Privacy & Email Policy

Effective 2026-09-28 · Last updated 2026-09-28

This is the single comprehensive privacy and email-transparency policy for Kelbrio. The intended email program for this revision is limited to United States recipients. Different requirements may apply depending on the recipient, source, relationship, and jurisdiction; unresolved legal questions remain subject to counsel review.

1. Who we are

KELBRIO TRADE LTD operates Kelbrio. Our postal address is 20 Osemnadeseta St., 4414 Debrashtitsa, Pazardzhik Municipality, Pazardzhik Province, Bulgaria. Privacy questions can be sent to privacy@pettvo.com; unwanted-email and abuse reports can be sent to abuse@pettvo.com; publisher and general questions can be sent to publisher@pettvo.com.

2. Scope and the U.S. email program

This policy covers this website, messages sent to the published role addresses, source and permission records where applicable, and commercial email associated with Kelbrio. The contemplated email population for this revision is United States only. U.S. commercial-email practices are designed around applicable U.S. commercial-email, privacy, and advertising requirements, but this statement is not a universal legal approval and does not determine the law for every recipient.

3. Why you may receive email from Kelbrio

The applicable reason depends on the source record associated with the message. These categories are factual source lanes, not interchangeable consent claims.

Direct subscription

A person may have directly asked Kelbrio to send marketing or offers. We treat a person as directly subscribed only when supporting evidence is bound to that person and records what was presented, when it was presented, the email channel, and the permission status.

Partner or publisher permission

A person may have given another publisher, service, site, or partner permission for contact information to be used for relevant offers from other senders. We require source and provenance evidence before treating a partner record as consent-backed. A generic “opt-in list,” “partner approved,” or similar vendor label is not sufficient by itself. Partner permission is not represented as a direct subscription to Kelbrio.

Public or business contact information

Some business outreach may use public business directories, public business or place information, a company’s own public website, public contact/about/team pages, or another documented business source. Public availability does not itself mean subscription or consent.

Existing relationship

Where applicable law permits, a message may relate to an existing business, customer, or other relationship. This category is not universally applicable and does not replace a source-specific legal review.

Other documented source

A separately documented lawful source may exist that does not fit the categories above. Unknown provenance is not converted into consent.

4. What an email may contain

An email may contain information about a product or service, comparison information, offers, recommendations, publisher content, a Kelbrio product or service, another business’s product or service, partner offers, or a referral destination. An individual message may concern Kelbrio, another provider, or information that Kelbrio publishes; no single relationship is implied for every message.

5. Products, providers, and referral relationships

Sometimes Kelbrio communicates about its own offering. Sometimes a message concerns another provider’s offering, or Kelbrio acts as a publisher or referrer. Following an external offer link can take you to a separate business with its own terms and privacy practices.

Kelbrio may have commercial or financial relationships with businesses referenced in its content and may receive compensation connected with qualifying referrals or actions. A relationship or compensation does not mean that the advertiser supplied a recipient’s email address. For each compensated offer, an internal material-connection review is required to determine whether the message context itself makes the relationship clear and whether additional disclosure is needed near a recommendation or link.

6. Information we may process

Depending on the interaction and source, we may process an email address; business or contact information; source and provenance information; source class; subscription or consent evidence where applicable; marketing preference and suppression status; delivery, bounce, and complaint records; inbound messages; security and request metadata; and affiliate or referral attribution information where available.

In the current architecture, Kelbrio does not use email-open tracking and does not operate an internal recipient-level click redirect. External affiliate networks and destinations may process click, browser, device, or conversion information under their own practices after a person follows an external link.

7. How we use information

Possible uses include sending applicable email communications; maintaining source, subscription, and permission records; maintaining preferences and suppression; preventing re-contact after an unsubscribe or objection; handling delivery, bounce, and complaint records; preventing abuse and securing systems; responding to privacy and contact requests; recordkeeping; and administering referral or attribution activity where applicable. We do not describe this architecture as behavioral profiling or cross-site advertising.

8. Source, consent, and legal basis

Our internal source classes are PUBLIC_BUSINESS_OUTREACH, DIRECT_KELBRIO_OPT_IN, and THIRD_PARTY_PARTNER_OPT_IN. They preserve factual provenance and do not by themselves establish legal clearance.

Where applicable, direct opt-in may rely on valid consent. Partner opt-in may rely on consent only where the originating permission actually covers the intended communication from another sender and the evidence is bound to the recipient. Public or business outreach requires a separate legitimate-interest and electronic-marketing analysis where relevant. For data not obtained directly from a person, including partner and public-source data, an Article 14 transparency analysis may apply; direct collection is assessed under an Article 13 model where GDPR applies. Legal send applicability remains COUNSEL_REVIEW_REQUIRED.

9. Unsubscribe, withdrawal, and objection

Recipients can stop future Kelbrio commercial email at any time. Commercial email includes a visible Unsubscribe link. Mail Infra also supplies a recipient-bound opaque URL in the List-Unsubscribe header and the RFC 8058 List-Unsubscribe-Post: List-Unsubscribe=One-Click header. Supported mailbox providers may show their own unsubscribe control; the provider determines whether it appears and its placement and size.

Withdrawal of consent and objection to direct marketing are distinct concepts, but both are honored operationally through global future-marketing suppression where applicable. A GET confirmation request does not change suppression; the governed POST action is the mutation. A minimal suppression identifier may be retained so an address is not accidentally re-imported or contacted again. An opt-out mechanism remains required even where a recipient previously consented.

10. Privacy rights

Depending on where you live and which laws apply, you may have rights to access, correction, deletion, restriction, portability, information about sources and recipients, withdrawal of consent, and objection to direct marketing. An objection to direct marketing is decisive where the applicable law gives that right. Contact privacy@pettvo.com and provide only the minimum information needed to locate and protect a request.

If a complaint route is available under applicable law, you may contact a competent supervisory authority, including the Bulgarian Commission for Personal Data Protection through its complaints and alerts process. U.S. state privacy obligations depend on facts such as revenue, resident volume, data flows, and statutory scope. CCPA_APPLICABILITY=UNKNOWN_PENDING_REVENUE_AND_CALIFORNIA_FACTS; we do not state that information is sold or shared until the relevant facts and contracts are reviewed.

11. Retention and security

We retain information only for operational, security, legal, audit, and suppression needs. Evidence used to justify a subscription-based message should preserve the source, recipient binding, timestamp, presented text or version/hash, scope, and withdrawal or revocation state without retaining unnecessary raw data indefinitely. Retaining a minimal suppression marker can be necessary to honor an objection.

Access is restricted through the relevant system authority and protected service interfaces. No security measure eliminates all risk. Report suspected abuse to abuse@pettvo.com and do not send passwords, tokens, or unrelated personal data.

12. Site and offer terms

This site and email content are informational and promotional. Third-party destinations have their own terms and privacy notices; offers, availability, eligibility, pricing, coverage, and conditions may change. Kelbrio is generally a publisher or referrer unless a specific relationship says otherwise. We do not guarantee acceptance, insurance coverage, savings, pricing, eligibility, or any particular outcome. Affiliate links may result in compensation. Use of the site must not disrupt, scrape, impersonate, or abuse the service. These terms and any limitation of liability remain subject to applicable law and counsel review.

13. Contact and changes

Use privacy@pettvo.com for privacy, source, consent, or direct-marketing questions; abuse@pettvo.com for unwanted email or abuse; and publisher@pettvo.com for publisher and general questions. We may update this policy when the service, law, or data practices change. The effective and last-updated dates above identify the current version.