Version: 1.0 / Effective date: 01.06.2026

1. Introduction

This Cookie Policy (the “Policy”) applies to the website [www.blendedleading.com] and its subdomains (the “Site”), operated by “Lean Digital Solutions” EOOD, with registered office and address of management: city of Sofia, postal code 1303, Vazrazhdane district, 12 Chiprovtsi Str., floor 2, UIC 202204879 (“Blended Leading”, “we”, “us”).

This Policy is drafted in accordance with:

  • Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”);
  • Directive 2002/58/EC (ePrivacy Directive) and its national transposition in the Bulgarian Electronic Communications Act;
  • the Bulgarian Personal Data Protection Act;
  • EDPB Guidelines 03/2022 on deceptive design patterns in social media platform interfaces (“dark patterns”);
  • EDPB Guidelines 05/2020 on consent under the GDPR.

This Cookie Policy describes which cookies and similar technologies we use on our website, why we use them, how you can manage your preferences, and what happens to your data. This Policy should be read together with our Website Privacy Policy, which describes the general principles for processing personal data.

2. What cookies and similar technologies are

2.1 Cookies

Cookies are small text files placed by a website on your device (computer, tablet, phone) when you visit it. They contain information that allows the Site to recognise you on subsequent visits, remember your preferences, and provide you with improved functionality and user experience.

2.2 Types of cookies by origin

  • First-party cookies: placed directly by the Site you are visiting.
  • Third-party cookies: placed by external providers (e.g. Google, LinkedIn, Meta) whose services the Site uses.

2.3 Types of cookies by duration

  • Session cookies: exist only for the duration of your session and are automatically deleted when you close the browser.
  • Persistent cookies: remain on your device for a defined period (from a few minutes to several years), unless you delete them manually.

2.4 Similar technologies

Apart from classical cookies, we may use the following technologies which perform a similar function and are subject to the same consent rules:

  • Local Storage / Session Storage: data storage in the browser without an expiry date (Local) or until closure (Session).
  • Pixel tags / Web beacons: small invisible images that allow tracking of email opens or page visits.
  • Tag Managers: tools (e.g. Google Tag Manager) that manage the loading of scripts and pixels.
  • Device fingerprinting: techniques to identify a device based on technical parameters (we do not use fingerprinting for advertising purposes).

For the sake of brevity, in this Policy all such technologies are collectively referred to as “cookies”.

3. Categories of cookies and legal bases

We classify cookies into four main categories, in line with the internationally accepted classification:

3.1 Strictly necessary cookies

These cookies are necessary for the basic functioning of the Site and cannot be disabled. They are usually set in response to your actions (e.g. entering data, requesting a service, navigating the Site). They also ensure the security of the Site (bot protection, load balancing).

  • Legal basis: Art. 6(1)(f) GDPR (legitimate interest) and the exemption under Art. 5(3), second sentence of the ePrivacy Directive – no consent required.

3.2 Functional cookies (preferences)

These cookies enable the Site to remember choices you make (e.g. language, region, font size, recently viewed products/articles) and provide you with a personalised experience, without tracking your behaviour outside the Site.

  • Legal basis: Art. 6(1)(a) GDPR – your consent.

3.3 Analytics cookies (statistical)

These cookies help us understand how visitors use the Site – which pages are most visited, where users come from, how long they spend on each page. This allows us to improve content and functionality.

  • Legal basis: Art. 6(1)(a) GDPR – your consent. (Exception: where analytics is performed strictly first-party, aggregated and without cross-site tracking, some supervisory authorities allow “legitimate interest”; in our case we use consent to ensure maximum protection.)

3.4 Marketing / advertising cookies

These cookies are used to build a user profile, display relevant advertisements on our Site and on third-party sites (remarketing/retargeting), and measure the effectiveness of our marketing campaigns. They are usually set by third parties (advertising networks).

  • Legal basis: Art. 6(1)(a) GDPR – your explicit, granular consent (separate for each purpose/category).

Cookies in categories 3.2 – 3.4 are NOT loaded onto your device before you have given explicit consent through our cookie banner.

4. List of specific cookies we use

Below is a detailed list of the cookies we use on the Site, broken down by category. The list is updated periodically when new tools are added or existing ones change. Exact expiry periods and identifiers can be viewed at any time through our Cookie Management Platform / Cookie Settings in the footer of the Site.

4.1 Strictly necessary cookies

Cookie name
Provider / Domain
Purpose
Type
Duration
1st/3rd party

4.3 Analytics cookies

Cookie name
Provider / Domain
Purpose
Type
Duration
1st/3rd party

4.4 Marketing / advertising cookies

Cookie name
Provider / Domain
Purpose
Type
Duration
1st/3rd party

5. How to manage your cookie preferences

5.1 Through our cookie banner

On your first visit to the Site, we display a cookie banner that provides you with the following options:

  • “Accept all”: activates all cookie categories (including analytics and marketing).
  • “Reject all”: activates only strictly necessary cookies. This button is of the same size, visibility and prominence as the “Accept all” button.
  • “Customise”: allows you to choose granularly which cookie categories to activate (except for strictly necessary cookies, which are always active).

You may change your choice at any time through the “Cookie Settings” link, which is always available in the footer of the Site. Withdrawing consent is as easy as giving it.

5.2 Through your browser settings

Apart from our banner, you can also manage or block cookies through your browser settings. Please note that disabling strictly necessary cookies may impair the functioning of the Site.

6. What happens if you refuse cookies

Refusing cookies does NOT deny you access to the Site or its core functionalities. You can browse content, fill in contact forms and request a demo without accepting analytics or marketing cookies.

Possible consequences of refusal:

  • you will not see personalised ads from us on third-party sites;
  • you may see the same ad more often, as we will not be able to limit its frequency;
  • we will not be able to accurately measure the effectiveness of our campaigns;
  • certain functionalities (e.g. embedded videos or interactive calendar) may require confirmation before loading.

WE DO NOT USE so-called “cookie walls” – we do not block your access to the Site if you refuse cookies.

7. International transfers and providers outside EU/EEA

Some cookie providers listed in Section 4 may process data outside the European Union / European Economic Area (e.g. in the United States). Such transfers are subject to appropriate safeguards under Chapter V of the GDPR:

  • Adequacy decision: for transfers to the USA – via certification under the EU-U.S. Data Privacy Framework (Implementing Decision (EU) 2023/1795 of 10 July 2023). Google, Meta and LinkedIn are DPF-certified.
  • Standard Contractual Clauses (SCCs): where an adequacy decision is not applicable, we use SCCs under Decision (EU) 2021/914.
  • Supplementary measures: encryption, pseudonymisation, contractual restrictions on third-party access.

You may obtain additional information and a copy of the applicable safeguards by contacting us using the details in Section 11.

8. What data is collected through cookies

Through cookies, the following data may be collected (depending on the category and provider):

  • IP address and approximate geolocation;
  • device type, operating system, browser version;
  • pages visited, time spent, navigation flow;
  • traffic source (where you came from – Google, LinkedIn, direct etc.);
  • clicks, scrolls, form completions;
  • unique browser/device identifier;
  • language and regional preferences;
  • possible user identifier if you have identified yourself in a third-party tool (e.g. LinkedIn).

Such data may qualify as personal data within the meaning of the GDPR. Their processing is carried out in accordance with our Website Privacy Policy.

9. Your rights

In relation to personal data collected through cookies, you have all rights guaranteed by the GDPR:

  • right to information and access (Arts. 13–15);
  • right to rectification (Art. 16);
  • right to erasure (Art. 17);
  • right to restriction (Art. 18);
  • right to data portability (Art. 20);
  • right to object (Art. 21);
  • right to withdraw consent (Art. 7(3));
  • right to lodge a complaint with the Bulgarian Commission for Personal Data Protection (Art. 77) – www.cpdp.bg.

To exercise your rights, contact us using the details in Section 11. Detailed information on procedures and conditions is available in our Website Privacy Policy.

10. Changes to the Policy

We reserve the right to amend this Policy to reflect changes in legislation, our practices, or the tools used. The list of cookies is updated periodically. The current version is at all times available on the Site.

For material changes (e.g. addition of a new cookie category or new provider involving international transfers), we will request a new consent through the banner and/or notify you through a prominent notice on the Site.

11. Contact details

For questions about cookies or to exercise your rights, please contact us:

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Controller

"Lean Digital Solutions" EOOD

Address

city of Sofia, postal code 1303, Vazrazhdane district, 12 Chiprovtsi Str., floor 2

UIC

202204879

Privacy email

dpo@leandigitalsolutions.com

DPO

Kamen Kanev

Supervisory authority

Bulgarian Commission for Personal Data Protection (CPDP) 

www.cpdp.bg | kzld@cpdp.bg