Last updated: 20 October 2026
1. Who is responsible for your data
This Privacy Policy explains how personal data is processed on haritaasumani.com (the “Website”), which presents the works of the artist Harita Asumani.
The Website is operated by, and the data controller is:
Think East Business Consulting OOD
EIK/BULSTAT: 205432368, VAT number: BG205432368
Vasil Levski 103, floor 13, apt. 96, Severen District, 4000 Plovdiv, Bulgaria
Email for privacy matters: hi@haritaasumani.com
In this policy, “we” and “us” refer to Think East Business Consulting OOD.
2. What data we process, why, and on what legal basis
2.1 Visiting the Website
When you visit the Website, your browser automatically sends technical data, such as your IP address, browser type and the page requested. Our hosting provider processes this data to deliver the Website and keep it secure.
Legal basis: our legitimate interest in operating a secure website (Art. 6(1)(f) GDPR).
2.2 Contact form
When you use the contact form, we process your name, email address, phone number (optional) and your message. We use this data to answer your message, including enquiries about artworks.
Legal basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR) and, for other messages, our legitimate interest in answering you (Art. 6(1)(f) GDPR).
2.3 Artwork enquiry forms
When you send an enquiry from an artwork page, we process your name, email address and the details you enter in the form. We use this data to answer your enquiry about that artwork.
Legal basis: steps taken at your request before entering into a contract (Art. 6(1)(b) GDPR).
2.4 Subscription to the pricelist and email updates
When you subscribe on the Connect page, we process your name, email address and your choice: to receive the pricelist of available works, email updates about Harita Asumani’s work, or both. We use this data to send you what you chose.
Legal basis: your consent (Art. 6(1)(a) GDPR). You can withdraw your consent at any time through the unsubscribe link in every email or by writing to hi@haritaasumani.com. Withdrawal does not affect processing carried out before it.
2.5 Analytics and advertising
With your consent, the Website uses:
- Google Analytics 4, to understand how visitors use the Website: pages visited, time on page, scrolling, form submissions and downloads.
- Meta Pixel, to measure the results of our ads on Facebook and Instagram, to show ads to people who visited the Website (retargeting) and to create custom audiences for advertising.
These tools store or read cookies and similar identifiers on your device and are used only after you accept them in the cookie settings. You can withdraw your consent at any time through the cookie settings on the Website.
Legal basis: your consent (Art. 6(1)(a) GDPR).
For the collection and transmission of data through the Meta Pixel, we and Meta Platforms Ireland Limited are joint controllers under Meta’s Controller Addendum. Meta is solely responsible for its further processing of the data, described in Meta’s privacy policy at facebook.com/privacy/policy.
2.6 Purchasing an artwork
When you buy an artwork, we process your name, email address, phone number, billing and delivery address, and the data needed for payment and invoicing. For bank transfers, this includes the payer’s name and account details shown on the transfer.
Signed prints are paid on a Revolut checkout page of Think East Business Consulting OOD, where you enter your delivery address and payment details. Payments are processed by Revolut Bank UAB, and we do not receive your full card details. Prints are shipped with DHL, UPS or DPD, depending on the destination.
We use this data to conclude and perform the sale, arrange delivery, issue the invoice and meet our accounting and tax obligations.
Legal basis: performance of the contract (Art. 6(1)(b) GDPR) and compliance with legal obligations (Art. 6(1)(c) GDPR).
Signed prints are sold by Think East Business Consulting OOD under our Terms of Sale. Original artworks are sold only by enquiry. Depending on the sale of an original, the seller is either Think East Business Consulting OOD or Harita Asumani personally. When the seller is Harita Asumani, she is the controller of your purchase data, and her details are provided to you before the sale is concluded.
2.7 Automated decisions
We do not make decisions based solely on automated processing that produce legal or similarly significant effects for you.
3. Who receives your data
We share your data only with the recipients below, and only as far as needed for the purposes in section 2.
| Recipient | Role | Data | Location |
|---|---|---|---|
| Coolice Host | Website hosting, database and email server | All Website and form data, emails | Bulgaria (EU) |
| Google (Gmail) | Mailbox that receives contact form messages | Contact form messages | EU and USA |
| Brevo | Sending the pricelist and email updates | Subscriber name, email, choice | France (EU) |
| Google Ireland Limited (Google Analytics 4) | Website analytics | Usage data, cookie identifiers | EU, with transfers to the USA |
| Meta Platforms Ireland Limited (Meta Pixel) | Joint controller for the collection of advertising data | Usage data, cookie identifiers | Ireland, with transfers to the USA |
| Revolut Bank UAB | Processing payments for signed prints | Payment data, delivery address | Lithuania (EU) |
| Banks | Processing bank transfers | Payment data | Depends on the bank |
| Courier companies (DHL, UPS, DPD) | Delivering artworks | Name, delivery address, phone | Depends on the courier |
| External accountant | Bookkeeping | Invoices and accounting records | Plovdiv, Bulgaria |
We also disclose data to public authorities when the law requires it.
4. Transfers outside the EU
Google and Meta may transfer data to Google LLC and Meta Platforms, Inc. in the USA. These transfers rely on the European Commission’s adequacy decision of 10 July 2023 for the EU-U.S. Data Privacy Framework.
5. How long we keep your data
| Data | Retention period |
|---|---|
| Contact form and artwork enquiry messages | 24 months from receipt |
| Subscriber data (Brevo) | Until you unsubscribe or withdraw your consent |
| Google Analytics 4 data | 14 months |
| Meta Pixel data | As set out in Meta’s privacy policy |
| Purchase and invoice data | As long as accounting and tax legislation requires |
| Technical data processed by the hosting provider | As long as needed for the security and operation of the Website |
6. Your rights
Under the GDPR, you have the right to:
- access the personal data we hold about you;
- have inaccurate data corrected;
- have your data erased;
- restrict the processing of your data;
- receive your data in a portable format;
- object to processing based on our legitimate interest, and to processing for direct marketing at any time;
- withdraw your consent at any time, without affecting processing carried out before the withdrawal.
To exercise your rights, write to hi@haritaasumani.com. We answer within one month of receiving your request.
7. Complaints
You can lodge a complaint with the Bulgarian Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria, www.cpdp.bg, or with the data protection authority of the EU country where you live or work.
8. Changes to this policy
We may update this Privacy Policy. The current version is always published on this page, with the date of the last update.