Privacy Policy

Personal Data Protection Policy when using the website and the internet resources of SAGES LTD

We at SAGES LTD (Value Sages /we) are aware of our responsibility to you – our clients, partners and those who use our website and internet resources, to provide you not only with quality services, but also to protect your information in the course of our relationship.

With this Personal Data Protection Policy, when using the website and the Internet resources of SAGES LTD (the Policy), we would like to inform you about how we process and protect your personal data when you use the information services and resources available on our website https://valuesages.com and https://app.valuesages.com (the Website) and on our corporate profiles in various social networks. Please read this Policy carefully to understand how we collect, store, and otherwise process your personal data in this context and what your rights in relation to this processing are.

This Policy also does not apply to the processing of personal data performed by various third parties to whose websites/platforms/applications, etc. you have been redirected from the Website. Such third parties should have their own privacy policies available on their websites/platforms/applications, etc., which we recommend that you read before using the respective service/resource.

I. Who are we?‍

We Sages Ltd. is a legal entity registered under Bulgarian law with Company ID No. 208161801 and registered address in Plovdiv, postal code 4001, Zapaden district, 4E Zname Street, entrance 2, floor 3, apartment 9.

As a personal data controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the Regulation/GDPR), we process your personal data in accordance with applicable law and the rules and principles set out in this Policy.

II. Persons whose data we process

In relation to the management and maintenance of our Website, the provision of information resources on it and on our corporate social media profiles, and the communication with anyone who comes into contact with us, we may process information about the following categories of individuals (Data Subjects/You):

• Visitors to the Website and users of information resources available on the Website;
• Persons who send us inquiries, requests, business proposals, signals, complaints or otherwise enter into correspondence with us, regardless of the communication channel used (mail, e-mail, telephone, etc.);
• Third parties whose information is contained in enquiries, requests, business proposals, signals, complaints, or other correspondence addressed to us, regardless of the communication channel used;
• Persons who have subscribed to receive certain communications sent by us (marketing messages, newsletters, etc.);
• Persons who interact with our corporate profiles/pages on various social networks.‍

III. Categories of personal data we process

1. Data related to correspondence or other types of interaction you have with us:

When you contact us with inquiries, requests or other communication, incl. via the contact form on the Website with us using the special form on the Website, as well as when you interact with our corporate profile or page in various social networks or thorough another communication channel (mail, e-mail, telephone, etc.), we may process the following types of personal data relating to you:

a) Data related to correspondence/ communication with us via the Website contact form, by e-mail, telephone, at our contact address, etc.

When you contact us, we may process the following types of data relating to you: name and surname; telephone; e-mail address; postal address, city/town; information on the way you have found about us and our services; unstructured information you provide in your message/inquiry; information about third parties contained in the messages/inquiries/ requests you have sent us; information contained in subsequent correspondence/ communication between you and Value Sages; data related to the receipt of initial and subsequent correspondence with us, such as time log (date/time) and source (IP address) of the respective correspondence, channel through which the correspondence was made, etc.; additional information collected or created in relation to the processing, status and final outcome of the relevant correspondence.

When the communication addressed to or made with us via the Website contact form, by e-mail or telephone, contains data and information about you and/or third parties which data and information are provided to us in the context of an inquiry for trust services and other services or other type of cooperation related to the professional activity of Value Sages, we will process such data in accordance with the rules and principles set out in this Policy.

b) Data related to any interaction on your part with our corporate profile or page in various social networks

In order to promote our activity and the services we provide, we may maintain corporate profiles/ pages in various social networks (such as Facebook, Twitter, LinkedIn, etc.). When you interact with our corporate profiles/ pages in such social networks (e.g., by liking, sharing or other forms of interaction with the content published by us – depending on the functionalities of the respective social network), we may receive information about you in accordance with your privacy settings in the respective social network, such as: names; username; information from your profile on the relevant social network (e.g., photo, gender, age or age range, language, country, list of friends, list of liked/ followed pages, etc.); other information you have given us access to and which the social network you use provides us with; information contained in and related to the initial and subsequent communication with us through the functionalities of the relevant social network.

The social networks referred to above are not maintained by us and the processing of personal data by them is not under our control. The persons maintaining the relevant social networks have different rules and procedures for the protection of your personal data, including the collection of information through tools such as cookies, therefore, we recommend that you carefully read their rules and policies.

c) Data related to receiving marketing messages, newsletters, etc. sent by us

When you subscribe to receive any type of communication/correspondence sent by us (e.g., marketing messages, newsletters, etc.), we will process the data provided by you in relation to this subscription. Such data may include: names; e-mail address; other data related to your occupation, profession or interests (if applicable); your preferences regarding the frequency of receiving the relevant communication and its content, etc. The specific types of data we may process in relation to sending such messages to you will always be clearly indicated in the relevant form through which you subscribe.

Newsletter and marketing messages subscription

Specifically, by filling in your email address in the relevant field in a registration form on our Website, or, respectively, by filling in your email address and ticking the box to agree to receive marketing messages, you grant your consent to us to send you our newsletter, or, respectively, marketing messages, including information and news about Value Sages services, to this email address. In this case, along with your email address information, we also keep information proving the fact that you have subscribed (log files – IP address and time at which the subscription statement was made). You can unsubscribe/terminate these subscriptions at any time via the relevant links in the messages we will send you or by contacting us. 

2. Data automatically collected or generated in relation to the use of the Website

Unless explicitly stated otherwise, access to the Website is free and no registration is required to use the information resources available on it. However, when you use the Website, certain information which is technologically necessary for its operation and which does not allow direct identification of the visitors, is automatically collected and processed. This information includes the following data: date and time of access to the Website; IP address from which the connection was made; server and system logs (to detect technical problems and/ or detect malicious activity); where applicable, logs for making legal statements (such as acknowledgement of having read a data protection policy, newsletter and/or marketing messages subscription, etc.).

In connection with the possibility to use the Website to log in and access by Users of Value Sages’s services, Value Sages also stores additional data necessary to ensure this access, such as access logs, logs of actions performed through the Website, encrypted forms of log-in credentials for the Website for the purpose of comparison with data entered by the User, and other necessary information.

‍3. “Cookies” and similar technologies

In relation to the management and maintenance of the Website, we may use cookies and other similar technologies, e.g., web beacons (beacons/ web bugs/ pixel tags/ clear GIF technologies) to ensure its reliable and efficient operation. You can find out more about the different types of cookies we use, as well as about your options for managing cookies by reading our Cookies Policy of Value Sages (Cookies Policy) published on the Website and accessible from the footer of each of its web pages. The Cookie Policy constitutes an integral part of this Policy, unless expressly stated otherwise.

IV. Voluntary/mandatory nature of the provision of personal data

Where we ask you to provide us with your personal data, for example, through the contact form on the Website, we clearly indicate the mandatory or voluntary nature of the provision of personal data relating to you. Providing your data is entirely at your discretion, but your refusal to provide data marked as mandatory may result, as the case may be, in us not being able to contact you (e.g. if we do not have contact details to send a response to), to process and respond adequately to your inquiry, etc. 

The data that is mandatory to provide for account creation is: Email address, Password (intended for account access), First and Last Name, Country of residence, and Date of Birth.

V. Purposes and legal grounds for processing personal data

Value Sages collects, stores, and processes the information described in item III above for the purposes set out in this Policy and in our General Terms and Conditions for the Use of Value Sages Website available [here]. Depending on the legal basis for processing, these purposes may be:
(1) Purposes necessary for compliance with legal obligations of Value Sages;
(2) Purposes related to steps taken by you before entering into a contract with you;
(3) Purposes related to the legitimate interests of Value Sages or of third parties;
(4) Purposes for which you have given your consent.

1. The purposes for processing personal data by Value Sages related to compliance with legal obligations include:

• Where applicable, carrying out activities to comply with legal obligations related to providing information to competent state and judicial authorities and to assisting inspections by competent authorities;
• Handling inquiries, requests, including the exercise of rights, etc., which are addressed to us, incl. the preparation of responses thereto;
• Where applicable, documenting electronic statements addressed to Value Sages and related to compliance with our legal obligations, such as acknowledgement of having read the privacy policies, cookie policy, etc.

For the purposes listed above, we may process some or all of the personal data referred to in items III, 1, ,2 and 3 of this Policy.

2. The purposes related to the steps you have taken before entering into a contract with you include: 

Initial review of inquiries for services and assistance, and contacting you (in case you are acting as an individual) in relation to the opportunity to provide you with the services you need, as well as in relation to the manner of proceeding the communication under your inquiry. Where such an inquiry is made on behalf of an entity, the processing of the data included in or relating to that inquiry constitutes our legitimate interest, namely to provide our services, and in those cases, we process that data on the basis of legitimate interest.

For the purposes listed above, we may process some or all of the personal data referred to in item III, 1 (a) and 2 of this Policy.

‍3. The purposes for processing personal data related to the legitimate interest of Value Sages to maintain and improve the quality of information services and resources provided on the Website, include:

• Administering, managing, and analyzing the effectiveness and quality control of the information services and resources available on the Website;
• Ensuring the normal functioning and use of the Website and the services and resources available on it;
• Performing activities for maintenance and administration of the Website, including, but not limited to, prevention of cyber-attacks and other malicious activities;

For the purposes listed above, we may process some or all of the personal data referred to in items III, 2, and 3 of this Policy.

4. The purposes for processing personal data related to the legitimate interest of Value Sages to communicate with you include:

• Providing an opportunity for correspondence/ communication with us (incl. the opportunity for online inquiries for services and assistance) through various channels;
• Providing an opportunity for interactions and communication with us through our corporate profiles/ pages in various social networks;
• Timely processing and providing a response to the initially received correspondence, as well as to the subsequent ones;
• Ensuring internal accountability, organizing the work, and distributing the correspondence to the relevant persons in charge at Value Sages.

For the purposes listed above, we may process some or all of the personal data referred to in item III, 1 (a), (b), and (c) of this Policy.

5. The purposes for processing personal data related to the legitimate interest of Value Sages and/ or third parties for the exercise and protection of legal rights and interests include:

• Exercise and protection of the legal rights and interests of Value Sages, incl. the establishment, exercise, or defence of legal claims, including in legal proceedings (e.g., by filing and defending against filed complaints, signals, etc., to the competent state and judicial authorities);
• Assisting in the exercise and protection of the legal rights and interests of third parties (Value Sages’s employees, visitors to the Website, processing personal data, etc.), including in legal proceedings;
• Carrying out activities for the administration and servicing of correspondence containing complaints, signals, etc.

For the purposes listed above, we may process some or all of the personal data referred to in items III, 1, 2, and 3 of this Policy.

6. The purposes for which personal data are processed on the basis of your consent include:

When we process your personal data on the basis of consent, the purposes for which we perform this processing are explicitly stated in the relevant forms by which you provide us with your consent for the respective processing (e.g., when subscribing to a newsletter, marketing messages, etc.). We will only process personal data which you have provided to us in the relevant consent form and only for the purposes specified in this form.  

VI. Categories of recipients of personal data

When we transfer your personal data to other persons, we do it in strict compliance with the terms of this Policy and our internal rules and policies, as well as in compliance with the requirements of the applicable personal data protection legislation. The categories of recipients we may transfer your personal data to, include:

Our subcontractors – Value Sages uses carefully selected partners, subcontractors, and service providers who may process your personal data on our behalf as processors. Such persons include persons providing services for the development and maintenance of the functionalities of the Website. We disclose data to our subcontractors only to the extent necessary for the performance of the work assigned, while our subcontractors are obliged under a contract concluded with us to process such data strictly in accordance with our instructions and only for the purposes specified in the relevant contract.

Our business partners and service providers – other personal data controllers (e.g. companies providing telecommunication, transportation or courier services, etc.), as well as persons whose cooperation is necessary for the purposes of implementing and protecting the legitimate interests of Value Sages or third parties (Website users, our employees and subcontractors or service providers, etc.) such as private and public bailiffs, notaries, etc. When dealing with such persons we require them to strictly comply with the applicable data protection laws and regulations.

The list of service providers we may transfer your personal data to, include (but might not be limited to):

• Cloud Infrastructure Providers: We use Amazon Web Services (AWS) to host our application, databases, and infrastructure. Our infrastructure is located within the EU (Frankfurt, Germany).
• Payment Processors: We use Stripe, Inc. to process your subscription payments. We do not store your full credit card details on our servers.
• Transactional Email Providers: We use SendGrid (a Twilio service) to send you service-related emails, such as account confirmation, password resets, and notifications.
• Analytics and Website Improvement Providers: We use Google Analytics and Microsoft Clarity to understand how visitors use our Website, so we can improve it. We only use these tools if you provide your consent via our cookie consent platform.
• Consent Management Platform: We use Clickio to manage your cookie and consent preferences.
• Financial Data Providers: Our financial data provider (EODHD) does not receive or process any of your personal data.
• Security and Fraud Prevention Providers: We use Google reCAPTCHA to protect our Website from spam and abuse. This service analyzes traffic (e.g., mouse movements, IP address, and device information) to distinguish between humans and bots.

Competent state, municipal, and judicial authorities, where necessary to comply with our legal obligation or to protect the rights or legitimate interests of Value Sages or third parties.

In other cases provided for by law.

VII. Transfer of personal data outside the European union (EU)/ European Economic Area (EEA)

Yes, in the course of our operations, your personal data may be transferred to and processed in countries outside the EU/EEA, primarily the United States.

This occurs when you use our service providers, such as our payment processor (Stripe), analytics providers (Google, Microsoft), security providers (Google reCAPTCHA), and email provider (SendGrid/Twilio), which are based in the United States.

We take all necessary measures to ensure your personal data is protected when transferred. We rely on legally-approved transfer mechanisms to do so. For transfers to the United States, we rely on the EU-U.S. Data Privacy Framework (DPF). Our key US-based service providers (Amazon Web Services, Stripe, Google, Microsoft, and Twilio/SendGrid) are certified under the DPF, which the European Commission has determined provides an adequate level of protection for your personal data. When providing personal data to third countries, Value Sages complies with the decisions taken by the European Commission pursuant to Article 45(3) of Regulation (EU) 2016/679.

VIII. Storage period of personal data

‍We undertake to store your personal data only for as long as it is necessary to achieve the purposes of processing.

1. Storage of personal data for compliance with legal obligations

Personal data relating to and/or contained in documents/ information carriers for which there are storage periods prescribed by law, will be stored for the periods provided for in the applicable legislation, unless this Policy provides for a longer storage period for the relevant documents/ information carriers.

2. Storage of personal data contained in correspondence/ communication with us

In the absence of a storage period prescribed by law, the personal data contained in correspondence with us (including, but not limited to, inquiries, requests, complaints, applications, and signals (including free text) and any other communication with us), incl. information on the processing, status and final outcome of this correspondence, will be stored for a period of up to 5 (five) years from the completion of the respective correspondence and the related relations.

3. Storage of server and system logs and logs for actions performed on the Website

We store server and system logs typically for a period of up to 1 (one) year.

Logs for statements of intent made on the Website, such as acknowledgement of having read and agreed to the Terms of Use of the Website and/or this Policy, are stored for a period of up to 5 (five) years after the completion of the relevant communication with us. Logs for activities carried out on the Website, such as giving consent, shall be stored for the periods specified in item 4 below.

‍4. Storage of personal data when processed on the basis of consent

When the processing of your personal data is based on consent that is not time-limited, we may continue to process your personal data for the purposes for which you have given us this consent until you withdraw it or until the final achievement of the purposes for which we process it. You may withdraw your consent at any time. When the consent you have given us for the processing of your personal data is time-limited, we will process the relevant personal data only for the period for which you have given us such consent.

5. Storage of cookies

For detailed information on the storage periods of the various cookies and similar technologies we use, you can refer to our Cookie Policy, published on the Website and accessible from the footer of each of its web pages. If certain information and/or certain documents or information carriers are required by law or other regulation to be stored for a longer period than the ones specified in items 1-6 above, the longer period prescribed by law shall apply to the storing such information. In case of a legal dispute or proceedings requiring the retention of data, and/ or in the case of a request from a competent public authority, it is possible to retain the data for a period longer than the ones specified above until the final settlement of the dispute or conclusion of the proceedings before all instances and for a period of up to 5 (five) years after its conclusion. The periods specified above may be amended if other requirements for retention of information are prescribed by the applicable legislation.

IX. Your rights

As a Data subject within the meaning of the Regulation, you have the following rights, which you can exercise by making a written request to Value Sages at the contact details specified in item I of this Policy:

Right of information

(Art.13 and Art. 14 GDPR)

You shall have the right to obtain information regarding the processing of your personal data by Value Sages. This Policy aims to inform you in detail about the processing of your personal data in relation to your use of the Website, as well as your communication with us.

‍Right of access

(Art. 15 GDPR)

You shall have the right to obtain confirmation as to whether your personal data are being processed by Value Sages when using the Website, to obtain access to such data, as well as information regarding their processing and your rights in relation to this processing.

‍Right of rectification

(Art. 16 GDPR)

You shall have the right to request rectification or completion of your personal data, if the data is inaccurate or incomplete.

‍Right of erasure

(Art. 17 GDPR)

If the grounds/conditions in the Regulation provided for this are available, you shall have the right to request erasure of your personal data.

‍Right of restriction of processing personal data

(Art. 18 GDPR)

The applicable legislation provides for a possibility to restrict the processing of your personal data, if the grounds provided for this in the Regulation are available.

‍Right of notification of third parties

(Art.19 GDPR)

Where applicable, you shall have the right to require Value Sages to notify the third parties to whom your personal data has been disclosed, of any rectification, erasure, or restriction of the processing of your personal data, unless this proves impossible or involves disproportionate effort on our part.

‍Right of data portability

(Art. 20 GDPR)

You shall have the right to receive the personal data, concerning you and provided by you, in a structured, commonly used, and machine-readable format and to transmit those data to another controller without hindrance on our part. The right of data portability is applied when the following two conditions are met simultaneously: the processing is based on consent or contract, and the processing is carried out by automated means.

Right to a complaint with a supervisory authority

(Art. 77 GDPR)

You shall have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data relating to you infringes the applicable legislation on personal data protection. The Supervisory Authority in the Republic of Bulgaria is the Commission for Personal Data Protection, with address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria.

Right to object

You shall have the right at any time and on grounds relating to your particular situation to object to the processing of your data processed on the basis of legitimate interest. In case such an objection is received, we shall consider your request and if it is reasonable, we will comply with it. If we believe there are compelling legal grounds for processing, or that it is necessary for the establishment, exercise, or defense of legal claims, we will inform you of that.

Cookie Policy

This Cookie Policy (the Policy) applies to the use of cookies and other similar technologies that enable the storage of information on your end device and access to it when you visit and navigate the website https://valuesages.com and https://app.valuesages.com (the Website). The Policy explains what cookies are and how they are used, and provides information about the types of cookies used on the Website, their functions, and how you can control their use.

Who are we?

The Website is administered and managed by "SAGES" Ltd., Company ID No. 208161801, with registered office and address of management: Plovdiv, 4001, Zapaden district, 4E Zname Street, entrance 2, floor 3, apartment 9, (the Company/SAGES/we), with email address: support@valuesages.com

What are cookies?

Cookies are small text files that are stored on your device (computer, smartphone, or other mobile device) when you visit various websites. Cookies allow the website to recognize your device and preferences and help improve your overall online experience.

Why do we use cookies?

We use cookies to improve navigation between the pages of our website and to track and analyze traffic.

Storing cookies

Cookies can be session cookies or persistent cookies. Session cookies are stored only for the duration of your visit to a website. Persistent cookies may remain stored on your device after the end of your visit and may be accessed each time you revisit the website.

Third-party cookies

The cookies we use may be third-party cookies that are not controlled by us. Such third-party cookies include cookies from Google Ireland Limited (Google) and Microsoft Corporation (Microsoft).

The Google cookies found on our website are related to the Google Analytics service. The Microsoft cookies are related to the Microsoft Clarity service. The information generated by such cookies may be transmitted and stored by Google and Microsoft on their servers, including in the United States. For more information on how these companies process information, please refer to their respective policies:

• Google: https://policies.google.com/technologies/cookies?hl=en
• Microsoft: https://privacy.microsoft.com/en-us/privacystatement

What cookies do we use? 

We use the following categories of cookies on our Website:

1. Strictly Necessary Cookies: These cookies are essential for the operation of our Website and service. They enable basic functions payment processing and managing your consent preferences. These cookies cannot be disabled.
   1. Examples: Cookies from our payment processor (Stripe) to facilitate checkout; the cookie from our consent platform (Clickio) that remembers your consent choices (__lxG__consent__v2_gdaisybit, __lxG__consent__v2_daisybit, __lxG__consent__v2); and cookies from Google reCAPTCHA (e.g., _GRECAPTCHA) which are necessary for the security and protection of the Website against bot attacks.
2. Performance & Analytics Cookies (Require Consent): These cookies allow us to analyze the use of the Website so that we can measure and improve its effectiveness. Thanks to them, we can understand which pages are most popular, see how visitors navigate the Website, and identify errors. All information collected by these cookies is aggregated. If you do not consent to these cookies, we will not be able to monitor the effectiveness of the Website.
   1. Examples:
      1. Google Analytics: _ga, _gat, _gid (used to collect statistical data).
      2. Microsoft Clarity: _clsk, _clck (used to capture user interactions and create heatmaps).

Control and deletion of cookies

Cookies that are Strictly Necessary for the functioning of the Website cannot be refused. By using the Website, you confirm that you are aware of the use of these cookies.

For all other cookies (such as Performance & Analytics), we ask for your explicit consent.

Our Site uses a consent management platform (Clickio) to manage your preferences. When you first visit our Site, you will be shown a cookie consent banner. Non-essential cookies (like Google Analytics and Microsoft Clarity) are not loaded unless and until you provide your active, affirmative consent by clicking "Accept" (or an equivalent). You can also reject these cookies or manage your preferences in more detail.

You may withdraw your consent or change your preferences at any time by accessing the consent management settings (e.g., via a "Privacy and cookie Settings" button in the footer of our Website).

You can also set your browser to not accept cookies and use its features to delete cookies. To find out how to do this, visit https://www.allaboutcookies.org.

Your rights

You have the right to request additional information about the cookies we use at any time by writing to us at the address indicated above in this Policy or at the email address contact@valuesages.com. Additional information about your rights in relation to the processing of information stored on your device, such as cookies and other similar technologies, can be found in our Privacy Policy for the use of the Website, published on the Website.

Changes to the Cookie Policy

Any future changes to our Cookie Policy will be posted on the Website. If necessary, we will notify you of any changes to the Cookie Policy and in other ways in accordance with the Terms of Use of the Website of SAGES Ltd. published on it. All changes take effect immediately, except where otherwise stated.