This Personal Data Protection Policy is issued in accordance with the requirements of applicable Bulgarian and European legislation on personal data protection (including the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), or “Regulation” for short).
The Buddy Guard Policy contains the rules according to which Buddy Guard processes your personal data as a natural person — User of the Platform — and your rights regarding the protection of your personal data.
It is an integral part of the General Terms of Use of the Buddy Guard Platform.
Unless otherwise provided in this Policy, the definitions used have the meaning given in the General Terms.
Buddy Guard reserves the right to make periodic changes to the Policy at its discretion, of which you will be notified by publishing the change on the Platform website. Since the Platform may only be used in accordance with the current General Terms, including the Policy attached to them, if you do not agree with the changes in the Policy, you must notify Buddy Guard before the changes take effect that you wish to terminate your contract with Buddy Guard. In that case your profile will be closed and you must cease use of the Platform and the Services provided through it.
In connection with use of the Platform or the Services provided through it, insofar as you are a natural person — User of the Platform, Buddy Guard, as controller of personal data, processes your personal data in your capacity as data subject.
In processing them Buddy Guard acts in accordance with this Policy and in compliance with all applicable normative acts on personal data protection relevant to its activities, including the PDPA and the Regulation.
Controller details:
Name: Buddy Guard Bulgaria Ltd.,
UIC: 206679605,
Registered office and management address: Sofia, postal code 1504, Oborishte St. No. 24, entrance A, floor 1, apt. 3, Bulgaria
Contact person: Kristina Vodenicharova
According to the Regulation, personal data is any information relating to you as a natural person by which you can be identified, and processing of your personal data is any operation or set of operations which may be performed on your personal data by automated or other means (e.g. collection and storage of personal data, processing, sending to third parties, etc.).
The purposes for which Buddy Guard may process your personal data are:
This includes processing of your personal data for taking the necessary steps to conclude and perform the contract between you and Buddy Guard, including registration and profile creation, respectively closure, deactivation or blocking of profile, identification for login to the Platform, as well as other activities related to use of the Platform functionalities available via the website (www.buddyguard.bg) and the mobile application (Buddy Guard), and communication with Buddy Guard in connection therewith. For this purpose Buddy Guard may process all categories of data listed below or part of them
This includes processing of your personal data for the protection or application of the legitimate interests of Buddy Guard, other Users of the Platform or third parties, including ensuring normal operation and use of the Platform by you and by other Users, detecting and resolving technical or functional problems, identifying and preventing unlawful actions and remedying their consequences, resolving disputes, protecting the rights and lawful interests of Buddy Guard, including in court and out of court, and providing assistance in exercising and protecting the rights and lawful interests of other Users of the Platform or affected third parties, processing received inquiries, requests, signals, complaints or other correspondence to Buddy Guard (including by telephone or email), as well as other activities related to the protection or application of the legitimate interests of Buddy Guard, other Users of the Platform or third parties and communication with Buddy Guard in connection therewith. For this purpose Buddy Guard may process all categories of data listed below or part of them.
This includes processing of your personal data for the performance of Buddy Guard’s legal obligations, including providing information to competent public authorities, ensuring the possibility for competent public authorities to exercise supervisory powers, notifying you by Buddy Guard in connection with legally significant circumstances related to your rights (including in connection with use of the Platform and processing of your personal data), as well as other activities related to Buddy Guard’s legal obligations and communication with Buddy Guard in connection therewith. For this purpose Buddy Guard may process all categories of data listed below or part of them.
This includes processing of your personal data in view of your express consent. For this purpose Buddy Guard may process your personal data to the extent and scope provided in your consent, insofar as there is no other valid ground for processing.
Buddy Guard may process your personal data from the following categories; their scope may vary depending on which group of data subjects you fall into:
Personal data related to identification of your identity: first name, middle name, family name, date of birth, age, personal identification number, ID card number or foreigner number, permanent address, current address, biometric data stated in an identity document (photo, eye colour, height), signature. Personal data related to contacting you: phone number, email address, permanent address, current address.
Personal data related to financial transactions by you or to you: first name, middle name, family name, IBAN/bank account number, bank card number, security code
Personal data related to the technical functionalities of the Platform you use: IP address, profile identification number, profile name, profile photo, Request numbers in which you are a party, location/location, logs evidencing registration, confirmation of your profile and provision of your consent to the General Terms (date, time, IP address), logs related to login to your profile, server/system logs, security device logs, electronic statement logs (sender email address, recipient identification, statement number) and other similar, related to ensuring reliable operation of the Platform, identifying and resolving technical problems, ensuring security of the Platform and its Users and detecting malicious actions (date and time, IP address, URL, information on the internet browser and technical device used).
Video images accidentally captured during real-time video surveillance. Video footage is not stored or otherwise processed by Buddy Guard or a third party
Other personal data provided by you.
Cookies used in connection with the operation of the Platform.
In the forms through which you enter your personal data in the Platform it is clearly indicated which of them you must provide mandatorily in order to use the Platform and which are voluntary and you may provide at your discretion. Data whose provision is mandatory is such without which Buddy Guard cannot provide you with use of the Platform or part of it.
Buddy Guard does not require you to provide special categories of personal data/sensitive personal data and does not process such data in connection with use of the Platform by its Users.
Such may include: data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, your genetic or biometric data, data concerning your health, data concerning your sex life or sexual orientation, data relating to your criminal record and others.
In connection with use of the Platform you undertake not to store, and not to provide through the Platform in any form, information containing special categories of personal data/sensitive personal data. Disclosure of such information is entirely at your risk and responsibility in view of possible breaches.
Buddy Guard is not obliged to monitor for the presence of special categories of personal data/sensitive personal data on the Platform which you may have voluntarily disclosed, nor to guarantee their protection against unlawful processing.
Buddy Guard may process your personal data if you are a natural person and fall into one of the following categories of data subjects:
users of the Platform registered as a Client;
users of the Platform registered as a Sitter;
users of the Platform without registration; including persons who have sent inquiries, requests, signals, complaints or other correspondence to Buddy Guard (including by telephone or email);
persons whose information is contained in an inquiry, request, signal, complaint or other correspondence to Buddy Guard (including by telephone or email) made by another person.
Your personal data as a user of the Platform or mobile application without registration are stored for a period of 1 year.
Your personal data as a User of the Platform with a registered user profile are stored for at least 5 years after termination of contractual relations with Buddy Guard, by notification or deletion of your profile.
Buddy Guard does not disclose your personal data to third parties except in the cases and under the conditions described in this Policy or provided by law. Under this Policy Buddy Guard may disclose your personal data to third parties only if:
this is provided by law;
a request has been made by a competent public authority;
you have given your express consent;
when this is necessary in view of protecting the rights and lawful interests of Buddy Guard, other Users of the Platform or third parties.
Accordingly, in connection with the operation of the Platform Buddy Guard uses subcontractors and service providers such as lawyers, insurers, payment service providers, consultants, accountants, technical specialists, etc., to whom access to your personal data processed by Buddy Guard may be provided when necessary. With regard to processing of your personal data and their protection, in working with subcontractors and service providers Buddy Guard requires them to strictly comply with the rules set out in this Policy.
Insofar as this Policy regulates storage and processing of your personal data by Buddy Guard as controller, processing of personal data by other persons in their capacity as controllers shall be governed by the rules established by them, agreed between you or established by law.
Buddy Guard applies appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction or damage.
As a data subject you have certain rights related to their protection, including:
Right to information on processing of your personal data, including whether, how, why, for how long and by whom your personal data are processed, and what rights you have regarding their protection. This Policy aims to provide information on processing of your personal data by Buddy Guard in connection with use of the Platform.
Right of access to your personal data processed by Buddy Guard, including confirmation of whether Buddy Guard processes your personal data, on what basis and to what extent, and ensuring the possibility to exercise your rights in connection therewith. You may exercise such access yourself at any time through the functionalities provided in your profile or by sending an express request to the Data Protection Officer of Buddy Guard.
Right to request rectification of your personal data if they are incomplete or inaccurate. You may do this yourself at any time through the functionalities provided in your profile or by sending an express request to the Data Protection Officer of Buddy Guard.
Right to request erasure of all or part of your personal data except where there is another ground for processing (e.g. Buddy Guard has a legal obligation to store your personal data for a certain period). You may do this yourself at any time through the functionalities provided in your profile or by sending an express request to the Data Protection Officer of Buddy Guard. Erasure applies only to personal data stored on the Platform.
Right to restriction of processing of your personal data in cases provided by law. You may do this by sending an express request to the Data Protection Officer of Buddy Guard.
Right to notification of third parties to whom Buddy Guard has disclosed your personal data where a subsequent request is made by you for rectification, erasure or restriction of processing of your personal data. You may do this by sending an express request to the Data Protection Officer of Buddy Guard.
Right to data portability by receiving your data in a structured, commonly used, machine-readable format and possibly subsequent use of personal data by another controller at your discretion. You may do this by sending an express request to the Data Protection Officer of Buddy Guard.
Right not to be subject to a decision based solely on automated processing of personal data, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where the grounds provided for in applicable data protection legislation apply and appropriate safeguards exist for your rights, freedoms and legitimate interests. In this regard Buddy Guard does not use technologies for automated processing of your personal data.
Right to withdraw consent you have given for processing of your personal data. Withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal, nor further processing of your personal data if another valid ground for processing exists. You may do this by sending an express request to the Data Protection Officer of Buddy Guard. This may lead to cessation of the Services provided by Buddy Guard.
Right to object to processing of your personal data on the basis of legitimate interest. You may do this by sending an express and reasoned request to the Data Protection Officer of Buddy Guard.
Right to lodge a complaint with a supervisory authority where you consider that processing of your personal data is in breach of applicable data protection legislation. You may do this yourself by lodging a complaint with the Commission for Personal Data Protection, the competent supervisory authority in the Republic of Bulgaria, at: Sofia 1592, Prof. Tsvetan Lazarov Blvd. No. 2, Bulgaria.
For any questions regarding your personal data and exercise of your rights related to their protection, please contact the data protection officer of Buddy Guard:
Address: Sofia, postal code 1504, Oborishte St. No. 24, entrance A, floor 1
Phone: +359877882308
Email: [email protected]
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