Privacy Policy

Personal Data Protection Policy
According To Regulation 2016/679 (EU)
of Sokole - Imopoly Ltd.

What is the scope of application of this Personal Data Protection Policy? “SOKOLE – IMOPOLY” LTD., with headquarters in Varna and registered address: Varna, 60 '27 July' str., floor 1, UIC 103098666, acts as the controller of the personal data you provide and the information that is related to you and can identify you, and that we collect from and about you through the services of the company and within the scope of its activities. Such information ('Personal Data') is processed in accordance with the terms of this Personal Data Protection Policy. This Personal Data Protection Policy applies to all users, including those who use the services of the Company without being registered or subscribed for a service of the Company, as well as to those who have registered or subscribed for services of the Company. The services of the Company are not intended for persons under 16 years of age and personal data is not purposefully collected from such persons.

1. Which data is considered personal data? According to the applicable provisions of Regulation (EC) No 2016/679 (EU), personal data is defined as: ' any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person'.

2. What types of personal data do we collect? The Company collects:

A) Contact data: information you provide to register for a service of the Company, to create your profile, subscribe to a newsletter or to make an inquiry. The contact details may include - name, e-mail address, telephone number, permanent address, country;

B) Information required for and with regards to the conclusion of a contract with the company: The information required to conclude a contract is the one that consists of your identification data and serves to verify your identity when entering into a contractual relationship, which may include full name, personal identification number, details of your identity document, mailing address and permanent address, and certain categories of special data such as marital status;

C) Information which you have allowed the social media to share with the Company: If you access the company's services through social media services or connect a company service to a social media service, the information that the Company collects may also include user identification or a username associated with this social media service, any information or content that you have agreed to be shared by the social media service with us, including a profile photo, e-mail address, and any other data you have made available to the public in connection with such service;

D) details on the activity: when you access and interact with a company service: When you access and interact with the services of the Company, we can collect information about those visits. Cookies and other related technologies can also be used to collect and store information about your use of the Company's services, such as information on the pages you've visited, content you've viewed, search queries you've made, and ads you've seen, which information may include - an IP address; browser type, device data. For further information, please refer to our Cookies Policy.

The Company does not store in any way: financial information; information connected with sensitive personal data relating to origin; political, religious and other beliefs; Health status; conviction status; participation in trade unions and political organizations.

Related Services: The services of the Company may also be connected to websites managed by unrelated companies and may include advertisements or offer content, functionality or applications developed and maintained by unrelated companies. The Company is not responsible for the personal data protection practices of such unrelated companies.

3. How do we use your personal data? The data that the company collected from and for you is used for:

3.1. the provision of services by the company;

3.2. Assessment, analysis and improvement of the services of the company, according to your expectations and interests;

3.3. Increase of the level of your satisfaction while using the services of the Company and providing you with relevant and interesting content for you;

3.4. Offering quality customer service, communication with you and responding to inquiries;

3.5. Protecting and preserving the rights of the Company and in particular, there may be cases in which the company may disclose the data if such disclosure is necessary in order (i) to protect, exercise or preserve the legal rights, privacy, safety or ownership of the Company, its employees, intermediaries and contractual partners; (ii) to protect the Company against fraud, or (iii) for the purpose of risk management;

3.6. conducting negotiations and execution of the contractual relationship between the Company and you;

3.7. Compliance with the law or legal procedures and/ or execution of requests from public and governmental authorities;

3.8. Providing functionality for social media sharing, if you log in with or connect to a profile (account) for a social media service with the company services, we may share your user name, photo and likes, and your activity and comments with other users of the Company's services and your friends connected to the social media service you are using. We can also share this personal data with the social media service provider;

3.9. With your prior consent, we may send you (via email, SMS, phone, chat and social media) offers, promotions and other marketing communications related to the Company's services, related party and / or partner organizations services/ products in the field of real estate business, including companies of the 'SOKOLE - IMOPOLY' group and branded or co-branded services and features, conducted jointly with a partner organization or a related party;

3.10. With your prior consent we send you via email marketing notifications tailored to your individual interests and searches.

The Company may use anonymized information or information that no longer allows Users to be identified directly or indirectly as a specific individual for any purpose or for sharing with third parties.

4. On what grounds do we use your personal data? The processing of your personal data for the purposes of:

- Section 3: p.3.1. – pt. 3.5 of this Personal Data Protection Policy is carried out on the grounds of the legitimate interest of the company and is necessary for the provision of the services requested;

- Section 3: p.3.6. of this Personal Data Protection Policy is carried out on the grounds of a legal obligation of the company and is necessary for the observance of the applicable legislation;

- Section 3: p.3.7 of this Personal Data Protection Policy is carried out under a contract with the company and is necessary for entering into a contractual relationship with the company or, if the latter has already been concluded, for its implementation;

- Section 3: p.3.8. - p.3.10. of this Personal Data Protection Policy is carried out based on your consent and you have the right to withdraw your consent at any time without any consequences;

5. How do we process your personal data? Personal data shall be processed both by automatic means and by hand and shall be protected by appropriate security measures, taking into account the achievements of technical progress, the cost of implementation and the nature, scope, context and purpose of the processing. The Company introduces appropriate administrative, technical, personnel and physical measures to protect the personal data at its disposal from loss, theft and unauthorized use, disclosure or modification.

6. Who has access to your personal data? The Company may share your personal data for the purposes of Section 3 with the following categories of recipients within the European Union:

(A) Third-party service providers who are assigned processing activities and who are duly appointed as personal data processors, where this is required by the applicable law, providers of supporting or auxiliary services for the Company, and in this context persons providing IT services, experts, consultants, lawyers;

(B) Related persons in their capacity as data controllers or processors;

(C) Competent authorities in order to comply with the applicable law.

7. Is your personal data transferred abroad? Your personal data may be transmitted to countries within the European Economic Area. If the company performs such a transmission, the Company will use appropriate and adequate measures to protect the Data and transmit the Data in accordance with the applicable data protection laws.

8. What are your rights with respect to your personal data? According to the General Data Protection Regulation (EU) 2016/679, you are entitled at all times to:

- receive a confirmation whether your personal data exists, obtain a copy thereof and be informed of both its content and source, as well as the right to obtain additional information specified in this Personal Data Protection Policy regarding the purpose of processing of your personal data, the categories of recipients, the existence of any automated decision making (if any), the envisaged period for which the Company will store the data (wherever possible);

- verify the accuracy of your personal data and request its rectification, updating or modification;

- ask for deletion or anonymization of your personal data in the cases where:

• Data is processed in violation of the applicable law;
• The company no longer needs the data for the purposes for which it was collected;
• The Company has a legal obligation to delete it;
• You have objected to the processing based on a legitimate interest and there are no overriding and compelling legal grounds to continue such processing;

- ask the Company to restrict the processing of your personal data in cases where:

• You dispute the accuracy of the data until the Company has taken the necessary steps to rectify or verify its accuracy;
• The processing is unlawful, but you do not want the Company to delete the Data;
• The company no longer needs your personal data for the purpose of processing, but you require the data for the establishment, exercise or protection of legal claims; or
• you have objected to the processing based on a legitimate interest pending verification that the Company has compelling legal grounds to continue processing.

- object to the processing of the Data when it is based on a legitimate interest, including for marketing purposes;

- Require the deletion of the Data without undue delay;

- receive an electronic copy of the Data ('data portability') in cases where the Data is processed by automatic means and the processing is either (i) based on your consent, or (ii) necessary for the implementation of a contract with the Company; and

- file a complaint to the relevant supervisory authority.

You can send your request to the address below. In your request, please include an e-mail address, name, address, and phone number, and clearly state the information you want to receive, change, update, hide or delete. You should know that even after you remove your account or have requested erasure of your data, copies of certain information from your account may remain visible under certain circumstances, for example, if you have shared information with social media or other services, or where keeping such copies is necessary in order to comply with legal obligations or for legal protection. Due to the nature of the technology for information caching, your account may not become immediately unavailable to others. We may also keep on our servers archive information associated with your account for some time after the removal or request for deletion if this is required in order to comply with the applicable law. In addition, with regards to your personal data used by the Company for marketing purposes, you may choose at any time not to receive any direct marketing communications. If you no longer wish to receive emails from us for advertising and marketing purposes in the future, you can unsubscribe from receiving such emails by following the instructions for unsubscribing contained in our messages. You can also send a request to the address below. Sharing of your personal information by us with our Affiliates for their marketing purposes: If you would prefer your personal information not to be shared with our Affiliates in the future for their direct marketing purposes, you can opt out of such sharing by submitting a request to the address listed below in the Personal Data Protection Policy. In all of the above cases, we may contact you and ask you for further information in order to fulfill your request.

9. Period of retention of personal data: We will keep your personal data for the period necessary to meet the purposes for which the data was collected as described in this Personal Data Protection Policy. The following retention periods will apply to the processing of your personal data for the below purposes: The data collected for the purposes specified in Section 3, pt. 3.1. - 3.7 of this Personal Data Protection Policy is retained for the period of providing the company services and performance of the contractual relationship with the company, adding the duration of the limitation period under the applicable law after the termination of in the services or the implementation of the contract with the Company; Data collected for the purposes specified in Section 3, pt. 3.8 of this Personal Data Protection Policy is retained for the period necessary for the registration in the Company Service through the social media network; The data collected for the purposes set out in Section 3, pt 3.9 . – pt. 3.10. of this Personal Data Protection Policy is retained for a period of 24 months from the collection; At the end of the retention period your personal data will either be deleted, or anonymized or aggregated.

10. Updating this Personal Data Protection Policy The Company has the right to modify or update this Personal Data Protection Policy for any reason (including, but not limited to, changes in the applicable law and interpretations, instructions, decisions, opinions and orders related to such applicable legislation. Any changes to this Personal Data Protection Policy will be announced in advance by publishing them on the company's website.

11 . Contacts If you have any questions about this Personal Data Protection Policy, please contact us at the following e-mail address: office@imopolybg.com