Privacy policy

We respect your privacy and are committed to protecting the personal information you provide to us. In this regard, we would like to share with you the principles that form our privacy policy.

All capitalized terms used in this Privacy Policy or in any notice given in connection with this Privacy Policy have the same meaning as in the Terms of Use unless expressly defined otherwise herein.

This Privacy Policy is based on the requirements of the European Union General Data Protection Regulation 2016/679 (“GDPR”) on the protection of individuals in relation to the processing of any information that relates to an identified or identifiable living individual (“Personal Datа”). and other Soft Skills Pills websites (collectively, the “Website”) are operated by Tochka 2 Ltd. with UIC 204253608, registered office address in Bulgaria, Sofia, 53 Velcho Atanasov str., ent. 1, floor 5 (referred to for the purposes of this Privacy Policy as the “Company”). The Company is the Personal Data controller within the meaning of the GDPR.

The Company collects personal data and uses this personal data only for the purposes of offering, providing and/or improving the Services, unless a reasonable assessment is made that this personal data shall also be processed for additional purposes. Users will be informed if the personal data is processed for additional purposes. This Privacy Policy is addressed to individuals with whom we interact, including clients, visitors to our Website, other users of our services, and personnel of corporate clients (referred to for the purposes of this Privacy Policy as “you”).

This document (“Privacy Policy”) describes our policies and procedures, governing the collection and processing of this information, which identifies an individual User and may be used for contact with him or her (“Personal Data”, “Personal Information”).

This Privacy Policy is valid only with respect to the Service and should not apply to any third-party website or service, related to the Service recommended or referred by the Service or by customers of Tochka 2, or to any other websites or online services, related to Tochka 2. 

Collection of Personal Data

We collect personal information to respond to your requests that may include, for example, providing access to the Service, creating a personal profile, verifying your identity, sending messages related to the Service, providing access to certain features of the Service, signing up for our newsletter, or events or games we host, participating in online surveys, discussion groups or forums, for marketing activities.

We collect the following personal information from Users of the Service:

Directly through the Website: first and last name, phone, email, address, ID number (in case of invoicing an individual);

We may also request additional information, but only with your explicit permission or in case this information is necessary for the performance of the Service you have requested. You are the sole owner of your personal information.

By using our Service, you expressly consent to your personal information to be collected and processed by us while you warrant their accuracy and reliability. You also represent that you have been informed about the type of personal data we collect and process, the purposes for which it will be used and your right to access, rectify or erase the personal data collected.

Use of your personal data

We use your personal data to provide you with the opportunity to access the Website, access the Service and/or register for a personal account, process your requests and enquiries, send you our regular newsletter and/or offer you additional services, for promotional and marketing activities, and generally to fulfil our commitments to you and to provide you with the service you expect. You expressly consent to your personal data being provided to third parties when it is necessary for the performance of the business relationship between you and Tochka 2. 

You have the right to refuse your personal data being used by us for commercial, advertising or marketing purposes. If you do not want your data to be used by us for commercial, advertising or marketing purposes, you can contact us at the contact details published at We may use your information to create aggregated statistics that are anonymous and to perform based statistical analysis. Also, a necessary part of your information may be used to enforce our Terms of Use and to prevent possible harm to persons or property.

Use of cookies and other tracking technologies

We use cookies to collect certain information from all users, including unregistered visitors to the Website who do not use the Services provided by us. Cookies provide information about the use of the Service and user data that we might use to personalize your user experience as well as track patterns of user traffic. Cookies also allow us to remind you of your previous activities and to offer similar services and events. Also, we use information collected through Cookies to develop statistical analytics about your use of the Service, such as the amount of time users spend on the Website and the pages they visit most frequently. These aggregate statistics do not include any personal information.

We use Google Analytics to collect statistical information about Website users, such as the website from which you come to our Website, the country you are in, your language, your online behaviour, the browser you use, the web, etc. This information does not include personal data and you cannot be identified by it. We collect the above data to analyse what type of Users use the Website and how they use it, which helps us personalize the Service.

We also use Facebook Ads cookies – but we do not have access to personal data that could be collected and processed by Facebook through such cookies.

Lastly, we use YouTube cookies – the analytical cookies register only anonymous statistical data. The advertisement cookies collect information such as tracking views of embedded videos, bandwidth, video preferences, etc., but no personal data is collected and stored and you cannot be identified by it.

When you access the Website, at the bottom of the page you will be given the opportunity to customize, reject or accept the use of the cookies. Once you choose your preferred option the field would not be shown again.

By agreeing to use the Service and/or clicking “Accept all” on the Website, you explicitly express your consent to the use of Cookies, including Google Analytics cookies, Facebook Ads cookies and YouTube-related cookies, and you represent that you have been given the opportunity to refuse the storage of or access to the information. If you want to change your preferences at a later stage, you can do that on the following link.

Protection of personal data

We ensure the security of the data you send us with standardised electronic and managerial procedures. Where it is appropriate, we use SSL encryption to enhance the security of the transmission of sensitive data. Internally, data is stored on controlled servers with restricted access. Your information may be stored and processed in certain locations where we are located, strictly in accordance with applicable privacy laws and data protection. Inquiries and complaints related to this Privacy Policy can be sent to the contact email addresses published on

Disclosure of personal data to third parties

We will not disclose your personal data to third parties. We may disclose your personal information to third parties only with your explicit consent or where the disclosure is necessary for the performance of obligations under a business relationship between you and Tochka 2.

We can share the following data with a third-party merchant of record for the execution of the Service – your name and address, email address and everything else necessary for the payment processing. Any personal data provided by you to the merchant of record in connection with making а payment for the Service, including but not limited to IBAN, card information, banking and/or any financial information will not be shared with us and will not be stored or processed by us.

Exceptions are where disclosure is required by law in the public interest or for the establishment, exercise or defence of rights in a court of law, e.g. where certain information is provided to lawyers, collection agencies, customs or other government authorities, or to law enforcement authorities to address potential violations, other breaches of contract, or unlawful conduct. We may also disclose information required by court order or other laws, or to prevent possible harm to persons or property.

As noted above, we compile statistics about the use of Service from data collected through cookies. These statistics do not contain personal information and may be published or made available to third parties.

Links to third-party websites

The Service, as well as third-party materials that are posted on the Website, contain links to and may allow you to visit other electronic pages (“Third Party Electronic Pages “). If you choose to visit any of these Third Party Pages by “clicking on” a link or navigating to a Third Party Page, you will be redirected to the relevant third-party page. The fact that we provide a link to an electronic page through the Service, or by posting a banner or other advertisement, or by offering you the opportunity to interact with, or provide personal information to a third party is not a warranty, permission, or representation of our affiliation with the said third party and should not be considered as consent to their privacy policies and practices and information security practices.

Access and correction of personal information

You have the right to access, require correction, amendment or deletion of portions of your personal data stored by us. It is not possible to request the immediate deletion of personal data in every circumstance, for example, if there is a regulatory obligation to maintain the personal data. You may also request a limitation of the processing of personal data where the processing may violate applicable regulations. 

We will retain your data for as long as necessary to provide our services or for as long as the law requires us to. Personal data for which there is no explicit legal obligation for storage will be deleted after achieving the purposes for which the personal data was collected and processed.

Amendment to this privacy policy

This Privacy Policy may be amended unilaterally by Tochka 2, of which we will give appropriate notice. You agree that any additions or modifications to this Policy will be effective to you upon notice from Tochka 2.

You agree that all statements made by Tochka 2 in connection with the amendment of this Policy will be sent to your e-mail address used to register for the Service or by posting in an appropriate place on the Website.

If you do not agree with the revised content, you should stop the use of the Services immediately. Continuing to use the Services is acceptance of changes to the Privacy Policy.


Effective date: Jan 24, 2023

Last modified: Jan 24, 2023