I. Introduction
We at “WOMENO” JSC (hereinafter referred to as “Administrator,” “WOMENO,” or “Company”) are a personal data controller and operate in compliance with Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of personal data (General Data Protection Regulation) of individuals and its processing. This policy aims to inform you, as users of the website www.womeno.me (“Website”) and/or the mobile application “Womeno” (“Application”), collectively referred to as the “Platform,” about the collection, processing, and storage of your personal data, as well as the rights you have in this regard. The privacy policy may be updated in line with developments in data processing practices and our commitment to improving data protection.
“Personal data” means any information related to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity.
“Sensitive personal data” refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as processing of genetic data, biometric data for the purpose of uniquely identifying an individual, health data, or data concerning a person’s sex life or sexual orientation.
“Data subject” refers to a person identified by or identifiable through their personal data.
“Processing of personal data” means any operation or set of operations performed on personal data, including but not limited to collection, analysis, or destruction.
“Personal data controller” means a natural or legal person, public authority, agency, or other body that determines the purposes and means of processing personal data.
“Data processor” means a natural or legal person, public authority, agency, or other entity that processes personal data on behalf of the controller.
“Cookies” are small text files stored on your computer or mobile device when you visit a site or platform. They enable the Platform to remember your actions and preferences (such as language, font size, and display settings) over a period of time, eliminating the need to re-enter them upon each visit. We use the information collected from cookies to customize our Platform to your needs by making improvements. Cookies allow the Platform to function smoothly, monitor for irregularities and identify opportunities to optimize the ways in which it provides information and communicates with users.
“Third party” means a natural or legal person, public authority, agency or any other body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are entitled to process the personal data;
“Restriction of processing” means marking stored personal data to limit its future processing.
“Consent of the data subject” means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they signify agreement to the processing of their personal data.
“Personal data breach” means a security breach leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
We collect, process and store your personal data in order to:
All personal data we collect when you use the Platform is for the purpose of providing you with access to content that is personalized and limited to the criteria you set, providing you with full functionality to use the Platform. By using the Website and the App, you gain access to the Platform, which provides information, resources and services related to menopause, as well as the opportunity for online consultations with medical professionals and menopause experts. The medical professionals and menopause experts on the Platform communicate with you and provide remote medical evaluations, consultations, and personalized recommendations based on the information you voluntarily share about your health condition (the “Services”). The medical professionals and menopause experts on the App process your data following their knowledge and professional qualifications. They are data controllers in respect of the consultations and communications they carry out with users on the Platform insofar as they process the data on their own basis – a contract with the user for consultation/assessment, they determine the amount of data they process and how this happens. We are not responsible for the processing of your data by medical professionals and menopause experts, as they themselves determine what data to collect and how to process it when carrying out their activities.
Where you provide personal data and consent to it being used for marketing activity, we will process it in order to inform you about the receipt of newsletters and other promotional communications and to analyse your user behaviour through the use of cookies to provide you with information of interest to you. After subscribing to our newsletter, you will receive marketing messages. You may withdraw your consent to receive marketing communications at any time and we will immediately stop sending them to you. If you wish to withdraw your consent to receive our newsletter, you may do so in one of the following ways:
We adhere to the following principles related to the processing of personal data:
In order to provide you with effective access to the Platform, we collect, process, and store the following personal data:
To create a profile, you need to fill out a registration form by providing the above-mentioned data. Alternatively, you can log in using a social media account such as Google or Facebook.
In these cases, we collect and process your personal data based on the contractual relations established between you and Womeno – Regulation (EU) 2016/679, Article 6, Paragraph 1, Letter “b”.
In all cases, we do not have access to the email address or social media account data, as they are always stored in an encrypted format on our servers. In case of transfer the data will be encrypted.
In these cases, we collect and process your personal data based on the contractual relations established between you and Womeno – Regulation (EU) 2016/679, Article 6, Paragraph 1, Letter “b”.
When you provide information about your health conditions, symptoms, or menstrual cycle, you voluntarily share your personal data with us. In these cases, we collect and process your personal data based on consent – Regulation (EU) 2016/679, Article 6, Paragraph 1, Letter “a” and Article 9, Paragraph 2, Letter “a”.
The following rules apply to the data you provide:
We collect and process this data on a contractual basis – Regulation (EU) 2016/679, Article 6, Paragraph 1, Letter “b”.
We sometimes store small data files, called cookies, on your device to ensure that the Website functions properly. Most modern websites use this method as well. It is important for us that you understand what cookies we use and for what purposes. The cookies we use store information about accessibility settings, such as font size, color themes, and formatting styles.
The Website may use one or more of the following types of cookies, depending on its necessity:
1) System-Essential Cookies
These are cookies without which the functioning of the Website/Application would be impossible or significantly compromised. This category includes cookies for navigation, saving entered information when moving between steps, as well as login and registration functionalities. Also included are cookies that ensure connection security and protection against unauthorized external interference. This type of cookies is often classified as temporary or session cookies, as they are stored temporarily and disappear once the browser session is closed.
2) Functional Cookies
This category of cookies facilitates user experience on the Platform and adapts to individual user preferences. Functional cookies include cookies that recognize the device, save language preferences, font size settings, and more. These cookies may be stored on your device for a longer period and can be used across multiple browser sessions, which is why they are called persistent cookies.
3) Third-Party Cookies for Performance, Analytics, and Advertising
Analytics cookies are used to collect statistical information, based on which general conclusions and recommendations can be made regarding the effectiveness of the Platform, considering user goals as well as marketing and advertising purposes. Such statistics include the number of visitors to the Platform, the most visited pages, sources of visits, time spent on pages, errors encountered, and more. These cookies allow for the collection of anonymous information about how users navigate the Platform and any difficulties they may experience. For better accuracy, the Platform uses:
Google: The Platform utilizes Google’s Analytics service for analysis and statistics, including tracking visitors and determining how they use the Platform. These cookies help analyze the usability of the Platform and improve its functionality by considering visitors’ needs. The Platform also uses other Google-related cookies, such as those from YouTube.
More information about cookies set by Google can be found at:
https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
You can control and/or delete cookies at any time – for more details, visit aboutcookies.org. You can delete all cookies already stored on your computer, and you can also configure most browsers to block them. However, if you do so, you may need to manually adjust some settings each time you visit a website, and some services and features may not function properly in your internet browser.
Womeno collects and processes so-called “sensitive personal data”, including health-related data, based on consent as defined in Regulation (EU) 2016/679, Article 6, Paragraph 1, Letter “a”, and Article 9, Paragraph 2, Letter “a”.
The personal data we collect through the Platform is provided by the individuals to whom it pertains. We do not perform automated decision-making based on the personal data provided. Additionally, we do not collect or process personal data of individuals under the age of 18.
We have implemented all necessary administrative, technical, and physical measures to protect your personal data from loss, misuse, theft, unauthorized access, disclosure, alteration, or destruction. The platform uses encryption at rest as well as encryption in transit to prevent the possibility of data misuse by third parties. Each of our employees is trained and obligated to maintain the confidentiality of your information, as well as to implement the necessary organizational and technical measures, having access to your personal data in accordance with their duties.
All the suppliers and partners we currently work with have undergone thorough research and verification to ensure that they meet the security and data confidentiality requirements outlined in Regulation (EU) 679/2016. To maintain this level of security, such checks will also be carried out for all future suppliers with whom we will collaborate. In cases where we transfer, store, and process personal data outside the European Union and/or the European Economic Area (EEA), we have previously ensured that appropriate safeguards have been put in place to provide an adequate level of protection.
When working with companies outside the EEA, we ensure that they have provided us with a detailed explanation of the safeguards they implement to protect the personal data of their clients.
VII. Sharing of Personal Data
We may share information about you with:
VIII. Retention Period of Your Personal Data
Data provided when filling out the contact form, newsletter subscription, and the Questionnaire on the Platform, as well as communication records with medical specialists and menopause experts, are stored for 1 year to ensure security and facilitate future communication with the user, unless there is a legal basis for a longer retention period.
Your registration data for the Platform is stored as long as your profile remains active. If you choose to delete your profile, we will also delete the personal data you have provided.
If the retention period of your data needs to be extended due to legal obligations or our legitimate interests, we are required to notify you about the specific extension and the legal basis for it.
Your Rights Regarding the Collection, Processing, and Storage of Your Personal Data
Withdrawal of Consent for Data Processing
If you do not wish а part or all of your personal data to continue being processed by us for specific or all processing purposes, you have the right to withdraw your consent at any time by filling out a withdrawal of consent form or by submitting a free-text request.
Right of Access, Rectification, and Objection
You have the right to request and obtain access to your data, as well as information regarding its collection, processing, and storage by us.
You have the right to correct inaccurate or incomplete personal data directly through your Platform profile or by submitting a request to us.
If we process your personal data based on legitimate interest, you have the right to object to this processing at any time.
Right to Erasure (“Right to be Forgotten”) and Restriction of Processing
You have the right to request the deletion of part or all of your personal data, and we are obligated to comply without undue delay if any of the following conditions apply:
✔️ The personal data is processed in a manner different from the original purpose.
✔️ The personal data is no longer necessary for the purposes for which it was collected.
✔️ You withdraw your consent for processing, and there is no other legal basis for processing.
✔️ The personal data has been processed unlawfully.
✔️ You object to the processing of your personal data for services related to the information society.
✔️ The personal data is stored and processed for a longer period than legally permitted, and you have not given explicit consent for this.
You also have the right to request limited processing of your personal data for specific purposes.
Right to Data Portability
Under certain circumstances, you may have the right to receive your personal data, which you have provided to us, in a structured, machine-readable format.
Exercising Your Rights
To exercise any of the above rights, please contact us at info@womeno.me or at the address provided above.
We will respond to personal data-related requests within one month. If an extension is necessary, we will inform you of the delay and its reasons. We may refuse to process requests that are unjustifiably repetitive or threaten the privacy of other users.
We are not responsible for the content and security of third-party websites linked from our Platform. Clicking on such links and using those websites is entirely at your own risk and responsibility.
Right to File a Complaint with a Supervisory Authority
If you believe that your data protection rights have been violated, please contact us so we can attempt to resolve the issue.
You may also contact your local data protection authority to file a complaint.
In Bulgaria, this is the Commission for Personal Data Protection:
Address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Website: www.cpdp.bg
Email: kzld@cpdp.bg
Phone: +359 2 915 35 18
If we make changes to our Privacy Policy, we will publish the updated text here and indicate the date of the last revision. If the changes are significant and substantially alter our data protection practices, we will notify you through other means (e.g., email or a notice on our Platform and/or social media pages) before the changes take effect.
Last update of the Privacy Policy is from February 27, 2025
This Privacy Policy does not apply to third-party applications, products, services, websites, or social media features that may be accessed via links provided on the Platform for your convenience. We advise you to review the privacy policy of each website before allowing the collection of your personal data.
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