Privacy Policy (GDPR)

Effective date: 09 September 2025 Last updated: 09 September 2025

SpearX is a project of GEOCOM Co. LLC

This Privacy Policy describes how GEOCOM Co. LLC / www.spearx.eu hereinafter referred to as “Company”, “we”, “our” collects, uses and protects users’ personal data in accordance with the General Data Protection Regulation (GDPR) EU 2016/679.

1. Data Controller and Contacts

The data controller responsible for processing personal data on this website is:

GEOCOM Co. LLC

Address: 1000, Bulgaria, Sofia, Lege str., 6

EIK: 207002760 | VAT: BG207002760 | EORI: BGC207002760ZZZZ1

Email: info@spearx.eu

Data Protection Officer (DPO): Not appointed. For GDPR inquiries, please contact us at info@spearx.eu

2. Data We Collect

We may collect the following categories of personal data:

• Identification and contact details: name, email, phone number (if you submit forms).

• Interaction data: messages and requests submitted via contact forms.

• Technical and log data: IP address, browser type/version, device information, referrer URL, date/time of requests, log files.

• Cookies and similar technologies (see Section 7 below).

We do not intentionally collect special categories of personal data (Art. 9 GDPR) unless explicitly provided with your consent.

3. Purposes and Legal Basis

We process personal data for the following purposes:

• Purpose

• Examples

• Legal Basis (Art. 6 GDPR)

• Website operation and content delivery

• Page display, security, preventing misuse

• Legitimate interests (6(1)(f))

• Handling inquiries/requests

• Responding to your messages

• Contractual necessity (6(1)(b)) and/or Legitimate interests (6(1)(f))

• Subscriptions/newsletters (if applicable)

• Sending updates or news

• Consent (6(1)(a))

• Analytics and improvement

• Visitor statistics, UX improvements

• Consent (6(1)(a))

• Compliance with legal obligations

• Accounting, responding to authorities

• Legal obligation (6(1)(c))

4. Data Retention

• Contact form data: up to 24 months after request closure, unless longer required by law.

• Technical logs: typically up to 12 months, unless needed longer for security.

• Marketing subscriptions: until consent is withdrawn or up to 24 months of inactivity.

After retention periods, data is deleted or anonymized.

5. Sharing and International Transfers

We may share data with trusted service providers (processors) such as:

• Hosting and IT infrastructure providers

• Analytics tools (with your consent)

• Email marketing tools (if subscribed)

• Security and DDoS protection services

If data is transferred outside the EEA, we rely on GDPR safeguards such as EU Standard Contractual Clauses (SCCs) or adequacy decisions.

6. Your Rights

Under GDPR, you have the right to:

• Access your personal data (Art. 15)

• Rectify inaccurate data (Art. 16)

• Erase data (“right to be forgotten”, Art. 17)

• Restrict processing (Art. 18)

• Data portability (Art. 20)

• Object to processing (Art. 21)

• Withdraw consent at any time (where processing is based on consent)

To exercise your rights, please contact us at info@spearx.eu. We will respond within one month in accordance with GDPR.

7. Cookies and Tracking

We use cookies and similar technologies for functionality, security, and (with your consent) analytics.

Categories of cookies:

• Strictly necessary: essential for core site functionality and security (legitimate interests).

• Functional: remembering user settings such as language (consent).

• Analytics: visitor statistics and improvements (consent).

You can manage your preferences in the cookie banner or via browser settings.

8. Security Measures

We apply technical and organizational measures such as encryption (HTTPS/TLS), access controls, system logging, regular updates, and monitoring to protect personal data.

9. Children’s Data

This website is not intended for individuals under 16. We do not knowingly collect children’s data. If you believe we have collected such data, please contact us and we will delete it.

10. Changes to this Policy

We may update this Privacy Policy from time to time. The latest version will always be available at https://spearx.eu/privacy-policy. Significant changes will be highlighted.

11. Contacts and Supervisory Authority

For questions regarding this Privacy Policy or the processing of your data, please contact:

GEOCOM Co. LLC

Address: 1000, Bulgaria, Sofia, Lege str., 6

Email: info@spearx.eu

You also have the right to lodge a complaint with your local EU supervisory authority or with the Bulgarian authority:

Commission for Personal Data Protection (CPDP)

2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria

Website: https://www.cpdp.bg/