Oshatex LLC. ("Company," "we," "us," or "our")

Effective Date: August 6th 2026 Last Updated: August 6th 2026

1. Introduction

Oshatex Ltd. ("Company," "we," "us," or "our") operates the website at www.ginkakostova.com (the "Site") and provides nutrition, coaching, and related health-education services under the brands Performance Energy Physiology and The Performance Advantage (the "Services"). This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and what rights you have regarding it.

This Policy applies to visitors of the Site, prospective clients, and current and former clients. It should be read together with our Terms and Conditions. By using the Site or the Services, you acknowledge the practices described here.

2. Who We Are and How to Reach Us

Oshatex Ltd. is the entity responsible for the personal information described in this Policy (the "data controller" for purposes of GDPR, and the "business" for purposes of US state privacy laws).

●      Business Entity: Oshatex LLC registered in South Carolina, USA

●      Registered Address: 14 Windtree Ln, 29910 Bluffton, SC

●      Email: hello@ginkakostova.com

●      WhatsApp: +359 887 711 816

If you are located in the EU/EEA/UK and have concerns we haven't resolved, you also have the right to lodge a complaint with your local data protection supervisory authority.

3. Information We Collect

3.1 Information You Provide Directly

●      Contact details: name, email address, phone number, WhatsApp number, mailing address

●      Intake and health information: medical history, symptoms, medications, diet, sleep, stress, lifestyle habits, lab results, functional testing data (for example, GI-MAP, blood panels, Stool OMX), and other health-related information you choose to share in forms, sessions, or messages

●      Payment information: processed directly by our payment and course-delivery platform (Kajabi); we do not directly store full card numbers

●      Session content: notes, recordings (only with your separate consent), and follow-up communications

●      Testimonials or feedback you voluntarily provide

3.2 Information Collected Automatically

●      Usage data when you visit the Site: pages viewed, time on page, referring URLs, device and browser type, approximate location derived from IP address

●      Cookies and similar tracking technologies, as described in Section 8

3.3 Information From Third Parties

●      Scheduling and calendar data from Calendly

●      Course engagement and purchase data from Kajabi

●      Communications and workspace data through Google Workspace (Docs, Sheets, Drive, Gmail) used to manage client files

4. Why We Collect and How We Use Your Information

●      To deliver the Services: intake review, session preparation, protocol and recommendation development, and follow-up support

●      To communicate with you about scheduling, program updates, and your account

●      To process payments and manage billing, including installment plans

●      To improve the Site and the Services, including understanding how clients use our content and programs

●      To send marketing communications, such as newsletters or program updates, where you have opted in or as otherwise permitted by law, always with an option to unsubscribe

●      To comply with legal, tax, and regulatory obligations

●      To protect the rights, safety, and property of the Company, our clients, and others

5. Legal Bases for Processing (EU/EEA/UK Clients)

If you are located in the EU, EEA, or UK, we rely on the following legal bases under GDPR to process your personal data:

●      Contract performance: processing necessary to deliver the Services you have purchased

●      Explicit consent: for health data (a special category of data under GDPR Article 9), which we collect only with your explicit, separately obtained consent, and for optional marketing communications and any session recordings

●      Legitimate interests: for Site analytics, security, and improving our Services, balanced against your rights and interests

●      Legal obligation: where processing is required to comply with tax, accounting, or other legal requirements

You may withdraw consent at any time by contacting hello@ginkakostova.com. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal, and may affect our ability to continue providing the Services to you.

6. How We Share Your Information

We do not sell your personal information. We share information only as follows:

●      Service providers who process data on our behalf under contractual confidentiality obligations, including Kajabi (course delivery and payments), Calendly (scheduling), Google Workspace (file storage and communication), and WhatsApp (client messaging)

●      Other health professionals or mentors, on a limited, need-to-know basis, when we believe consultation would benefit your care; your identity is protected in these consultations and your name is not disclosed unless you separately agree

●      Legal and safety purposes, where disclosure is required to comply with a law, regulation, court order, or valid legal process, or to protect the rights, property, or safety of the Company, our clients, or the public

●      Business transfers, in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy or a policy at least as protective

●      With your direction, such as when you ask us to share information with your physician or another provider

7. International Data Transfers

We are based in the United States, and our service providers may process data in the United States or other countries. If you are located in the EU/EEA/UK, your information may be transferred outside your region. Where required, we rely on appropriate safeguards for such transfers, such as Standard Contractual Clauses, and we work with service providers that maintain appropriate data protection commitments. You may contact us for more information about the safeguards in place.

8. Cookies and Tracking Technologies

The Site may use cookies and similar technologies to operate correctly, remember preferences, and understand how visitors use the Site (for example, through analytics tools). You can control cookies through your browser settings; disabling cookies may affect some Site functionality. Where required by law, we will request your consent before placing non-essential cookies.

9. Data Retention

We retain personal information for as long as necessary to provide the Services, maintain our business records, and comply with legal, tax, and accounting obligations. Health-related intake and session data is generally retained for the duration of our working relationship and for a reasonable period afterward to support continuity of care and meet recordkeeping obligations, after which it is securely deleted or anonymized, unless a longer retention period is required by law or you request earlier deletion in accordance with Section 11.

10. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect your personal information, including restricted access to client files and use of reputable third-party platforms for storage and communication. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. As noted in our Terms and Conditions, standard email and WhatsApp are not fully encrypted, HIPAA-grade secure channels; please consider this when sharing highly sensitive information through those channels.

If we become aware of a data breach affecting your personal information, we will notify you and any applicable regulator as required by applicable law.

11. Your Privacy Rights

11.1 EU/EEA/UK Residents (GDPR)

You have the right to:

●      Access the personal data we hold about you

●      Correct inaccurate or incomplete data

●      Request deletion of your data ("right to be forgotten"), subject to legal recordkeeping requirements

●      Restrict or object to certain processing, including direct marketing

●      Receive your data in a portable format

●      Withdraw consent at any time where processing is based on consent

●      Lodge a complaint with your local supervisory authority

11.2 US Residents

Depending on your state of residence, you may have rights under applicable state privacy laws (such as, where applicable, the right to know what personal information is collected, request deletion, correct inaccurate information, and opt out of the sale or sharing of personal information, or of targeted advertising). We do not sell personal information.

To exercise any of these rights, contact us at hello@ginkakostova.com. We will respond within the timeframe required by applicable law and may need to verify your identity before fulfilling certain requests.

12. Children's Privacy

The Services are not directed to children, and we do not knowingly collect personal information from anyone under 16. If you believe a child has provided us with personal information, please contact us so we can delete it.

13. Testimonials

If you provide a testimonial or agree to have your case referenced (in anonymized or attributed form) in our marketing, we will use it as agreed with you. You may request removal at any time by contacting hello@ginkakostova.com.

14. Third-Party Links

The Site may link to third-party websites or services. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies separately.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last Updated" date above reflects the most recent revision. Material changes will be communicated to active clients by email, and continued use of the Site or Services after changes take effect constitutes acceptance of the revised Policy.

16. Contact Us

Questions about this Privacy Policy, or requests relating to your personal data, can be sent to:

●      Email: hello@ginkakostova.com

●      WhatsApp: +359 887 711 816

●      Business Entity: Oshatex LLC registered in South Carolina, USA —14 Windtree Ln, 29910 Bluffton, SC