Last updated: 6 September 2026

This Privacy Policy explains how PRED Ltd. (Bulgarian legal entity: ПРЕД ЕООД), operating LX Mind at lxmind.org, processes personal data.

1. Who We Are

PRED Ltd.
UIC / EIK: 208913271
VAT No.: BG208913271
Registered office: 78 367-ma St., Entrance B, Floor 6, Apt. 1, 1360 Sofia, Bulgaria
Managing Director: Elena Dimchova Gotseva
Contact: elena@lxmind.org

2. Scope

This Policy applies to personal data processed through LX Mind, including website accounts, the Experience & Forum community, newsletter subscriptions, email communications, analytics where enabled, embedded external content, and website security.

The current Cookie Policy is available at /cookie-policy/.

3. Personal Data We Process

Website accounts

When you create an account, we may process your display name, email address, automatically generated WordPress username/internal identifier, account status, authentication/security data and technical information needed to operate and secure the service.

Passwords are handled through WordPress authentication mechanisms and are not stored by us in readable plain text.

Creating an LX Mind account does not automatically subscribe you to marketing emails.

Experience & Forum

If you participate in the community, we may process and publish discussion topics, replies/comments, display name, publication date, category, moderation status and information needed to associate contributions with your account.

Forum contributions are public when published. Please do not post private, confidential or sensitive personal information that you do not want to make public.

Newsletter

LX Mind uses MailPoet to manage LX Mind email updates.

If you voluntarily subscribe, we may process your email address, subscription status, mailing-list membership, opt-in source, opt-in timestamp, consent wording version, and unsubscribe/preference status.

Newsletter subscription is voluntary and separate from account registration. The newsletter checkbox shown during registration is unchecked by default.

You can unsubscribe at any time or manage your preferences at /email-preferences/.

Newsletter engagement analytics

MailPoet is currently configured to provide engagement analytics. Depending on email-client behavior, this may include technical indications that an email was opened, that a link was clicked, that a message bounced, or that you unsubscribed.

Email-open measurements are not always precise because some email applications and privacy features may load images automatically.

Each LX Mind marketing email provides a Stop tracking my opens and clicks link. If you use it, MailPoet stops recording future open and click activity for your subscriber profile while you may continue receiving emails unless you also unsubscribe.

We use engagement information to understand whether our communications are useful and to improve content and delivery. Where applicable law requires consent for such tracking, we will obtain the required consent or limit tracking accordingly. Where processing is based on legitimate interests, you may object as provided by law.

Contact by email

If you contact elena@lxmind.org, we process the information you choose to provide in order to respond and maintain necessary correspondence.

Website analytics

LX Mind may use Google Analytics through Google Site Kit to understand website usage and improve the site.

Analytics may involve pages viewed, approximate location derived from IP address, device/browser information, referral source, interaction/session information and technical identifiers where permitted.

The operation of analytics is subject to the website’s current cookie and consent configuration. For the current list of cookies and services detected on the website, see /cookie-policy/.

YouTube embeds

LX Mind may embed YouTube videos, including privacy-enhanced youtube-nocookie.com embeds. When external video content is loaded, Google/YouTube may receive technical information such as IP address, browser/device information and player interaction information.

Where required, consent controls may prevent or delay loading such content until the relevant choice has been made.

Avatars / Gravatar

Where WordPress avatar functionality is active, an avatar may be obtained from Gravatar based on an encoded representation of your email address. The external service may receive technical request information when an avatar is loaded.

4. Why We Process Personal Data

We process personal data to create and maintain accounts, enable and moderate community participation, send newsletters to voluntary subscribers, manage email preferences, measure communications where lawful, respond to enquiries, operate and secure the website, prevent abuse and comply with legal obligations.

5. Legal Bases

Where the GDPR applies, we may rely on:

• Consent for newsletter subscription and for cookies, analytics or similar technologies where consent is required.
• Performance of a contract or steps requested before entering into a contract where processing is necessary to provide an account or service you request.
• Legitimate interests for security, abuse prevention, moderation, technical operation, service improvement and certain communication analytics where permitted and not overridden by your rights.
• Legal obligations where processing is required by law.

Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before withdrawal.

6. Service Providers and Recipients

Depending on the feature you use, service providers may include website hosting/infrastructure providers, MailPoet for newsletter management, SMTP2GO for email transmission, Google Site Kit / Google Analytics, YouTube / Google, and WordPress-related technical services.

We disclose personal data only to the extent reasonably necessary for the relevant service, legal requirement or security purpose.

Some providers may process data outside the European Economic Area. Where applicable, transfers should be protected by an appropriate legal mechanism such as an adequacy decision, Standard Contractual Clauses or another lawful transfer mechanism.

We do not claim that every service or processing operation remains exclusively within the European Union.

7. Newsletter Delivery and Preferences

LX Mind uses SMTP2GO to transmit newsletter messages and MailPoet to manage subscriber preferences.

You can:

• unsubscribe using the link in any newsletter;
• manage preferences at /email-preferences/;
• opt out of MailPoet open/click tracking using the tracking opt-out link included in newsletters.

Unsubscribing from the newsletter does not delete your website account. Closing a website account does not necessarily remove a newsletter subscription because account registration and newsletter consent are separate.

8. Cookies and Consent Choices

LX Mind uses a cookie-consent system to provide information and choices concerning cookies and similar technologies.

See /cookie-policy/ and use Manage Cookie Preferences on the website to revisit your choices.

9. Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Policy and for applicable legal, security and compliance requirements.

In general:

• account data is retained while an account is active and as reasonably necessary afterward for security, disputes or legal obligations;
• forum contributions may remain while published and as necessary for moderation, discussion integrity and lawful operation, subject to applicable rights;
• newsletter data is retained while subscribed, with limited suppression information retained where necessary to respect an opt-out;
• consent evidence may be retained as reasonably necessary to demonstrate compliance;
• correspondence is retained as needed to respond and maintain relevant records;
• analytics data is retained according to the verified configuration of the relevant analytics service.

10. Security

We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, loss or misuse.

No internet service can guarantee absolute security. You are responsible for keeping your credentials confidential and using a secure password.

11. Your Rights

Where the GDPR applies, you may have the right to request access, correction, deletion, restriction, portability, withdrawal of consent, and to object to processing based on legitimate interests.

To exercise your rights, contact elena@lxmind.org. We may need to verify your identity before acting on a request.

12. Bulgarian Supervisory Authority

The competent supervisory authority in Bulgaria is the Commission for Personal Data Protection (CPDP).

Website: https://cpdp.bg/

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

13. Children and Minors

LX Mind is not intended to bypass legal protections applicable to children or minors. Where applicable law requires parent or guardian authorization, that authorization must be obtained.

If you believe a minor has provided personal data in circumstances that do not comply with applicable law, contact elena@lxmind.org.

14. Changes to This Policy

We may update this Policy when the website, processing activities or legal requirements change. The current version will remain at /privacy-policy/ and the “Last updated” date will show the latest revision.

15. Contact

PRED Ltd.
Email: elena@lxmind.org
Registered office: 78 367-ma St., Entrance B, Floor 6, Apt. 1, 1360 Sofia, Bulgaria