Privacy & Cookies Policy — W.I.N. Project

This Privacy & Cookies Policy explains how the W.I.N. Project (coordinated by CUBU Foundation) collects, uses, stores, and protects personal data, and how it uses cookies on this website. It also explains your rights under the General Data Protection Regulation (EU) 2016/679 (GDPR) and relevant EU law.

1. Data controller

The data controller responsible for personal data collected via this website is:
W.I.N. Project, coordinated by CUBU Foundation (Bulgaria).
Contact details:
• Email: info@cubufoundation.com
• Postal address: Mladost 4, building 404, office 3, Sofia 1715, Bulgaria
If you have any questions about this policy or how your data is processed, please contact us.

2. Personal data we collect

We collect only the personal data that is necessary for specific purposes, including:
• Contact form data: name, email address, country, message text.
• Cookies / usage data: information about your visit (pages visited, time, device, IP address in anonymized form).
• Newsletter / updates (optional): email address (only if you opt in).

We do not collect sensitive personal data (such as race, religion, health data, etc.).

3. Legal basis for processing

We process your personal data based on one of the following legal grounds:
• Your consent (when you submit contact forms or subscribe to updates).
• Legitimate interest, for improving the website and user experience (aggregated analytics).
We do not use your data for profiling or automated decision-making.

4. How we use personal data

Your data may be used for:
• Responding to your messages or inquiries.
• Sending updates or newsletters (only if you consent).
• Improving the website and analyzing usage patterns (in anonymized or aggregated form).
• Complying with legal obligations.

We will never sell or share your private data with third parties for marketing.

5. Cookies and tracking technologies

We use cookies and similar technologies to improve website functionality and performance.
• Necessary cookies: required for basic website operations (e.g., navigation, security).
• Performance cookies: collect anonymized analytics (e.g., page views, time on site).
• Functional cookies: remember choices (e.g., language preferences).
• Optional cookies: only used if you consent (e.g., third-party widgets).

You will be asked to accept or decline cookies when you first visit the site. You can always manage your cookie preferences via your browser settings.

6. Sharing and third parties

We may share data with third parties only as required to operate the website and provide services (e.g., hosting provider, analytics). All third parties we work with are required to follow GDPR.
We do not sell your personal data.

7. Data storage and retention

Personal data is stored securely and retained only as long as necessary for the purpose it was collected.
• Contact form entries: up to 2 years.
• Newsletter opt-ins: until you unsubscribe.
• Log/analytics data: anonymized, retained as required for performance monitoring.

You can request deletion of your data at any time (see “Your rights” below).

8. Your rights under GDPR

Under GDPR, you have the right to:
• Access the personal data we hold about you.
• Rectify incorrect or incomplete data.
• Request erasure (right to be forgotten).
• Restrict or object to processing.
• Withdraw consent at any time (where processing is based on consent).
• Data portability (receive your data in a portable format).

To exercise your rights, contact us at winproject2025@gmail.com.

9. Security measures

We implement reasonable technical and organizational measures to protect your data from loss, unauthorized access, misuse, or alteration. However, no method of transmission over the internet is completely secure.

10. Children’s data

This website is not directed at children under 16. We do not knowingly collect data from individuals under 16. If you believe we have collected such data, please contact us to request removal.

11. Changes to this policy

We may update this policy from time to time. The “last updated” date will be clearly displayed at the top of the page. Significant changes will be communicated where appropriate.

Last updated: