PRIVACY POLICY

Effective date: 18 October 2026
Last updated: 18 October 2026

This Privacy Policy explains how BETTER HEALTHY LIFE Ltd. (“Better Healthy Life”, “BHL”, “we”, “us”, or “our”) collects, uses, stores, shares, and protects personal data when you visit betterhealthylife.eu, create an account, purchase or use a Membership, contact us, or otherwise interact with our services.

This Privacy Policy should be read together with our Terms and Conditions and Cookie Policy.

We process personal data in accordance with Regulation (EU) 2016/679 (“GDPR”), the applicable Bulgarian data-protection legislation, and other privacy laws that apply to our activities.

I. DATA CONTROLLER

The data controller is:

BETTER HEALTHY LIFE Ltd.
UIC: 207335971

Registered office and management address:
Republic of Bulgaria
1592 Sofia
Iskar District
Druzhba Residential Complex
Block 168
Entrance A
Floor 4
Apartment 12

Email: [email protected]
Telephone: +359 888 889 164

For questions concerning this Privacy Policy or the processing of your personal data, you may contact us using the details above.

II. WHO THIS POLICY APPLIES TO

This Privacy Policy applies to personal data relating to:

• visitors to betterhealthylife.eu;
• registered Users;
• Members;
• customers and prospective customers;
• people who contact us;
• newsletter subscribers;
• persons who interact with our checkout, payment, account, security, or support systems.

Better Healthy Life Membership is intended for persons aged 18 years or older.

We do not knowingly offer Membership accounts to children under 18.

If we become aware that personal data has been collected from a person under 18 in circumstances where it should not have been collected, we will take appropriate steps in accordance with applicable law.

III. PRINCIPLES OF DATA PROCESSING

When processing personal data, Better Healthy Life follows the principles required by applicable data-protection law, including:

• lawfulness, fairness, and transparency;
• purpose limitation;
• data minimization;
• accuracy;
• storage limitation;
• integrity and confidentiality;
• accountability;
• data protection by design and by default.

We collect and process only personal data that is reasonably necessary for legitimate and disclosed purposes.

IV. CATEGORIES OF PERSONAL DATA WE MAY PROCESS

Depending on how you use the Website and our services, we may process the following categories of information.

1. Account and Identity Information

This may include:

• first and last name;
• username;
• email address;
• telephone number;
• billing address;
• country or region;
• Account identifiers;
• Account status;
• Membership status.

2. Order and Membership Information

This may include:

• Membership plan selected;
• Order number;
• subscription or Membership identifier;
• start date;
• trial status;
• Billing Period;
• renewal information;
• cancellation status;
• payment status;
• transaction reference;
• access status.

3. Payment and Transaction Information

Payments may be processed by third-party Payment Providers such as Stripe and PayPal.

Better Healthy Life may receive information such as:

• payment status;
• transaction identifier;
• payment amount;
• payment currency;
• date and time of payment;
• payment method type;
• limited payment-method details such as card brand and last digits, where supplied by the Payment Provider;
• refund or chargeback status.

Better Healthy Life does not intend to store complete credit or debit card numbers, card security codes, or complete PayPal credentials.

Payment Providers process payment information under their own legal and technical arrangements and may process additional information required to provide payment, fraud-prevention, regulatory, and financial services.

4. Communications and Support Information

When you contact us, we may process:

• your name;
• email address;
• Account or Order information;
• the content of your message;
• attachments or other information you choose to provide;
• records of our response.

5. Device, Technical, and Security Information

We may process technical information such as:

• IP address;
• browser type;
• operating system;
• device type;
• device or session identifiers;
• login time;
• logout time;
• failed login attempts;
• Account activity;
• security events;
• page requests;
• referral information;
• fraud or abuse indicators.

This information may be used to secure the Website, protect Member Accounts, prevent unauthorized Account sharing, detect fraud, enforce reasonable access controls, investigate security incidents, and maintain the reliability of the service.

6. Website Usage Information

Depending on your cookie choices and the technologies enabled on the Website, we may process information concerning:

• pages viewed;
• navigation through the Website;
• interactions with Website features;
• session information;
• traffic source;
• approximate technical location derived from IP address;
• analytics information.

Further information is provided in our Cookie Policy.

7. Consent and Compliance Records

Where necessary, we may keep records demonstrating:

• acceptance of Terms and Conditions;
• cookie preferences;
• marketing consent;
• withdrawal of consent;
• statutory withdrawal requests;
• immediate digital-access requests or acknowledgements;
• other legally relevant choices or confirmations.

These records may be necessary to demonstrate compliance with legal and contractual obligations.

V. SPECIAL CATEGORIES OF PERSONAL DATA

Better Healthy Life does not normally request or require special categories of personal data such as medical or health records, racial or ethnic origin, religious beliefs, political opinions, biometric identification data, or information concerning a person’s sex life or sexual orientation.

Our fitness content is not a medical service.

Please avoid sending medical records or detailed health information through ordinary contact forms or support messages unless there is a legitimate reason to do so.

If a User voluntarily provides special-category information, we will process it only where an appropriate legal basis exists and only to the extent reasonably necessary.

VI. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA

We may process personal data for the following purposes:

• creating and managing User Accounts;
• processing Orders;
• creating and administering Memberships;
• providing Membership access;
• managing free trials;
• processing and confirming payments;
• managing renewals and cancellations;
• providing customer support;
• handling refund, withdrawal, and complaint requests;
• maintaining records required for accounting, taxation, and legal compliance;
• preventing fraud and payment abuse;
• preventing unauthorized Account sharing;
• securing the Website and Member Accounts;
• investigating security incidents;
• maintaining service functionality;
• improving Website performance and usability;
• analyzing service usage where permitted;
• managing cookie preferences;
• sending transactional communications;
• sending marketing communications where legally permitted;
• establishing, exercising, or defending legal claims;
• complying with lawful requests from competent authorities.

VII. LEGAL BASES FOR PROCESSING

We do not rely on one single legal basis for all processing.

Depending on the purpose, we may rely on one or more of the following legal bases.

1. Performance of a Contract

We process information where necessary to:

• create or administer your Account;
• process an Order;
• activate or provide a Membership;
• manage Membership access;
• process contractual communications;
• administer renewals or cancellations;
• provide customer support connected with the contract.

This processing is based on Article 6(1)(b) GDPR where applicable.

2. Compliance with Legal Obligations

We may process information where necessary to comply with obligations relating to:

• accounting;
• taxation;
• consumer protection;
• fraud prevention;
• financial records;
• regulatory obligations;
• court orders;
• lawful requests by competent authorities.

This processing is based on Article 6(1)(c) GDPR where applicable.

3. Legitimate Interests

We may process information where necessary for legitimate interests such as:

• Website and Account security;
• prevention of fraud and abuse;
• prevention of unauthorized Account sharing;
• defending legal claims;
• maintaining and improving our services;
• administrative record keeping;
• understanding service performance;
• protecting our intellectual property.

We rely on legitimate interests only where those interests are not overridden by the rights and freedoms of the individual.

This processing is based on Article 6(1)(f) GDPR where applicable.

4. Consent

We rely on consent where consent is the appropriate legal basis, including where required for:

• certain non-essential cookies;
• certain analytics or marketing technologies;
• direct marketing where consent is legally required;
• other optional processing activities.

Consent is voluntary and may be withdrawn at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Acceptance of our Terms and Conditions does not constitute blanket consent to all processing of personal data.

VIII. PAYMENTS — STRIPE AND PAYPAL

Better Healthy Life uses third-party Payment Providers to process payments.

Stripe

Where Stripe is available as a Payment Provider, information may be transmitted to Stripe for purposes including:

• payment processing;
• payment authentication;
• fraud prevention;
• transaction management;
• refunds;
• disputes;
• recurring payments where applicable;
• regulatory compliance.

Depending on the particular processing activity, Stripe may act as a data processor on behalf of Better Healthy Life and/or as an independent data controller for certain Stripe services and regulatory purposes.

PayPal

Where PayPal is selected as a Payment Provider, information necessary to process the transaction may be transmitted to PayPal.

PayPal may process personal information for purposes including:

• payment processing;
• account and transaction management;
• fraud prevention;
• security;
• dispute handling;
• regulatory and legal compliance.

PayPal processes certain information under its own Privacy Statement and applicable legal obligations.

Better Healthy Life does not control all processing independently carried out by Stripe or PayPal.

Users should review the privacy information provided by the Payment Provider they choose.

IX. GOOGLE reCAPTCHA AND FRAUD PREVENTION

Better Healthy Life uses Google reCAPTCHA in connection with certain payment and security functions, including PayPal fraud-protection measures.

reCAPTCHA may process technical and interaction information in order to assess whether activity appears legitimate, automated, fraudulent, or abusive.

Information processed may include technical identifiers, device and browser information, IP-related information, interaction signals, and security-related data.

Better Healthy Life uses this processing for the purposes of:

• fraud prevention;
• abuse prevention;
• payment security;
• protecting Accounts;
• protecting the Website.

For reCAPTCHA Customer Data, Better Healthy Life acts as the data controller and Google processes relevant Customer Data as a processor in accordance with the applicable Google Cloud contractual and data-processing terms.

X. SECURITY AND ACTIVITY LOGGING

For security and administrative accountability, Better Healthy Life may maintain logs concerning:

• successful logins;
• failed login attempts;
• logout events;
• administrative changes;
• changes to User roles;
• changes to Website content;
• plugin or system events;
• security-related events.

These records may be used to:

• investigate unauthorized access;
• identify suspicious activity;
• protect User Accounts;
• maintain an audit trail;
• diagnose technical issues;
• protect the Website.

Access to administrative logs is restricted to authorized persons.

XI. COOKIES AND SIMILAR TECHNOLOGIES

The Website uses cookies and similar technologies.

Some cookies are necessary for:

• Website functionality;
• security;
• Account login;
• checkout;
• payment functionality;
• fraud prevention;
• remembering privacy choices.

Other cookies or technologies may be used for analytics, measurement, or other optional purposes where legally permitted.

Where prior consent is required, non-essential cookies will not be activated until the User has made the required choice.

The User can manage applicable cookie preferences through the Website’s cookie controls.

Further information is provided in the Cookie Policy.

XII. ANALYTICS

Better Healthy Life may use analytics services to understand how the Website is used and to improve performance, content, and User experience.

Where Google Analytics or another analytics service is enabled, its use will be subject to the applicable cookie and privacy requirements.

Analytics technologies requiring consent will be used only after the required consent has been obtained.

Information about active analytics cookies and providers should also be available through the Website’s Cookie Policy or cookie-preference interface.

XIII. MARKETING COMMUNICATIONS

Better Healthy Life may send newsletters, offers, or promotional communications where permitted by applicable law.

Where consent is required, marketing communications will be sent only after the appropriate consent has been obtained.

Marketing consent is separate from the creation or use of a Membership Account.

A User may unsubscribe from marketing communications at any time by:

• using the unsubscribe option included in the relevant communication; or
• contacting [email protected].

Unsubscribing from marketing communications does not prevent us from sending necessary transactional or service communications, such as payment confirmations, Account security notices, or Membership-related contractual information.

XIV. RECIPIENTS AND SERVICE PROVIDERS

We may disclose personal data where reasonably necessary to trusted recipients and service providers, including:

• payment processors such as Stripe and PayPal;
• website hosting providers;
• cloud and infrastructure providers;
• security and fraud-prevention providers;
• Google in connection with reCAPTCHA;
• email and transactional communication providers;
• analytics providers where enabled;
• technical support providers;
• professional advisers such as accountants, lawyers, or auditors;
• competent authorities where disclosure is required by law.

Service providers that process information on our behalf are required to process data under appropriate contractual and security arrangements where required by law.

We do not disclose personal data to third parties merely because they wish to advertise to our Users.

We do not sell personal data for monetary compensation.

XV. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Some service providers used by Better Healthy Life may process personal data outside Bulgaria or outside the European Economic Area.

Where personal data is transferred to a country outside the EEA, we will rely on an appropriate transfer mechanism where required, such as:

• an adequacy decision of the European Commission;
• Standard Contractual Clauses approved by the European Commission;
• another legally recognized safeguard;
• a permitted statutory derogation where applicable.

Payment, cloud, security, and technology providers may operate internationally and may maintain infrastructure in multiple jurisdictions.

For this reason, Better Healthy Life does not represent that every item of personal data is stored exclusively within the EEA.

XVI. HOW LONG WE RETAIN PERSONAL DATA

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and for any additional period required by applicable law.

The retention period depends on the category and purpose of the information.

Contact Enquiries

Information submitted through general enquiries may normally be retained for up to 12 months after the enquiry is resolved, unless a longer period is reasonably necessary.

Account and Membership Data

Account and Membership information may be retained for the duration of the Account or contractual relationship and for an appropriate period afterward where necessary for:

• legal obligations;
• dispute resolution;
• fraud prevention;
• security;
• enforcement of agreements;
• legal claims.

Order, Payment, Accounting, and Tax Records

Information required for accounting, tax, payment, or statutory record-keeping purposes will be retained for the period required by applicable law.

Security and Activity Logs

Security and activity logs are retained for a limited period appropriate to security, troubleshooting, audit, and fraud-prevention purposes.

Relevant records may be retained for longer where necessary to investigate an incident, enforce legal rights, or comply with law.

Marketing Information

Marketing information based on consent is retained until consent is withdrawn or the information is no longer reasonably necessary.

We may retain limited suppression information after an unsubscribe request to ensure that the User is not unintentionally re-added to marketing communications.

Consent and Compliance Records

Records demonstrating consent, withdrawal, contractual acceptance, or legally relevant User choices may be retained for as long as reasonably necessary to demonstrate compliance or establish, exercise, or defend legal claims.

When information is no longer required, it will be deleted, anonymized, or otherwise securely disposed of where appropriate.

XVII. INFORMATION SECURITY

Better Healthy Life uses reasonable technical and organizational measures designed to protect personal data against:

• unauthorized access;
• unlawful processing;
• accidental loss;
• unauthorized alteration;
• unauthorized disclosure;
• destruction;
• misuse.

Measures may include, where appropriate:

• access controls;
• password protection;
• restricted administrative privileges;
• secure payment processing;
• fraud-prevention technologies;
• activity logging;
• software and security updates;
• backups;
• security monitoring.

No online system can be guaranteed to be completely secure.

Users are also responsible for protecting their Account credentials and should notify Better Healthy Life if unauthorized Account activity is suspected.

XVIII. PERSONAL DATA BREACHES

Better Healthy Life maintains procedures for responding to suspected personal data breaches.

Where a personal data breach is likely to result in a risk to the rights and freedoms of individuals, Better Healthy Life will notify the competent supervisory authority without undue delay and, where feasible, within the period required by applicable law.

Under GDPR, notification to the competent supervisory authority is generally required within 72 hours after becoming aware of the breach, where the legal notification threshold is met.

Where a personal data breach is likely to result in a high risk to the rights and freedoms of affected individuals, Better Healthy Life will communicate the breach to affected individuals without undue delay where required by law.

XIX. YOUR DATA-PROTECTION RIGHTS

Subject to the conditions and limitations provided by applicable law, you may have the following rights.

Right of Access

You may request confirmation as to whether we process your personal data and request access to that information.

Right to Rectification

You may request correction of inaccurate personal data and completion of incomplete information.

Right to Erasure

You may request deletion of personal data where the legal conditions for erasure are satisfied.

The right to erasure is not absolute and does not require us to delete information that must lawfully be retained, including certain accounting, tax, security, or legal-claims records.

Right to Restriction of Processing

You may request restriction of processing in circumstances provided by applicable law.

Right to Data Portability

Where the legal conditions are satisfied, you may request personal data in a structured, commonly used, machine-readable format and may have the right to transmit that data to another controller.

Right to Object

You may have the right to object to processing based on legitimate interests.

Where personal data is processed for direct marketing, you may object to such processing at any time.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect processing lawfully carried out before the withdrawal.

Rights Relating to Automated Decision-Making

You have rights under applicable law relating to decisions based solely on automated processing, including profiling, where such decisions produce legal effects or similarly significantly affect you.

Better Healthy Life may use automated security and fraud indicators, but does not intend to make decisions producing legal or similarly significant effects solely through automated processing unless lawful and appropriately disclosed.

Right to Lodge a Complaint

You have the right to lodge a complaint with a competent data-protection supervisory authority.

XX. HOW TO EXERCISE YOUR RIGHTS

Requests relating to personal data may be sent to:

[email protected]

Please provide sufficient information to allow us to identify the relevant data and understand your request.

Where reasonably necessary, we may request appropriate verification before acting on a privacy request in order to protect the Account and personal data from unauthorized disclosure.

We will respond within the period required by applicable law.

XXI. SUPERVISORY AUTHORITY IN BULGARIA

The competent Bulgarian supervisory authority is:

Commission for Personal Data Protection (CPDP)

2 Prof. Tsvetan Lazarov Blvd.
Sofia 1592
Republic of Bulgaria

Email: [email protected]
Website: www.cpdp.bg

Individuals may lodge a complaint with the CPDP or another competent supervisory authority where applicable.

XXII. USERS OUTSIDE BULGARIA AND THE EEA

Better Healthy Life may be accessed by Users in countries outside Bulgaria and the European Economic Area.

Where privacy laws applicable to a particular User provide additional mandatory rights, Better Healthy Life will respect those rights to the extent those laws apply to our processing.

Nothing in this Privacy Policy is intended to remove or restrict mandatory privacy rights that cannot legally be waived.

XXIII. THIRD-PARTY WEBSITES

The Website may contain links to third-party websites.

Better Healthy Life is not responsible for the privacy practices of independent third-party websites.

Users should review the privacy information provided by the relevant third party before providing personal information through an external website or service.

XXIV. CHANGES TO THIS PRIVACY POLICY

Better Healthy Life may update this Privacy Policy where necessary because of:

• changes in applicable law;
• changes to our services;
• changes to technologies or providers;
• security requirements;
• changes in our processing activities.

The current version will be published on betterhealthylife.eu with an updated effective or revision date.

Where a material change requires additional notice or consent under applicable law, Better Healthy Life will provide that notice or obtain that consent as required.

Continued Website use will not be treated as consent where applicable law requires a specific affirmative consent.

XXV. CONTACT

For privacy questions, requests, or complaints:

BETTER HEALTHY LIFE Ltd.
UIC: 207335971

Republic of Bulgaria
1592 Sofia
Iskar District
Druzhba Residential Complex
Block 168
Entrance A
Floor 4
Apartment 12

Email: [email protected]
Telephone: +359 888 889 164

Effective date: 18 October 2026
Last updated: 18 October 2026