Privacy Policy

1. Data Controller

The controller of your personal data is:

HAMALIBG OOD
Company ID (EIK): 131372715
VAT number: BG131372715
Registered office: 6 Nerazdelni Str., 1164 Lozenets, Sofia, Bulgaria

For questions regarding personal data processing:
Email: office@hamali.bg
Contact: Ivaylo Todorov, Managing Director

We are not required to appoint a Data Protection Officer (DPO) under Article 37 GDPR, as we do not conduct large-scale processing of special categories of data.

2. Legal Basis for Processing

We process personal data in accordance with Regulation (EU) 2016/679 (GDPR), the Bulgarian Personal Data Protection Act, and applicable Bulgarian law. Specific legal bases for each activity are listed in Section 3 below.

3. What Data We Collect and Why

3.1. Price Calculator

When you use the calculator, we collect data without identifying you personally: moving type, city or addresses, cargo volume, additional services, notes.

Legal basis: Article 6(1)(b) GDPR — pre-contractual steps at your request.

Retention: This data is not retained if you do not submit an order.

3.2. Submitting an Order

When submitting an order we collect: first and last name, phone number, email address (optional), plus the calculator data.

Legal basis: Article 6(1)(b) GDPR — necessary for pre-contractual relations and a potential contract.

Retention: Up to 6 months after last communication if no contract is concluded. With a concluded contract — per accounting record-keeping requirements (10 years).

3.3. Cookies and Analytics

The site uses cookies for operation, analytics, and marketing. Details — in our Cookie Policy.

Legal basis: Necessary cookies — Article 6(1)(f) (legitimate interest). Analytics and marketing cookies — Article 6(1)(a) (your consent).

3.4. Email Correspondence

When you communicate with us via email, we retain the content of the correspondence.

Legal basis: Article 6(1)(b) GDPR.

4. How Partner Routing Works

Hamali.AI operates as a platform connecting customers with local partner moving companies. When you submit an order for a city served by a partner, your personal data is transferred to that partner company to fulfill the service.

Current partner companies:

• Hamali.BG (HAMALIBG OOD) — serves Sofia and surrounding areas
• Hamali Pernik — serves Pernik and surrounding areas
• Hamalite Pleven — serves Pleven and surrounding areas

We have a joint-controller or processor agreement with each partner company governing the protection of your data. When new partner companies are added, this policy will be updated.

5. Who We Share Your Data With

Your personal data is not sold and not shared for marketing purposes with third parties beyond those listed below.

Data may be shared with:

• Partner moving companies — upon order submission, to fulfill the service
• Make.com — an EU-based automation platform routing orders to the relevant partner. Acts as a data processor.
• Google Ireland Limited — for analytics via Google Analytics 4. Acts as a data processor.
• Google Maps (Google Ireland Limited) — for address/city search and autocomplete in the calculator. The service loads only when you start entering an address, and your IP address is transmitted to Google at that point. If you do not use address search, no connection to Google Maps is made.
• Meta Platforms Ireland Limited — for advertising and analytics via Meta Pixel. Acts as a joint controller under Meta's Controller Addendum.
• SuperHosting.BG — hosting provider. Acts as a data processor.
• Accountant / accounting firm — to fulfill statutory obligations
• Regulatory and law-enforcement authorities — under statutory obligation

6. Transfers Outside the EU

Some tools (Google Analytics, Google Maps, Meta Pixel) are provided by companies based in the EU but with US parent companies. Transfers to the US are based on:

• EU-US Data Privacy Framework — Google and Meta are certified participants
• Standard Contractual Clauses approved by the European Commission, as an additional safeguard

7. Your Rights

Under GDPR you have the following rights:

• Access — receive a copy of the data we hold
• Rectification of inaccurate data
• Erasure ("right to be forgotten")
• Restriction of processing
• Portability — data in machine-readable format
• Object to processing
• Withdraw consent at any time

To exercise your rights: office@hamali.bg. We respond within 30 days.

8. Right to Lodge a Complaint

Bulgarian Commission for Personal Data Protection (CPDP)
Address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia
Email: kzld@cpdp.bg
Website: www.cpdp.bg

9. Security

We apply technical and organizational measures to protect your data: encrypted connection (HTTPS), restricted access, agreements with processors. Transmission of information over the internet carries inherent risks for which we cannot be held responsible beyond our control.

10. Changes to This Policy

This policy may be updated periodically. Material changes will be announced on the site.