Who we are
КОДЕР ЕООД (CODER LLC), company ID 208537335, 4 Lavski Rid St., fl. 9, apt. 47, 1680 Sofia. You can reach us at office@coderonline.org. On this page, "CODER", "we" and "us" mean this company.
We decide why and how your personal details are used, which makes us the controller under the General Data Protection Regulation (GDPR). We have no separate data protection officer. Write to the address above for anything about your data.
What this policy covers
This policy covers coderonline.org, our contact form, readings booked with Olga, courses at the CODER Academy, the sale of our instruments, MobiCoder and Coder Studio, and the apps we publish on the App Store and Google Play. It does not cover readings you book with an independent practitioner trained in the method: they are your contract with that person, and their own privacy terms apply.
When you visit the site
Our host keeps server logs with your internet address, the pages you open, the time, and your browser type. We use them only to keep the site running and safe; our ground is our legitimate interest in doing so. Logs are kept for thirty days.
The site sets one small cookie to remember the language you chose, and one to remember your answer in the cookie banner. Nothing else is set unless you say yes in that banner. If you accept statistics, Google Analytics records how the site is used, without storing your internet address. If you accept marketing, the Meta pixel tells Facebook and Instagram that you visited, so we can show our ads to people like you and measure them. Neither runs until you have said yes, and you can change your answer at any time with the cookie settings link at the foot of every page.
The map of practitioners is drawn with tiles from OpenFreeMap, which sets no cookies, though loading the tiles shows your internet address to that service. Videos on the site come from YouTube in its no-cookie mode and load only when you press play; from then on YouTube's own privacy terms apply.
When you write to us
The contact form asks for your name, your email, what your message is about, and the message itself. We use them to answer you, and for nothing else. We also keep a scrambled form of your internet address for a short time, only to stop the form being flooded. Our ground for this is our legitimate interest in answering the people who write to us, or the steps before a contract if you are asking about something you want to buy. Messages are deleted twelve months after the last reply.
When you book a reading
To give you a reading, Olga needs your name, your email, your date of birth, the photographs you send, and the questions you want answered. You give them to us by email or in the booking calendar. We use them only to prepare and give your reading. Our ground is the contract between us: without them, there is no reading.
Your photographs are used by Olga for your reading. The few people who help her run the office can open the inbox and the folders where they are kept, and our email host stores them for us, but nobody else looks at them. They are not published, they are not passed to anyone for their own use, and they are deleted when you ask. We do not use them to identify you or anyone else, and we do not build any database of faces. When Olga prepares your reading in Coder Studio, the photograph is processed on her own computer and nowhere else.
We do not ask about your health. Some people mention their health, their beliefs or their private life anyway, in their questions or during the reading. Because these details need extra protection, we ask you when you book to tick a box agreeing that Olga may use anything of that kind you choose to share, only for your reading. If you book by email, we ask for the same yes in writing before the reading. For a child, the parent gives it. You can take it back at any time; we then delete those details and our copy of the recording, and Olga will not use them again.
During and after a reading
Readings happen on Zoom. The session is recorded so that you can watch it again, and the recording is sent to you. We keep our copy of the recording, your photographs and your questions for twelve months after the reading, so Olga can refer to them if you book a follow-up; then we delete them. You can ask us to delete them sooner at any time.
Payment for a reading is made by card through the booking calendar, or by bank transfer after you book by email. The card payment is handled by Stripe; we never see your card number. Your name, the amount and the date go on an invoice that we must keep for ten years, as Bulgarian tax law requires.
When you join a course
Courses are joined on our course platform at learn.coderonline.org, where you create an account with your name, your email and a password. The platform handles the payment; we never see your card number. Live sessions are on Zoom and are recorded for the people in the course. Your name, your picture if your camera is on, and what you say in a session are in that recording. Course recordings stay available to the group for twelve months after the course ends, then they are deleted. Our ground is the contract between us, and the law that makes us keep invoices.
When you buy an instrument
To sell you a MobiCoder or Coder Studio we need your name, your contact details, and a delivery address if something is sent to you. We keep the invoice for ten years, as the law requires. For Coder Studio we also keep the activation code we issued to you, so we can help you if you lose it.
The instruments themselves keep what they measure on the instrument or on your own computer. MobiCoder never needs the internet, and Coder Studio works without any cloud. Nothing you do with them is sent to us. Activating or moving a Coder Studio licence sends nothing to us either.
Readings for children
A reading for a child is booked by a parent or legal guardian, who sends the child's photograph and answers for the child. We rely on the parent's consent for that, and we treat a child's details with the same care as an adult's. The site itself is not aimed at children, and we do not knowingly collect details from anyone under sixteen without a parent.
Practitioners
If you ask us to put you in touch with a practitioner trained in the method, we pass your name, your email and your message to that person, with your agreement. From then on their own privacy terms apply: each practitioner is independent and answers for their own readings.
Our apps
Any app CODER publishes on the App Store or Google Play appears under the developer name CODER LLC EOOD.
An app works on your phone and keeps what it makes there. If it uses the camera or the phone's sensors for a reading, the pictures and the measurements are processed on the phone and stay on it; nothing is uploaded to us or to anyone else. The app shows no advertising, and it contains no analytics or crash reporting.
If an app offers an account, it asks only for your email and a password, and uses them to sign you in and to keep your readings together. You can delete the account at any time inside the app, under its settings, or by asking us on the account deletion page. Deleting the account removes it and everything kept under it within thirty days; an invoice, if there was one, stays for as long as the law makes us keep it.
Support for the apps is the contact page and office@coderonline.org. The stores themselves (Apple and Google) handle your purchase and your store account under their own privacy terms.
Who else handles your details
A few services do part of the work for us:
- SuperHosting.bg (Bulgaria) hosts the site and our email, including the messages you send us.
- Calendly (United States) runs the booking calendar for readings.
- Stripe (Ireland and United States) takes card payments for readings and events.
- Zoom (United States) carries readings and live course sessions.
- Teachable (United States), the course platform behind learn.coderonline.org, hosts the courses and takes their payments.
- Google (Ireland and United States) for Google Analytics, only if you accept statistics, and for YouTube, only when you press play.
- Meta (Ireland and United States) for the Meta pixel, only if you accept marketing.
- WhatsApp (Ireland and United States), only if you choose to message us there.
- OpenFreeMap draws the map of practitioners and sees your internet address when the map loads.
- Our bank, for bank transfers.
Most of these only work on our behalf. YouTube, WhatsApp and Meta decide for themselves how they use what they see, under their own privacy terms.
We do not sell your details, and we do not pass them to anyone to use for their own advertising. We hand them over only if the law makes us, for example to a court or a tax authority.
Outside the European Union
Some of the services above work in the United States. Where they do, your details are protected by the EU-US Data Privacy Framework if the service is certified under it, and otherwise by the standard contractual clauses approved by the European Commission. You can ask us for a copy of the clauses that apply.
How long we keep things
- Server logs: thirty days.
- Messages through the contact form: twelve months after the last reply.
- Photographs, questions, the images and codes the program makes from them, the written description and our copy of the recording: twelve months after the reading, or sooner if you ask.
- Course accounts and recordings: twelve months after the course ends.
- Invoices and payment records: ten years, as Bulgarian accounting and tax law requires.
- Statistics, if you accepted them: two months, the shortest setting Google Analytics offers.
- Marketing, if you accepted it: Meta keeps what the pixel sends under its own terms; our side of it, the ad audiences, is cleared after six months.
Your rights
You can ask us at any time to see the details we hold about you, to correct them, to delete them, to limit how we use them, to object to our use of them, or to hand you a copy in a form you can take elsewhere. Where we rely on your consent, you can withdraw it at any time, and that does not undo anything done before. Write to office@coderonline.org and we will answer within a month.
You can object at any time to any use we base on our legitimate interest, and we will stop unless we have a stronger reason the law accepts. We make no decisions about you by automated means alone.
If you think we have handled your details wrongly, you can complain to the Commission for Personal Data Protection (Комисия за защита на личните данни), 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, cpdp.bg, or to the data protection authority where you live.
How we protect your details
Our email and the site run over encrypted connections. Photographs and recordings for readings are kept in accounts that only Olga and the people who help her run the office can open. We keep the number of people who can see your details as small as the work allows.
Changes to this policy
If this policy changes, the new version goes on this page with its date. If a change matters to something you have already bought, we tell you by email. Last updated: 29 October 2026.