Privacy Policy

Subject matter of data protection

The subject matter of data protection is personal data. Under Article 4 (1) GDPR, this means any information relating to an identified or identifiable natural person; this comprises, for example, names or identification numbers.

Collection and use of your data

Automated data collection

When you access our website, your device will automatically transmit data for technical reasons. These data will be stored separately from other data that you may transmit to us:

• date and time of the access,
• browser type/version,
• operating system used,
• URL of the previously visited website,
• IP address (truncated by one octet)

This data is stored exclusively for technical reasons and will never be assigned to any specific person.

Support requests

If you contact our support, we will collect and store the personal data transmitted by you for the purpose of processing your request. You are not obligated to provide personal data in your request, and you may contact us with a pseudonym at any time.

We will store your support requests for a period of 3 years from completion of your request, in order to ensure that your request has been successfully processed, and to enable us to understand which problems may have occurred in the past in the event of subsequent requests that may help with solving your request.

We collect and process your data in order to answer your support request and in order to ensure defectfree operation of our product for you, Article 6 (1) point (b) GDPR. If you contact us independently of a specific support request or a technical issue, we will collect and process your personal data based on our legitimate interest in being able to answer email queries and due to the fact that your interests are not overriding, Article 6 (1) point (f) GDPR.

Cookies

We store so-called "cookies" to offer you all features of our website, and to make the use of our websites more convenient. Cookies are small files that are stored on your computer using your internet browser. If you do not want cookies to be used, you can prevent storage of cookies on your device by making the corresponding settings in your internet browser. Please note that the scope of features of our website may be restricted due to this.

We specifically use the following cookies:

• A cookie that represents your “logged in” status, which allows access to certain areas of our website that are not supposed to be accessible by the general public;
• a cookie from Google AdWords (doubleclick.net) to measure success of AdWords ads;
• two cookies from Google Analytics for statistical evaluation of the use of the website and for improvement of our offer;
• cookie to record whether you have already confirmed the cookie notice with OK;
• a cookie to determine whether the non-standard fonts that are used on the website have been loaded.

These cookies cannot identify you as a person. In any case, use of cookies is justified based on our legitimate interest in demand-oriented design, as well as statistical evaluation of our website, and the fact that your legitimate interests are not overriding, Article 6 (1) point (f) GDPR.

Amazon

We use Amazon as our hosting service provider. Their privacy policy can be found here:

https://aws.amazon.com/privacy/?nc1=f_pr

Google Analytics

We use "Google Analytics", a web analysis service of Google LLC ("Google"). Google Analytics uses socalled "cookies", i.e. text files that are stored on your end device, and that permit analysis of your use of the website. The information regarding your use of the website (including your abbreviated IP address) is transferred to and stored on servers of Google in the United States of America. Google will use this information to evaluate your use of the website, in order to compile reports on the website activities for

the website operators, and to provide further services connected to the use of our website and the internet. Google will also transfer this information to third parties if this is required by law or to the extent that third parties process these data on behalf of Google.

For more information on how Google uses your data, see Google’s Privacy Policy:

https://www.google.com/policies/privacy/.

The data stored at Google Analytics are stored for a period of fourteen (14) months. After the end of this time, Google Analytics will only store aggregated statistics.

You can deactivate Google Analytics with a browser add-on if you do not accept website analysis. You can download such add-on here: http://tools.google.com/dlpage/gaoptout.

You can also deactivate recording by Google Analytics by clicking here.

Google Analytics is used based on our legitimate interest in demand-oriented design, statistical evaluation and efficient marketing of our website, and the fact that your legitimate interests are not overriding, Article 6 (1) point (f) GDPR.

Google reCAPTCHA

Based on our legitimate interest in the prevention of spam and abuse, we also use the reCAPTCHA feature of Google. This function is primarily used to distinguish whether an input is made by a natural person or abusive by automated processing. The service includes the sending of the IP address and other data required by Google for the reCAPTCHA service to Google.

Additional information about Google reCAPTCHA and Google’s privacy policy can be found at:

https://policies.google.com/privacy.

Stripe

We use the services of Stripe Inc. for our payment process. For this purpose, we will transfer your data to Stripe. Further information can be found in Stripe's privacy policy at https://stripe.com/at/privacy.

Transfer of data

In principle, your personal data will only be passed on without your explicit prior consent in the following cases:

If necessary, to investigate illegal use of our services, or for prosecution, personal data will be passed on to the law-enforcement authorities and potentially to harmed third parties. However, this will only be the case if there are any specific indications of illegal or abusive behavior. Data may also be passed on if this serves to enforce terms and conditions of use or other agreements. We are also legally required to provide information to certain public bodies on request. These are law-enforcement authorities, public authorities that pursue administrative offences subject to fines and the tax authorities.

These data are passed on based on our legitimate interest in fighting abuse, prosecuting criminal offences and the securing, assertion, and enforcement of claims and that your rights and interests in protection of your personal data are not overriding, Article 6 (1) point (f) GDPR or based on a legal obligation in accordance with Article 6 (1) point (c) GDPR.

We depend on contractually bound third-party companies and external service providers for rendering our services ("Data Processors"). In such cases, personal data will be passed on to such Data Processors in order to permit further processing by them. We select our Data Processors with care and review them at regular intervals to ensure that your rights and freedoms are respected. The Data Processors must only use the data for the purposes specified by us and are furthermore contractually obligated by us to treat your data only in accordance with this Privacy Policy, and the applicable data protection laws.

In detail, we use the following Data Processors:

• Google LLC (Google Analytics, Google AdWords, reCAPTCHA v3)

Data is passed on to Processors based on Article 28 (1) GDPR, alternatively based on our legitimate interest in economic and technical advantages connected to the use of specialized processors, and the fact that your rights and interests in protection of your personal data are not overriding, Article 6 (1) point (f) GDPR.

We also process your data in states outside of the European Economic Area ("EEA").

For the USA, the European Commission resolved by its decision dated 12 July 2016 that there is an adequate level of data protection under the provisions of the EU-U.S. Privacy Shield (adequacy decision, Article 45 GDPR). We use the following service providers that are certified under the EU-U.S. Privacy

Shield:

• Google LLC

Within the scope of further development of our business, the structure of Placeholder EOOD may be changed by amending the legal form or by founding, purchasing, or selling subsidiaries, company parts or components. In such transactions, the customer information will be passed on together with the part of the company to be transferred. Every time personal data is transferred to third parties in the scope described above, we will ensure that this is effected in compliance with this Privacy Policy and the relevant data protection laws.

Any passing on of the personal data is justified by our legitimate interest in adjusting our corporate form to the economic and legal conditions if required and by the fact that your rights and interests in protection of your personal data are not overriding, Article 6 (1) point (f) GDPR

Change of purposes

Processing of your personal data for any other purposes than those described shall only take place to the extent that this is permitted by law, or if you have consented to the changed purpose of the processing activities. In case of further processing for other purposes than those for which the data was initially collected, we will inform you about such other purposes before further processing and provide you with all other information relevant for such.

Erasure of your data

We erase or anonymize your personal data as soon as we no longer need them for the purposes for which we have collected or used them according to the above items. As a rule, we store your personal data for the duration of the usage or contractual relationship concerning the website, plus a period of sixty (60) days in which we keep backup copies after erasure. In particular, we will erase your data after the periods described below in the following cases:

• Google Analytics: 14 months.

After the end of these period, the data will be deleted, except if the data is needed for a longer period due to statutory archiving periods, for criminal prosecution or to secure, assert or enforce legal claims. In such a case, the data will be blocked and is no longer available for further use.

Automated individual decision-making or measures for profiling

We do not use any automated processing processes to procure a decision, including profiling.

Your rights as data subject

Right of access

Upon request, you have the right to obtain from us at any time access to information on the personal data concerning you that are processed by us at the scope of Article 15 GDPR. For this purpose, you can send your request to the above address by mail or email.

Right to rectification of inaccurate data

You have the right to obtain from us without undue delay the rectification of the personal data concerning you if they are inaccurate. For this purpose, please contact the addresses named above.

Right to erasure

You have the right to obtain from us the erasure of the personal data concerning you under the prerequisites described in Article 17 GDPR. These prerequisites specifically stipulate an erasure right if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, and in cases of unlawful processing, upon objection or where there is an erasure obligation under European law or the law of the member state to which we are subject. In order to assert your above right, please contact the above addresses.

Right to restriction of processing

You have the right to request restriction of processing as contemplated by Article 18 GDPR. This right applies in particular when the accuracy of the personal data is disputed between the user and us, for the duration required to verify the accuracy, and if the user demands restricted processing instead of erasure if there is a right to erasure; furthermore, this right shall apply if the data is no longer required for the purposes pursued by us, but the user still needs them to establish, exercise or defend legal claims as well as if the successful exercise of the right to object is still disputed between us and the user.

In order to assert your above right, please contact the above addresses.

Right to data portability

You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, machine-readable format as contemplated by Article 20 GDPR. In order to assert your above right, please contact the above addresses.

Right to object

You have the right to object on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based, inter alia, on points (e) or (f) of Article 6 (1) GDPR, as contemplated by Article 21 GDPR. We shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Right to lodge a complaint

You have the right to lodge a complaint with the competent supervisory authority. The competent supervisory authority is:

Commission for Personal Data Protection (CPDP)
Address: Sofia 1592, 2 Prof. Tsvetan Lazarov blvd.
E-mail: kzld@cpdp.bg
Website: www.cpdp.bg