the Controller may request a reasonable fee for executing the request or refuse to take action on the request.

XI. Principles of Personal Data Processing, in accordance with Regulation (EU) 2016/679

  • "Lawfulness, fairness, and transparency" - Your data is processed in compliance with applicable legislation, fairly, and in a transparent manner towards the data subject.
  • "Limitation of purpose" - Your data is collected for specific, explicitly stated, and legitimate purposes and is not processed further in a manner incompatible with these purposes.
  • "Data minimization" - The types of data we collect are suitable, related, and limited to the necessary minimum in connection with the purposes for which the personal data is processed.
  • "Accuracy" - Accurate and, if necessary, to be kept up to date, taking all reasonable measures to ensure the timely deletion or correction of inaccurate personal data, considering the purposes for which they are processed.
  • "Limitation of storage" - Your data is stored in a form that allows the identification of the data subject for a period no longer than necessary for the purposes for which the personal data is processed.
  • "Integrity and confidentiality" - Processed in a way that ensures an appropriate level of security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using suitable technical or organizational measures.

XII. Definitions

  • "Personal data" - any information related to an identified or identifiable natural person.
  • "Data subject" - an individual who can be identified directly or indirectly, especially through an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • "Processing" - any operation or set of operations performed on personal data or sets of personal data, whether by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
  • "Restriction of processing" - marking stored personal data with the aim of limiting their processing in the future.
  • "Pseudonymization" - processing personal data in a way that the data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
  • "Controller" - a natural or legal individual, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
  • "Processor" - a natural or legal individual, public authority, agency, or other body which processes personal data on behalf of the controller.
  • "Log file" – a file containing system information about the operation of the Platform and information about user actions;
  • "Consent of the data subject" - any freely given, specific, informed, and unambiguous indication of the data subject's wishes, which, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to them.
  • "Profiling" - any form of automated processing of personal data consisting of using those data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning the performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.
  • "Automated decision-making" - the ability to make decisions using technological means without human intervention.
  • "Personal data breach" - a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data that is transmitted, stored, or otherwise processed.
  • "Recipient" - a natural or legal individual, public authority, agency, or another body to whom personal data are disclosed, whether a third party or not. Public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law are not considered recipients. The processing of such data by those public authorities complies with applicable data protection rules in line with the purposes of the processing.
  • "Third country" - any state that is not a member of the European Union or a party to the Agreement on the European Economic Area.

Cookie Policy

Information about the Personal Data Controller

"DANUBE COMMUNICATION" Ltd., UIC 208055812, with its registered office and management address in Republic of Bulgaria, city of Sofia, "Ekzarch Yosif" Str. No. 93, website: https://alain-soral.com/, e-mail: [email protected]

Is providing the information about the type, purpose, basis, and method by which personal data are collected, processed, stored, and disclosed.

Information about the Data Protection Officer

……………………………… e-mail: [email protected], number.: ………

Information about the Competent Supervisory Authority

  1. Name: Commission for Personal Data Protection
  2. Headquarters and Management Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
  3. Correspondence Information: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
  4. Phone: +359 02 915 3 518
  5. Email: [email protected], [email protected]
  6. Website: www.cpdp.bg

What personal data do we process?

The personal data that we process in connection with your visit and use of the functionalities of the website of "DANUBE COMMUNICATION" Ltd. – https://alain-soral.com/ are as follows:

  • Name;
  • Contact: E - mail;
  • IP adress.

Other data:

Cookies – You will find detailed information about them below.

Legal basis for processing personal data

The processing of your data, provided personally, is necessary for taking steps at the request of the data subject, through the completion of the contact form on our website - Article 6, paragraph 1, letter 'b' of Regulation (EU) 2016/679, when expressing a desire to receive promotional messages or other information from us, through subscription to a mailing list.

Purposes of processing personal data

The personal data provided by you will be used for the purposes of administering the submitted inquiry through the specified functionality of the website:

  • Inquiry or request contact form.
  • For the purposes of direct marketing.

Sharing of Рersonal data

"DANUBE COMMUNICATION" Ltd. respects and preserves the confidentiality of your personal data. In compliance with legal requirements, it is possible to disclose your personal data to the following entities:

  • Providing data to the system administrator, IT department, company employees.
  • Providing information to the Ministry of Interior and others;
  • Providing information to the Commission for Personal Data Protection in connection with obligations under the regulatory framework for personal data protection – the Personal Data Protection Act, Regulation (EU) 2016/679 of April 27, 2016, and others;

Cookies integrated into our website:

In order to provide personalized and relevant services through our website, "DANUBE COMMUNICATION" Ltd. needs technology for storing and retrieving information about their use by you. This is done through so-called cookies. They are small text files containing small amounts of information and are stored on your computer or in the memory of your web browser. Subsequently, it sends these cookies back to our website with each subsequent visit, helping the site recognize you and store information about your user preferences (visits, clicks, activity history). The use of collected cookies is very limited and is related to technical purposes – improving and personalizing the functionality of our website. The information collected through the use of cookies cannot be linked to a specific individual. More detailed information about cookies and their functionality can be found at https://www.aboutcookies.org/.

By visiting our site, you accept the use of cookies as described in this notice. However, you can control and manage cookies in various ways. Keep in mind, though, that removing or blocking cookies may affect your use of our website by limiting your access to certain features or parts of it.

Types of cookies we use

• Necessary cookies

These cookies enable the proper functioning of our website, allowing you to browse the information and use its features. For example, they display information on our site in the correct language.

• Functional cookies

These cookies allow us to tailor the operation of our site to the preferences of our visitors and users, enabling them to use its full functionality, watch videos, etc. This information is entirely anonymous, used for very limited purposes, and stored for a limited period.

• Analytical cookies

We use analytical tools that help us understand the traffic to our site, how easily our users interact with it, and what interests them in its content. The information collected through these cookies is used solely for statistical purposes and is not intended to be used for the personal identification of users. We do not receive any information about your personal data. These cookies show us which pages of our site you have viewed, whether you have visited our site on a mobile or desktop device, and other anonymous data. Analytical tools are provided by Google Analytics, and the information collected about your IP address is not linked to any other information stored by Google.

• Cookies for precise targeting

These cookies do not store personal information but contain only information about how you have used our site. They may be triggered by our advertising partners to show you only information that is relevant to you. Examples include cookies from Facebook, Google, LinkedIn, etc.

Cookie Management

You can control and manage cookies in various ways using your browser. Keep in mind that if you delete all cookies, the preferences you have saved will also be deleted. For more information on how to change your browser settings to block or filter cookies, visit https://www.aboutcookies.org or http://www.cookiecentral.com.

The cookies used when visiting the website of "DANUBE COMMUNICATION" Ltd. are:

To domain https://alain-soral.com/en

Next-Locale – deletes automatically after the session is over;

We use the following service providers, and you can learn more about their privacy policies and how to opt-out of their cookies by visiting their websites:

"DANUBE COMMUNICATION" Ltd. may, at its discretion, change and supplement the way cookies are used at any time. In the event of a change to these Terms, we will indicate the date of the change, and this change will apply to you and your data after the date of the change or any other explicitly specified later date.

Additional information about the settings for 'cookies' in your respective internet browser can be found here:

For what period do we store your personal data?

As a rule, "DANUBE COMMUNICATION" Ltd. generally suspends the full processing of your personal data for the enumerated purposes but does not delete them before the expiration of legally defined obligations for their storage. The data is retained for a period not longer than necessary and no more than 5 years. Please note that we will not delete or anonymize your personal data if they are required for ongoing judicial, administrative proceedings, or proceedings related to the review of your complaint.

Your rights regarding your personal data

In compliance with Bulgarian and European legislation, you have the following rights regarding your personal data processed by "DANUBE COMMUNICATION" Ltd.:

  • to access your personal data processed by "DANUBE COMMUNICATION" Ltd. and obtain a copy of them;
  • in case of incompleteness or inaccuracy of the data processed by "DANUBE COMMUNICATION" Ltd., to have your personal data corrected;
  • to request the deletion of your data when the conditions for this are met. Such cases include when: the purpose for which the data was collected has been achieved; you have withdrawn your consent when the processing is based on consent and there is no other legal basis for processing; your data is processed unlawfully, and others;
  • in certain cases defined by law, to request that the processing of your personal data be restricted;
  • in cases where your data is processed based on legitimate interests, you can object to the processing of your personal data on this basis;
  • to exercise your right to data portability and request that your data be provided in a structured, commonly used, and machine-readable format.
  • to withdraw your consent given when the processing of your personal data is based on consent.