POLICY FOR PROCESSING AND PROTECTION OF PERSONAL DATA OF MODULARITY BULGARIA LTD („МОДЮЛЯРИТИ БЪЛГАРИЯ“ ООД), UIC 206225963

In force from 01.01.2021

1. What is personal data?

Personal data is information that directly or indirectly identifies you as an individual, indirectly when combined with other information such as your name, postal address, e-mail address, telephone number and others alike.

2. How we process your personal data?

"Modularity Bulgaria" Ltd. will use your personal data for the purposes of fulfilling the contract for the provision of services through our website (modularity.bg), to which you are a party, when you send a requests to our site, you register in order to use all available and provided free of charge functionality with or without a connection with an existing other commercial relationship.

We do not collect or process more or other types of personal data than we need to accomplish this purpose. The data you provide and the information you provide in the request only reaches the employee responsible for accepting requests and inquiries.

We will only use personal data as set out in this policy, unless you have given us your explicit consent to another use of your personal data, such as through an explicit statement of consent to send marketing messages.

3. What personal data do we process??

In order to fulfill our obligations to you under our contract for the provision of services, cited above, we will process the following categories of your personal data:

(1) names;

(2) Email addresses;

(3) Contact phone number;

(4) E-mail address to already created accounts in other service providers, where the collection and processing of data is carried out according to their policies and rules for personal data protection/p>

The listed categories of personal data are only those that you provide to us when making a request. We will not ask you for any other personal data other than that for the performance of the service contract.

We may be required to process and store personal data on legal grounds and to achieve regulatory compliance, such as to prevent, establish or investigate a crime, prevent loss, fraud or other financial misconduct.

4. Using the Home Page:

This Privacy Policy also applies to your use of our website with the following mechanics and features related to the protection of personal data.

(1) „Cookies“: Our Website uses cookies and other technologies to improve the user's work and the functioning of the Website, the ease of use and security, as well as for the purposes of research related to advertising effectiveness. Please see our cookie policy for more details.

(2) Third Party Websites: For the convenience of our visitors, this portal may contain links to various websites that are not linked, controlled or managed by us. The policies and procedures we describe here do not apply to these websites. We are not responsible for the security or protection of any data collected by these third parties. We encourage you to contact these websites directly for information on their data protection policies.

5. To whom we share your personal data:

We will disclose your personal data only for the purposes and only to those third parties listed below - unless we have obtained from you additional consent for the transfer of personal data to other categories of third parties given elsewhere, such as by declaration of consent for a specific purpose. We will take appropriate measures to ensure that your personal data is processed, protected and transferred in accordance with applicable law.

(1) External service providers:

When necessary, we engage other companies and individuals to perform on our behalf certain tasks that complement our services, such as supply companies - postal operators, freight forwarding companies and others alike. We will share or give access to such information to external service providers only to the extent necessary for the respective purposes. This information may not be used by them for any other purpose, in particular for their own purposes or for the purposes of third parties. External suppliers are obliged by contract with us to respect the confidentiality of your personal data.

(2) Public authorities:

We will disclose your personal data to public authorities when required by law. For example, we will grant requests from courts, administrative and other public state or municipal bodies, which may include similar state or municipal authorities. We do not transmit your personal data or any information that may concern you outside the territory of the Republic of Bulgaria.

6. Processing of children's personal data:

We do not collect or process personal data of children under the age of 18, except with the consent of a parent or guardian in accordance with applicable local law. If we learn that a child's personal data has been accidentally collected, we will delete the data in question in a timely manner.

7. Processing of special categories of personal data ("sensitive" data):

We do not collect or process the so-called special categories of personal data, namely: personal data revealing racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the sole purpose of identifying an individual, data on the health condition or data on the sexual life or sexual orientation of the individual.

8. Security of your data:

We take the security of your personal information seriously. We apply the appropriate level of protection and to this end have developed reasonable physical, electronic and technical procedures to protect the data we collect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to transmitted, stored or otherwise processed personal data. Access to your personal data is allowed only to those employees, service providers or persons related to us on the principle of need for information for official purposes or who need it to perform their official duties. In the event of a leak of data containing personal data, we will follow all applicable notification rules in such cases.

9. What are your legal rights?

As a data subject, you have specific legal rights related to the personal data we collect from you. This applies to all processing activities that we carry out and undertake with your personal data and which are listed above. We respect your individual rights and will answer your questions adequately.

The list that follows contains information about your rights arising from the applicable data protection laws:

• Right of correction: You have the right to correct personal data concerning you. We make reasonable efforts to ensure that the personal data at our disposal and under our control, which is regularly processed, is accurate, complete, up-to-date and relevant, based on the latest information available to us.
• Right of restriction: You have the right to restrict the processing of your personal data if:
  
  • 1. dispute the accuracy of your personal data for the period we need to verify their accuracy;
  • 2. the processing is illegal and you request a restriction on the processing instead of deleting your personal data;
  • 3. we no longer need your personal data, but you require it for the establishment, exercise or protection of rights and legitimate interests;
  • 4. objections to the processing pending verification that our legal grounds take precedence over yours;
• Right of access: You have the right to ask us for information about the personal data we hold about you, including information about what categories of personal data we hold or control, what they are used for, where we received them, if not directly from you, and to whom they were disclosed, if applicable. You have the right to a free copy of the personal data we hold about you. Under current law, we reserve the right to charge a reasonable fee for any additional copy after the first one you may request.
• Right of portability: At your request, we will transfer your personal data to another controller, where this is technically feasible, provided that the processing is based on your consent or contractual obligation. Instead of receiving a copy of your personal information, you may request that we transfer it directly to another administrator you specify.
• Right of deletion: You have the right to delete your personal data if:
  
  • 1. personal data are no longer needed for the purposes for which they were collected or otherwise processed;
  • 2. you have the right to object to the further processing of your personal data (see below) and exercise this right to object to the processing;
  • 3. processing is based on your consent, you withdraw this consent and there is no other legal basis for the processing;
  • 4. personal data have been processed illegally;
  • 5. unless processing is necessary for the following reasons:
  • 6. to comply with a legal obligation that requires processing by us;
  • 7. in particular, for archiving purposes in the public interest;
  • 8. for the establishment, exercise or protection of rights and legitimate interests.
• Right of objection: You may object at any time to the processing of your personal data in connection with your specific situation, provided that the processing is not based on your consent, but on our legitimate interests or those of a third party. In such a case, we terminate the processing of your personal data, unless we prove that there are compelling legal grounds that take precedence over your interests, or for the establishment, exercise or protection of legal claims. If you object to the processing, please specify whether you wish to delete your personal data or restrict the processing by us.
• Right to appeal: In the event of an alleged breach of applicable data protection laws, you may lodge a complaint with the Data Protection Supervisor in your country of residence or at the place of the alleged breach. In the Republic of Bulgaria this body is:

Additional information needed to exercise your rights:

Deadline: We will try to comply with your request to exercise rights or request information from us concerning your personal data within 30 days, and this period may be extended for specific reasons related to the specific legal right, or due to the complexity of your request.

Restricting access: In certain situations, we may not be able to give you access to all or part of your personal information due to legal provisions. If we deny your request for access, we will notify you of the reason for that denial.

Impossibility of identification: In some cases, we may not be able to verify your personal data based on the identifiers provided in your request. In such cases, when we cannot identify you as a data subject, we do not have the objective opportunity to comply with your request to exercise your legal rights as set out in this section, unless you provide us with additional information that would allow us to We identify you.

Exercising your legal rights: To exercise your legal rights, please contact us at the addresses listed at the end of this policy.

10. Storage of your personal data:

In general, we store personal data that you have provided for the purposes of the contract, while we need to implement, and in the long term, to the extent required by applicable regulations governing the requirements for accounting and control of money flow.

11. Changes in current policy:

We reserve the right to change our data protection practices and to update and amend this policy at any time. For this reason, we invite you to consult the policy regularly. This data protection policy is current as of the date of "last revision", which is indicated at the top of this page.

12. Contact data:

The data collector is: "Modularity Bulgaria" Ltd. („МОДЮЛЯРИТИ БЪЛГАРИЯ“ ООД), EIC 206225963, with registered office and address of management Republic of Bulgaria, Sofia, Ovcha Kupel district, residential complex Ovcha Kupel 1, building #610, entrance “G”, Floor 7, apartment 21, represented by Simeon Vladimirov Banov and Daniel Ivanov Yonkov.

Please send your inquiries regarding data protection and any requests regarding the exercise of your legal rights to the email specified on the site.