Privacy Policy

1. Data Subject is a natural person about whom PROFI DEVELOPMENT LTD. has got information or data enabling to identify the natural person. Data Subjects are, for example, the Clients, Visitors, and cooperation partners, as well as the employees who are natural persons and whose personal data are held by PROFI DEVELOPMENT LTD..

2. Privacy Policy is this text which sets out the principles for Personal Data Processing by PROFI DEVELOPMENT LTD..

3. Personal Data is any information concerning an identified or identifiable natural person.

4. Personal Data Processing is any operation or set of operations which is performed on the Personal Data of a Data Subject, such as collection, recording, organization, structuring, storage, alteration, and disclosure, enabling access to, retrieval, consultation, use, transmission, cross-checks, alignment or combination, restriction, erasure or destruction of Personal Data, irrespective of the manner of performing these operations or the means exploited.

5. Client is any natural or legal person that uses or has expressed a desire to use the Services of PROFI DEVELOPMENT LTD..

6. Agreement is the Service Agreement or any other agreement entered into between PROFI DEVELOPMENT LTD. and the Client.

7. General Terms and Conditions set forth the general terms and conditions applied to the entry into an Agreement with PROFI DEVELOPMENT LTD..

9. Services are any services and products offered by PROFI DEVELOPMENT LTD..

10. Cookies are the datafiles sometimes recorded in the device of a Visitor of the Website.

11. Person responsible for data protection is the person who monitors the implementation of the Personal Data Processing principles at PROFI DEVELOPMENT LTD. and who can be contacted by the Data Subject in case of a complaint.

12. Sales Channels are the means used by PROFI DEVELOPMENT LTD. for communicating with a Data Subject, devices created for selling the goods and providing the services, including e-mail, telephone, public and social media, various chat lines, individualised and interactive advertisements, and other tools on the Websites and elsewhere.

The above words and expressions are used in the meanings set out above in the Privacy Policy in the communication between the parties.

General provisions

General Provisions tell you who the controller of Personal Data is and when the Privacy Policy applies.

1. PROFI DEVELOPMENT LTD. is the legal person PROFI DEVELOPMENT LTD. registry code BG207020993 registered address Bulgary, 9002 Varna,Rayno Popovych street 19

2. PROFI DEVELOPMENT LTD. may process Personal Data as:

• a controller, while determining the purposes and means of processing
• a processor in accordance with the instructions from the controller;
• a recipient to the extent to whom the Personal Data are transferred.

For more information about the cooperation partners used contact our Person responsible for data protection (see section Contact information).

3. This Privacy Policy of PROFI DEVELOPMENT LTD. constitutes an inseparable part of the Agreement and General Terms and Conditions entered into between PROFI DEVELOPMENT LTD. and the Client.

4. The Privacy Policy shall apply to the Data Subjects, and the rights and obligations set out in the Privacy Policy shall be followed by all the employees and cooperation partners of PROFI DEVELOPMENT LTD. who come into contact with the Personal Data that are in the possession of PROFI DEVELOPMENT LTD..

5. The Privacy Policy may supplement the privacy statements published on the Website or on the devices, and the Privacy Policy may also be amended and supplemented by the same.

Principles

Here you find the principles that are always followed by PROFI DEVELOPMENT LTD. while Processing your Personal Data.

6. The objective of PROFI DEVELOPMENT LTD. is to Process Personal Data responsibly, based on the best practice, with the aim of always being prepared to demonstrate the conformity of Personal Data Processing to the established purposes, and PROFI DEVELOPMENT LTD. shall always take into account the interests, rights, and freedoms of Data Subjects.

7. All the processes, guidelines, operations, and activities of PROFI DEVELOPMENT LTD. that are related to Personal Data Processing are based on the following principles:

• Lawfulness. There is always a legal basis for the processing of Personal Data, i.e. consent;
• Fairness. Personal Data Processing shall be fair while providing a Data Subject with sufficient information and communication on how the Personal Data is processed;
• Transparency. Personal Data Processing shall be transparent for the Data Subject. Data Subjects get information from the Privacy Policy and additional information can be acquired from the Person responsible for data protection (see section Contact Information).
• Purposefulness. Personal Data shall be collected for legitimate purposes that have been established precisely and clearly, and shall not later be processed in any manner which is in conflict with these purposes;
• Minimisation. Personal Data shall be adequate, relevant, and limited to what is necessary for the purpose of Processing the given Personal Data. PROFI DEVELOPMENT LTD. shall be guided by the principle of minimum Processing in Personal Data Processing, and as soon as the Personal Data are no longer necessary or are no longer needed for the purposes for which they were collected, the Personal Data shall be deleted;
• Accuracy. Personal Data shall be correct and shall be updated as necessary, and all reasonable measures shall be taken to ensure that Personal Data which are incorrect in the light of the purpose of Personal Data Processing shall be deleted or corrected without delay;
• Limit of storage. Personal Data shall be stored in the format enabling the identification of Data Subjects only as long as it is necessary to achieve the purpose for which the Personal Data is processed. It means that in case PROFI DEVELOPMENT LTD. wishes to store the Personal Data for a longer period of time than necessary for the purpose of collecting the data, PROFI DEVELOPMENT LTD. shall anonymise the data in such manner that the Data Subject shall no longer be identifiable. PROFI DEVELOPMENT LTD. shall store the data that have been received by PROFI DEVELOPMENT LTD. via a client relationship or any other similar relationship, in accordance with the best practice, and the data processed on the basis of consent generally for as long as the consent is withdrawn;
• Reliability and confidentiality. Personal Data Processing shall be carried out in the manner ensuring the adequate security of Personal Data, including their protection against unauthorised or unlawful Processing and against accidental loss, destruction or damage, by taking reasonable technical or organisational measures;
• Data protection by design and by default. PROFI DEVELOPMENT LTD. shall ensure that all the systems used shall meet the required technical criteria. The suitable data protection measures have been planned upon the renewal or design of every information or data system (e.g. the information systems and business processes are constructed using pseudonymisation and encryption).

8. Additional information regarding the conformity to these principles can be requested from the Person responsible for data protection.

Composition of Personal Data

Here you find information on how we collect Personal Data.

9. PROFI DEVELOPMENT LTD. collects or may collect, inter alia, the following types of Personal Data:

• the Personal Data disclosed to PROFI DEVELOPMENT LTD. by the Data Subject;
• the Personal Data generated as a result of the day-to-day communication between the Data Subject and PROFI DEVELOPMENT LTD.;
• the Personal Data manifestly made public by the Data Subject (e.g. in social media);
• the Personal Data generated upon consumption of Services;
• the Personal Data generated as a result of visiting and using the Website (e.g. the time spent on the Website);
• the Personal Data received from third persons;
• the Personal Data created and combined by PROFI DEVELOPMENT LTD. (in the context of a client relationship).

Composition, purpose, and bases for the processing of Personal Data

Here you find out for which purposes and under which bases we can process your Personal Data.

10. PROFI DEVELOPMENT LTD. shall Process Personal Data only on the basis of consent or on a legal basis. Legal bases for Processing of Personal Data include but are not limited to legitimate interests or an Agreement between the Data Subject and PROFI DEVELOPMENT LTD..

11. PROFI DEVELOPMENT LTD. shall Process Personal Data on the basis of consent precisely within the limits, to the extent, and for the purposes determined by the Data Subject. As for consents, PROFI DEVELOPMENT LTD. shall follow the principle that every consent shall be clearly distinguishable from other matters, in an intelligible and easily accessible form, using clear and plain language. Consent may be given in writing or by clear action (e.g. filling the contact form) or by other electronic means or as an oral statement. A Data Subject shall give the consent freely, specifically, informedly, and unambiguously, for example by ticking a box on the Website.

12. Upon entry into and performance of an Agreement, Personal Data Processing may be additionally provided for in the specific Agreement, but PROFI DEVELOPMENT LTD. may Process Personal Data for the following purposes:

• in order to take steps at the request of the Data Subject prior to entering into the Agreement;
• to identify the Client to the extent required by due diligence;
• to perform the obligations to the Client regarding the provision of its Services;
• to communicate with the Client;
• to ensure the performance of the payment obligation of the Client;
• to submit, realise and defend claims.

13. For the entry into an employment agreement, the Processing of the Personal Data of a job applicant by PROFI DEVELOPMENT LTD. based on the entry into the agreement and legitimate interest shall include:

• Processing of the data submitted by the job applicant to PROFI DEVELOPMENT LTD. for the purpose of entering into an employment agreement;
• Processing of the Personal Data received from the person indicated as the referee by the job applicant;
• Processing of the Personal Data collected from state databases and registers and public (social) media.

In case a job applicant is not selected, PROFI DEVELOPMENT LTD. shall store the Personal Data collected for entry into an employment contract for two years in order to make a job oer to the job applicant in case a suitable position becomes vacant. When two years have passed after the submission of a job application, the Personal Data of the job applicant who was not selected shall be deleted.

14. Legitimate interest means the interest of PROFI DEVELOPMENT LTD. in the management and direction of its business in order to be able to oer the best possible Services on the market. PROFI DEVELOPMENT LTD. shall Process Personal Data on a legal basis only after careful consideration in order to ascertain the legitimate interest of PROFI DEVELOPMENT LTD., based on which the Personal Data Processing is necessary and is in compliance with the interests and rights of a Data Subject (after carrying out the so-called three-step test). In particular, Personal Data Processing may take place on the basis of a legitimate interest for the following purposes:

• to start Client relations for example if data Subject has given PROFI DEVELOPMENT LTD. information via contact forms on the Website or by e-mail or other electronic forms, PROFI DEVELOPMENT LTD. process the information given for the reason the info was collected and PROFI DEVELOPMENT LTD. may contact the data Subject for giving related information;
• for ensuring a trust-based relationship with a client, for example, Personal Data Processing that is strictly necessary to determine the ultimate beneficiaries or to prevent fraud;
• for the administration and analysing the client base to improve the availability, selection, and quality of Services and products, and to make the best and more personalised offers to the Client upon the Client’s consent;
• for the identifiers and Personal Data collected upon the use of websites, mobile applications, and other Services. PROFI DEVELOPMENT LTD. shall use the collected data for web analysis or for the analysis of mobile and information society services, for ensuring and improving the functioning, for statistical purposes and for analysing the behavior and using the experience of Visitors, and for providing better and more personalised Services;
• for the organisation of campaigns, including organisation of personalised and targeted campaigns, carrying out Client and Visitor satisfaction surveys, and measuring the effectiveness of the performed marketing activities;
• for analysing the behavior of the Clients and Visitors in different Sales Channels and on Websites;
• for monitoring of the service. PROFI DEVELOPMENT LTD. may record the messages and instructions given in its premises as well as by means of communication (e-mail, telephone, etc.), as well as information and other operations carried out by PROFI DEVELOPMENT LTD., and shall use those recordings as needed to evidence instructions or other operations;
• for network, information, and cyber security considerations, for example for fighting against piracy and for ensuring the security of the Websites, as well as for the measures taken for making and storing backup copies;
• for corporate purposes, in particular for the financial management;
• for the establishment, exercise, or defense of legal claims.

15. For performing a legal obligation, PROFI DEVELOPMENT LTD. shall Process Personal Data to perform the obligations set forth by law or to exercise the uses permitted by law. Legal obligations derive, for example, from adhering to the rules of payment processing and prevention of money laundering.

16. In case Personal Data Processing is carried out for a new purpose, different from those for which the Personal Data was originally collected, or is not based on the consent given by the Data Subject, PROFI DEVELOPMENT LTD. shall carefully assess the permissibility of such new Processing. In order to determine whether the Processing for the new purpose is in compliance with the purpose for which the Personal Data was originally collected, PROFI DEVELOPMENT LTD. shall take into consideration, inter alia, the following:

• any link between the purposes for which the Personal Data were collected and the intended further purposes Processing;
• the context of collecting the Personal Data, in particular regarding the relationship between the Data Subject and PROFI DEVELOPMENT LTD.;
• the nature of the Personal Data, in particular, whether any special categories of Personal Data;
• possible consequences of the intended further processing for the Data Subjects;
• the existence of appropriate protection measures which may consist in, for example, encryption and pseudonymisation.

Disclosure and/or transfer of Client Data to Third Persons

Here you find information on when we may transfer your Personal Data to our cooperation partners.

17. PROFI DEVELOPMENT LTD. cooperates with persons, to whom PROFI DEVELOPMENT LTD. may transfer data regarding the Data Subjects, including their Personal Data, in the context and for the purposes of co-operation.

18. Such third persons may be the persons within the same group with PROFI DEVELOPMENT LTD., its advertising and marketing partners, companies carrying out client satisfaction surveys, debt collection agencies, credit registers, IT partners, persons, authorities, and organisations intermediating or providing (electronic) mail services, provided that:

• the respective purpose and the Processing are lawful;
• the Personal Data Processing is carried out in accordance with the guidelines of PROFI DEVELOPMENT LTD. and on the basis of a valid agreement;
• the data regarding the respective processors are disclosed to the Data Subjects (for information contact Person responsible for data protection).

19. PROFI DEVELOPMENT LTD. shall transfer Personal Data to outside the European Union only if there is sufficient protection in the respective country; if protection measures have been agreed upon (e.g. binding internal rules of the group or standard data protection clauses); the Data Subject has given clear and informed consent for such transfer; the transfer is clearly required by an agreement entered into with the Data Subject; the transfer is not repeated, it concerns only a limited number of Data Subjects; it is necessary for protecting the legitimate interests of PROFI DEVELOPMENT LTD. which are not overridden by the interests, rights or freedoms of the Data Subject, and if all the circumstances related to the transfer have been assessed and suitable protection measures have been established to protect the Personal Data, or if there is some other legal basis therefor. PROFI DEVELOPMENT LTD. shall inform the Data Protection Inspectorate of the transfer based on legitimate interest.

Security of Personal Data Processing

Here you find a description of how we will protect your Personal Data and where you can nd information on the storage periods of Personal Data.

20. PROFI DEVELOPMENT LTD. shall store Personal Data strictly only for the minimum period required. The Personal Data with an expired storage period shall be destructed or anonymized by PROFI DEVELOPMENT LTD. or the IT partne

21. PROFI DEVELOPMENT LTD. has established guidelines and procedural rules for ensuring the security of Personal Data by both organisational and technical measures. Further information on the security measures taken by PROFI DEVELOPMENT LTD. can be obtained also from the Person responsible for data protection at PROFI DEVELOPMENT LTD..

22. In case of an incident related to Personal Data, PROFI DEVELOPMENT LTD. shall take all necessary measures to mitigate the consequences and hedge any relevant risks in the future. Inter alia, PROFI DEVELOPMENT LTD. shall register all the incidents and shall inform the Data Protection Inspectorate and the Data Subject directly (e.g. by email) or in public (e.g. via the news) in prescribed cases.

Processing of the Personal Data of Children

The Services of PROFI DEVELOPMENT LTD. are not targeting Children.

23. The Services of PROFI DEVELOPMENT LTD. are not targeting Children.

24. PROFI DEVELOPMENT LTD. does not knowingly collect any information on persons under 13 years of age, i.e. Children, and in case of any respective informed activity we shall act on the basis of the requests of a parent or guardian (including consent to send products to the name of a Child).

25. In case PROFI DEVELOPMENT LTD. finds out that it has still collected Personal Data from a Child or regarding a Child, PROFI DEVELOPMENT LTD. shall use its best efforts to discontinue the Processing of the respective Personal Data.

Rights of Data Subjects

Your Personal Data belongs to you, and here you find information on the rights you have in protecting your Personal Data.

26. Rights related to consent:

• A Data Subject will always be entitled to inform PROFI DEVELOPMENT LTD. about his or her wish to withdraw the consent for the Personal Data Processing.
• You will be able to view, change and withdraw your consents given to PROFI DEVELOPMENT LTD. by contacting PROFI DEVELOPMENT LTD.. The contact details are set out in the section Contact Information of this Privacy Policy.

27. A Data Subject has also the following rights upon Personal Data Processing:

• Right to receive information i.e. the right of a Data Subject to receive information regarding the Personal Data collected about him or her. A Data Subject will be able to receive information from this Privacy Policy and by contacting the Person responsible for data protection at PROFI DEVELOPMENT LTD..
• Right of access to data which, inter alia, includes the right of a Data Subject to a copy of the Processed Personal Data.
• Right to rectification of inaccurate Personal Data. A Data Subject has the right to demand that the data would be updated and/or corrected by contacting the Person responsible for data protection at PROFI DEVELOPMENT LTD..
• Right to erasure of data i.e. in certain cases a Data Subject will be entitled to demand the deletion of Personal Data, for example, if the Processing is carried out only on the basis of consent.
• Right to demand restriction of Personal Data Processing. This right is created, inter alia, in case the Personal Data Processing is not permitted under law or if the Data Subject challenges the accuracy of the Personal Data. A Data Subject will be entitled to demand the restriction of the Personal Data Processing for a period enabling the processor to check the accuracy of the Personal Data or if the Personal Data Processing is unlawful but the Data Subject does not request the deletion of the Personal Data.
• Right to data portability i.e. a Data Subject shall have, in certain cases, the right to receive the Personal Data in a machine-readable format and to take these data along or transfer them to another controller.
• Rights related to automated Processing mean, inter alia, that a Data Subject will have the right to object, on grounds relating to his or her particular situation, at any time to processing of Personal Data concerning him or her, based on automated decision-making. For the avoidance of doubt – PROFI DEVELOPMENT LTD. may Process Personal Data for automated decision-making promoting its business (i.e. for segmentation of Visitors in the marketing context, and for sending them personalised messages, in the context of commencement of an employment relationship, and in order to ensure that our employees shall adhere to our internal security regulations). Automated Processing may include also data collected from public sources. You have the right to avoid any decisions based on automated Personal Data Processing if they can be classified as profiling;
• Right to the assessment of a supervisory authority on whether the Processing of the Personal Data of the Data Subject is lawful;
• Compensation for damage.

Exercising of rights and filing of complaints

Here you find information on how to receive explanations or how and to where a complaint should be filed.

28. Exercising of rights. A Data Subject will be entitled to address PROFI DEVELOPMENT LTD. or the Person responsible for data protection at PROFI DEVELOPMENT LTD. using the contact details set out in section Contact Information in case of any question, request, or complaint related to Personal Data Processing.

29. Filing of complaints. A Data Subject will be entitled to address a complaint to PROFI DEVELOPMENT LTD. and the Person responsible for data protection at PROFI DEVELOPMENT LTD., to the Data Protection Inspectorate, or to a court if the Data Subject is of the opinion that his or her rights have been infringed in Personal Data Processing. e contact details of the Data Protection Inspectorate are available on the website of the Data Protection Inspectorate: www.aki.ee.

Cookies and other web technologies

Here you find information on the types of Cookies or other technologies we use and how you can control the use of such technologies.

30. PROFI DEVELOPMENT LTD. may collect data regarding the Visitors of the Websites and other information society services by using Cookies for this purpose (i.e. small pieces of information stored by the Visitor’s browser on the hard disk of the computer of any other device of the Visitor) or other similar technologies (e.g. IP address, equipment information, location information) and process these data.

31. PROFI DEVELOPMENT LTD. uses the collected data to enable the provision of the Service in accordance with the habits of a Visitor or Client; to ensure the best service quality; to inform the Visitor and Client about the contents and give recommendations; to update advertisements and make marketing efforts more efficient, and to facilitate logging in and protection of data. The collected data shall also be used for counting the Visitors and recording their using habits.

32. PROFI DEVELOPMENT LTD. uses session Cookies, persistent Cookies, and advertising Cookies. A session cookie is deleted automatically after every visit; persistent Cookies shall remain upon repeated use of the Website, and advertising Cookies and third-party cookies are used by the Websites of the partners of PROFI DEVELOPMENT LTD. which are connected with the Website of PROFI DEVELOPMENT LTD.. PROFI DEVELOPMENT LTD. does not control the generation of those Cookies, therefore information on these Cookies can be obtained from third persons.

33. As to the Cookies, Visitors agree with the use of Cookies on the Website, in information society service devices, or the web browser.

34. Most web browsers allow Cookies. Without fully allowing Cookies, the functions of the Website are not available to a Visitor. The allowing or prohibiting Cookies and other similar technologies shall be under the control of a Visitor via the settings of the Visitor’s own web browser, settings of the information society service, and platforms for making such privacy more efficient.