Privacy Policy

Last updated: 21 October 2026

I. Subject

This Privacy Policy / Personal Data Protection Policy (the “Personal Data Protection Policy”) explains how BETELGEUS Ltd. (the “Provider”, “Controller”, “we” and/or “us”), owner and operator of the website https://betelgeusrobotics.com/ (the “Website”), processes (including, but not limited to, collects and stores) the personal data of data subjects, such as users of the Website and of the Provider’s services (“User(s)”, “you”), and what rights they have in this regard.

The term “personal data” in this Policy has the meaning given to it in 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 (the “General Data Protection Regulation” or “GDPR”), namely: “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”

Below you will find brief information about:

• the Provider;
• the competent supervisory authority;
• the legal basis on which we process personal data;
• the purposes for which we use personal data;
• the principles of processing personal data;
• what personal data we collect;
• how long we keep personal data;
• access to and transfer of personal data; and
• the rights and safeguards that the GDPR gives data subjects.

II. Information about the Provider

1. Name: BETELGEUS Ltd., UIC 831617445
2. Registered office and address of management: 57-59 Vranya St., Sofia, Bulgaria
3. Address of operation: 16, Simeon Petrov Str., Industrial Area Bozhurishte, Bozhurishte 2227, Bulgaria
4. Email: sales@betelgeus.com
5. Registration in public registers: Commercial Register at the Registry Agency of the Ministry of Justice of the Republic of Bulgaria.

III. Information about the competent supervisory authority

1. Name: Commission for Personal Data Protection of the Republic of Bulgaria
2. Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
3. Phone: +359 2 915 3 518
4. Email: kzld@cpdp.bg
5. Website: https://www.cpdp.bg/

IV. Legal basis for collecting, processing and storing personal data

We process (including, but not limited to, collect and store) your personal data only in connection with our business and in accordance with applicable law, including the Personal Data Protection Act of the Republic of Bulgaria and the General Data Protection Regulation.

We process your personal data on at least one of the following grounds:

• the User’s consent to the processing of personal data;
• the processing is necessary for the performance of the Provider’s contractual obligations to the User;
• the processing is necessary in order to take steps at the User’s request prior to entering into a contract;
• the processing is necessary for compliance with the Provider’s legal obligations;
• the processing is necessary for the purposes of the Provider’s legitimate interests in carrying out its business.

V. Purposes of collecting, processing and storing personal data

We collect, process and store Users’ personal data in connection with the services we provide and with communication related to the use of the Website, as well as for the following purposes:

• communication and identification when performing a service contract or a sales contract (including when performing the respective contract);
• communication, identification, handling and fulfilment of enquiries, orders, requests, reservations, and purchases of goods or services (including preparation for concluding a contract, accepting orders, shipping goods, resolving issues related to cancelled orders or reservations, returns of purchased goods, refunds and others);
• fulfilment of tax and other legal obligations;
• accounting purposes in connection with the use of our services;
• protection of our legitimate interests in connection with our obligations to state and municipal authorities (for example, the National Revenue Agency and the Ministry of Interior);
• protection of our legitimate interests in storing information to defend against legal or tax claims and to improve the performance of the Website;
• protection of the information security of the Website;
• statistical information about the use of the Website;
• providing advertising content tailored to the User’s interests;
• sending email newsletters, and commercial and informational messages via push notifications.

If a data subject refuses to provide some or all of the personal data needed for a purpose listed above, we may not be able to provide the respective service (for example, to perform a contract concluded with that User) or to meet the respective legal requirements (for example, to enable the data subject to exercise their rights under the GDPR).

VI. Principles of collecting, processing and storing personal data

We follow these principles when collecting, processing and storing your personal data:

• lawfulness, fairness and transparency;
• purpose limitation;
• storage limitation, keeping data only as long as needed for the purposes for which it is processed;
• data minimisation;
• accuracy and keeping data up to date;
• integrity and confidentiality of processing, ensuring an appropriate level of security of personal data.

VII. Personal data

We collect the following categories of Users’ personal data, for the following purposes and on the following grounds:

• your identifying data (first and last name, phone number and email address), and other data you provide voluntarily, to handle your enquiries, send you service proposals and provide services at your request, including communicating with you about them; on the grounds of taking steps at your request before a possible contract, performing a contract to which you are a party, or your consent;
• your identifying data (first and last name, phone number and email address) and information about payments and chosen payment methods, to issue and send accounting/tax documents (invoices) for services you have used, including communicating with you about them; on the grounds of taking steps at your request before a possible contract, performing a contract to which you are a party, or complying with our legal obligation;
• your email address, to send you advertising and/or informational content, including news, newsletters, promotions, participation in loyalty programmes and activities, notices of improvements or changes to our services, and other advertising messages, at your request; on the grounds of your consent or our legitimate interest with respect to Users who are already our customers and/or partners;
• your IP address, browser settings and preferred language, the pages visited and actions taken, to send push notifications, if you have asked to receive them;
• your IP address and the pages visited, to protect information security;
• other data that may be needed in certain cases or in connection with providing services to Users, including data needed to perform contractual obligations (for example, date of birth, signature, personal identification number), or other data Users choose to share with us voluntarily; on the grounds of performing a contract to which you are a party, your consent, or complying with our legal obligation.

The Website uses “cookies”: small files downloaded to your computer to improve your experience as a user of the site. You can find more information on our dedicated Cookie Policy page.

We do not process, and therefore do not collect from Users, special categories of personal data (for example, data revealing racial or ethnic origin, political opinions, genetic or biometric data, or data concerning a person’s sex life or sexual orientation).

We do not make decisions based solely on automated processing, including profiling.

The Website and our services are not intended for persons under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have collected personal data of a person under 16 without the consent of a parent or legal guardian, we will delete it without undue delay.

We usually receive personal data directly from the data subject. However, we may also receive personal data from other persons, such as colleagues at the company where the data subject works, and from publicly available sources such as the Commercial Register and the Register of Non-Profit Legal Entities at the Registry Agency of the Ministry of Justice of the Republic of Bulgaria.

VIII. Retention period

We keep Users’ personal data for no longer than is needed for the respective purpose of processing or than the period set by law, where applicable. For example:

• personal data you provide when filling in the contact form will be kept until your request is fulfilled or your enquiry is answered, and for a maximum of one year after that for statistics and marketing analysis;
• personal data of our customers processed in connection with contracts between us and the respective User will be kept for no longer than ten years, starting from 1 January of the year following the year in which the contract was accounted for tax purposes;
• personal data of our customers processed in connection with issuing tax documents (invoices) will be kept for no longer than ten years, starting from 1 January of the year following the year in which the document was accounted for tax purposes;
• personal data of our partners/suppliers processed in connection with contracts between us and the respective partner/supplier will be kept for no longer than ten years, starting from 1 January of the year following the year in which the contract was accounted for tax purposes;
• personal data of candidates in recruitment and selection procedures will be kept for no longer than six months from the final completion of the procedure in which the data subject took part, or after the deadline for appealing that procedure has passed, unless the data subject has consented to longer storage; in that case the data subject may withdraw consent at any time without giving reasons.

The retention period also depends on the length of the legal relationship between us and the respective User and on the purposes for which the data is processed. Where there is an indication of a potential legal claim or liability, these periods will be extended accordingly. Where processing is based on the User’s consent (for example, personal data provided by third parties for direct marketing), we keep that data for as long as we have valid consent to process it.

After these periods expire, we take due care to delete and/or destroy your personal data without undue delay.

IX. Access to personal data and transfer to third parties

As a rule, the Users’ personal data we process is accessible to our employees, representatives and partners who need it to meet legal and/or contractual obligations (for example, to provide a service under a contract with a User). In this regard, at our discretion and in compliance with the GDPR, we may transfer all or part of your personal data to third parties such as: accountants and professional advisers, including lawyers (for the financial, accounting and administrative running of our business); cloud platforms for processing/storing data (for the organisational running of our business, for example storing and processing contracts with Users on cloud platforms for greater security); postal service companies (for example, sending paper contracts to Users); providers of IT services, system administration and marketing services (for a more reliable and better-performing Website and more secure data processing); and hosting providers (to perform contracts with Users).

Under applicable law or at the request of public authorities, all or part of your personal data may also be made available to public authorities.

We do not intend to transfer your personal data to countries outside the European Economic Area or to international organisations.

X. Rights of data subjects

At any time while we process your personal data, and subject to the limits set by applicable law, you as the data subject have the following rights:

• Right of access: you may ask whether we process your personal data and obtain access to and a copy of it; if you ask for more than one copy, you may be charged a fee for each additional copy.
• Right to rectification: you may ask for your personal data to be corrected if you believe it is inaccurate or incomplete. We will make such corrections without undue delay.
• Right to erasure (“right to be forgotten”): in certain circumstances (for example, the data is no longer needed for the purposes for which it was collected, or you have withdrawn consent and there is no other legal basis), you may ask for your personal data to be deleted from our records/database without undue delay. In certain cases we may refuse (for example, where processing is necessary to comply with a legal obligation or to establish, exercise or defend legal claims).
• Right to restriction of processing: where certain conditions are met (for example, processing is unlawful but you do not want the data deleted), you may ask us to restrict how your personal data is processed.
• Right to data portability: where you provided the data to us and it is processed by automated means, you may ask to receive it in a structured, commonly used and machine-readable format, and to have it transferred to another controller where technically feasible.
• Right to object: you may object at any time to the processing of your personal data for certain purposes, and we will stop using it for that purpose unless we have compelling legitimate grounds. In particular, you may object at any time to processing for direct marketing, and we will stop such processing without undue delay.
• Right not to be subject to automated decision-making, including profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, and all rights arising from it if you are subject to the legal effects of such processing.
• Right to withdraw consent: where we process your personal data based on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

If, at a User’s request, we delete their personal data from our database, we will keep only the information that may be needed to protect our legitimate interests or for public authorities.

You may ask us to tell you about all recipients to whom personal data subject to a request for rectification, erasure or restriction has been disclosed. We may refuse if this would be impossible or require disproportionate effort.

If we are asked to transfer personal data to another controller, to rectify, erase or restrict the processing of personal data, to stop processing, to provide information about recipients, or to give access to personal data, and we have doubts about the identity of the User making the request, we may first ask for additional information to confirm the data subject’s identity.

Where a third party to whom we have transferred all or part of your personal data (as described in Section IX) is involved in processing it, all the above requests will be forwarded to that third party.

Exercising these rights is free of charge, unless a request is manifestly unfounded or excessive. In that case we may charge a reasonable fee or refuse to act on the request.

Users can exercise these rights by contacting us by email at sales@betelgeus.com. We will respond to your request without undue delay and in any event within one month of receiving it. Where necessary, taking into account the complexity and number of requests, this period may be extended by a further two months, in which case we will inform you of the extension and the reasons for it within one month.

XI. Complaint to a supervisory authority

If you believe that your personal data is not processed lawfully or that any of your data protection rights has been infringed, you have the right to lodge a complaint with the competent supervisory authority listed in Section III above. You also have the right to seek protection of your rights in court.

Where the Website contains links to other websites, we recommend that you read their privacy policies carefully, because those websites may process your personal data when you visit them, and such processing is not covered by this Policy.

We reserve the right to amend this Personal Data Protection Policy at our discretion and whenever we see fit.