Privacy policy

Introduction

By presenting these rules, we aim to explain to you what information we collect about you, why and how we do it, what are your rights under the Personal Data Protection Act (PDPA) and the General Regulation on Personal Data Protection (REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 - GDPR).

Why is your consent needed?

Our exclusive priority is to protect your personal data and to obtain your free, informed and unambiguous consent for the processing of your personal data. 

If you tick "I accept everything" you agree that you provide your personal data voluntarily, that you have read your rights under the LPPD and REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016-GDPR and give your consent to your personal data being collected, processed, stored and passed on to third parties for the purposes we have set out below.

 

Definitions

" Personal data" means any information relating to an identified or identifiable natural person ("data subject" or "user"); a person who can be identified is a person who can be identified, directly or indirectly, in particular by an identifier such as name, identification number, location data, online identifier or one or more features specific to the natural person, the physiological, genetic, mental and intellectual, economic, cultural or social identity of that individual;

' Administrator' means a body which alone or jointly with other authorities determines the purposes and means of the processing of personal data; when the purposes and means for this processing are determined by the law of the European Union or the law of the Republic of Bulgaria, the administrator or the special criteria for its determination may be established in the law of the European Union or in the Bulgarian legislation. In the present case the administrator is Devstudio.bg. 

' Processor of personal data' means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller;

" Processing" means any operation or set of operations carried out with personal data or a set of personal data by automatic or other means such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, consulting, using, disclosing, disseminating or otherwise providing access to data, arranging or combining, restricting, deleting or destroying;

" Supervisory authority" means an independent public body of a Member State of the European Union responsible for monitoring the application of data protection rules. For the Republic of Bulgaria, the supervisory body is the Commission for Personal Data Protection.

Policy objective


This privacy policy is intended to ensure that the Administrator:

complies with the data protection legislation, namely the Personal Data Protection Act (PDPA) and the General Regulation on Personal Data Protection and other applicable legislation, and follows good practices;
protects consumers, customers and partners;

ensures transparency about the ways in which the personal data of the subjects are stored and processed;

provides protection against the risks associated with data breaches;

How do we collect information about you?

We may collect information about you in several ways:

Filled in and sent by you forms related to the used services

By submitting them, you knowingly share personal information.

For each form containing the transmission of personal data, we will indicate the purposes of use, the period of their storage, third parties with whom we may share them, the ways to exercise your rights under the Regulation.

We will minimize the amount of data in the form compared to the announced goals.

Sometimes we collect information about you by observing your behavior on our sites and in our mobile applications.

For this purpose, we use standard Internet approaches for tracking user behavior, e.g. network equipment, for tracking your IP address, HTTP GET / POST protocols for recording and exchanging identifiers of you and your device.

Data received from third parties

Sometimes, after your explicit consent given through the partner tools, we may receive data from third parties, e.g. data from your social media account, such as Facebook.

This data may be combined with other personal data about you that we already have.

Using various online analysis tools, we can obtain detailed but aggregated data about the audience of our sites. This is not personal data within the meaning of the Regulation.

What information do we collect and process when you use our services?

Forms filled in and sent by you

We may collect a variety of personal information, depending on the purpose of the form and our arrangements with advertising partners.

Typically, we collect the following data:

Your names;
Username;
Password;
E-mail address;
City;

Data collected through observations

For all visitors, we and the providers of the tools we use, usually collect the following data about you:

The IP address from which you make the visit;
Your browser ID;
Identifier of your mobile device;
Non-personal data Your identifier;
History of your behavior - pages visited, time spent on them, purchased products and others;
Behavior towards the content of the site - navigation, used interface elements, downtime;
Your searches;
Behavior towards your served ads - what and how many ads are served; where they are served; seen ads; clicks, missed ads, and more;
Your comments.
For logged-in users, in addition to the above data, we also collect identifiers that associate them with the specific user profile.

Data received from third parties

Depending on the data source, this includes:

Basic account information, such as name, email address, date of birth;
Details you choose to share according to your specific social media account settings;
Your contacts and how you connect with them.
For what purposes do we process the information?
The information we collect and process about you may be used for the following purposes:

Normal functioning of our sites

This data is strictly necessary for the normal operation of our sites and mobile applications. Through them we can verify your identity as logged in users, show you better content, load the site faster, protect sites and you from intrusion.

Such data are, for example, the data from your session - information whether you are logged in, cached content and others.

This includes the data related to your identification in connection with the registration for the use of our service.

For contractual performance of our services

Some of our services, such as e-commerce, require you to share personal information with us. We use them so that we can fulfill our contract with you, for the sale and delivery of the goods we offer.

Other services we offer are the ability to add recipes. We use your personal data, which allows us to identify you and, if necessary - to moderate the content you add.

This includes the data related to the identification of the user in connection with the registration for the use of our service.

To save and access information

This goal is ancillary to other goals - by using various technical mechanisms, we will be able to achieve any of the other goals described.

Includes storing and accessing information stored on your device, e.g. device identifiers, user identifiers, ad identifiers, cookies and other technologies.

This goal is helpful - by using the technical mechanisms described in it, we will be able to fulfill any of the other goals described.

For customization and profiling

We collect and process information about the use of our services for the subsequent serving of personalized advertising and / or content in another context, e.g. other sites and mobile applications over time.

Typically, your site content and behavior is used to draw conclusions about your interests that govern the future choice of ads and / or content served.

The goals we pursue are: to provide a better experience for users of the site by displaying relevant ads.

For selection, delivery and reporting of served ads

We offer free access to our users in our websites and mobile applications. In order to provide funding for our business, we offer advertising to our customers.

It is known that the offering of advertisements and the related collection of data on consumer behavior and the creation of user profiles are among the most serious reasons for the creation of ORDs.

We understand our responsibilities to users and strive to limit the collection and processing of data for the purpose of optimizing ad serving to a minimum. However, technological developments have led to the creation of a complex system of relationships and data exchange for these purposes.

We collect information and combine it with previously available information to select and deliver relevant advertising to you and to be able to measure its delivery and effectiveness. This may include pre-collected information about your previous interests in selected ads, data processing of your behavior, when your ad was shown, how often you were shown certain ads, where and when they were shown to you, whether you took action on the ad, including a click on the ad and a purchase.

This goal does not include customization and profiling.

For selection, delivery and reporting of the offered content

we collect information and combine it with previously collected information to select and deliver relevant content to you and measure its delivery and effectiveness. This may include pre-collected information about your interest in the content, processing data about the content you display, how often or for how long it has been displayed, whether you have taken action on the content, including a click on the content.

This goal does not include customization and profiling.

For measuring

We collect information about your use of the content and combine it with previously collected information to measure, understand and report your use of our services.

This goal does not include customization and profiling.

By assignment and for third party projects

For specific projects commissioned by third parties, we collect your personal data, which we share with them to achieve the objectives of their projects.

To inform you about games and promotional offers 

To fulfill this goal, we collect your personal data to inform you about our or third parties, our partners, initiatives, promotions, games, offers and more.

For all purposes described above, we may use third-party tools.

For the processing of your personal data, including the provision of competent authorities in the cases provided by law and for the fulfillment of legal obligations to us, as well as for purposes related to the fulfillment of the obligations of the parties to the contract

For planning, reporting and statistics purposes

For the purposes of planning, reporting and statistics, means any operation for the collection and processing of personal data necessary for statistical surveys or for the production of statistical results, as well as for the preparation, implementation and verification of plans and their results.

For Marketing purposes

In order to always send you up-to-date and useful information about our initiatives, we collect data as an e-mail address.

Who else has access to this information?


We sometimes disclose your personal information to third parties - Our Partners, including such third parties outside the European Union, subject to the requirements of the Regulation, such as:

Third parties with whom we have a contractual relationship to organize games, contests or promotions for these Partners;
Third parties with whom we have a contractual relationship to publish advertisements and promote through other appropriate means their products and services;
Third parties with whom we have a contractual relationship for the use of Virtual Servers (VPS);
Third parties providing services to improve the advertising targeting of our products and services and / or our Partners;
Industry-recognized solution providers that have publicly declared compliance with GDPR and e-privacy policies, such as Google and Facebook. The consent also includes the placement and use of marking unique depersonalized identifiers, including the use of cookies, localStorage or other appropriate generally accepted web technology;

What are your rights regarding personal data?

Our priority is both to inform you about your legal rights and to ensure their observance. You have the following rights, which should be respected when processing your personal data:

The right to withdraw your consent to the processing of your personal data at any time;
To request correction or supplementation of your data in case of ascertained inaccuracy through a written application sent to us;
Right of access to your personal data;
Right to limit the processing of your personal data;
Right to object to the processing of your personal data;
The right to data portability;
The right to request the deletion of your personal data that is processed illegally or with a revoked legal basis (withdrawn consent, fulfilled initial purpose for which they were collected, etc.);
The right to ask the Administrator of your personal data to notify the third parties to whom the Administrator has provided your data, regarding the correction, deletion or restriction of the processing of personal data.
You have the right to appeal to the Commission for Personal Data Protection.

When can we use your data to contact you?

We may use the information you provide to contact you about various issues such as:

to notify you of changes to our policies and current policies;
to respond to you when you have contacted us or to respond to your comment or complaint;
to invite you to participate in our research regarding our services;
for marketing purposes;
to send you appropriate offers for products and services to inform you about games, contests or promotional offers 

We will never contact you to request the password for your account.

How can I receive, update and manage my personal data?

You can easily update and manage your information by going to Settings.

Conclusion

This privacy policy is valid as of May 25, 2018.

Devstudio.bg reserves the right to change and / or supplement this Policy at any time. The changes take effect immediately after their publication on the website, unless otherwise provided in the updated version of the Policy. You should periodically visit this Policy Review page. The policy may be updated at any time without special notice to our users. Devstudio.bg is not responsible if a user of the websites has not read the latest version of this Policy.   

USERS 'RIGHTS UNDER THE GENERAL REGULATION FOR THE PROTECTION OF PERSONAL DATA

General

Under the General Data Protection Regulation (REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 - GDPR), you, as a subject of the collection and processing of personal data, have the right to exercise these below your rights.

Before you have this opportunity, we need to identify you.

You will be identified by login to the service for which you want to exercise your rights. If you have used a service for which no account has been created, we will identify you on the spot in our office.

The deadline for responding to your request in the Regulation is up to 1 (one) month. In view of the complexity and number of requests, we may extend this period by another 2 (two) months, of which we will notify you in an appropriate manner of your choice.

You can submit your request electronically from our Privacy Center. As we do not maintain a single database of all our sites / mobile applications / products / services, you will need to specify a specific site / mobile application / product or service for which you wish to exercise your rights.

We will notify you in the manner specified by you of the outcome of each of your requests under the GDPR.

List of your rights

The right at any time to withdraw your consent to the processing of your personal data in accordance with the requirements of the Regulation;
Right to correct personal data - if you believe that there is an error in the personal data collected about you, you can request their correction. You will have to provide us with the data you think is correct.
Right of access to your personal data - you have the right to receive confirmation whether we process your personal data and, if so, to access them. Along with the data we will give you access to the mandatory information described in Art. 15, item 1 of the Regulation.
Right to delete your personal data - you may request to be forgotten, and we will assess whether the requirements of Art. 17 of the Regulation.
Right to limit the processing - means marking stored personal data in order to limit their processing in the future. If you want us to keep your personal data without processing it, you can submit a request under this item.
Right to data portability - you can request that the personal data we collect about you be transmitted in a structured, widely used and machine-readable form. At this time, we are unable to transfer your data directly to another administrator.
Right to object - you can object at any time to the processing of your personal data, including profiling and direct marketing.
The right to ask the Administrator of your personal data to notify the third parties to whom the Administrator has provided your data, regarding the correction, deletion or restriction of the processing of personal data. In all cases where you exercise any of the above rights, we will notify these third parties of your request.
You have the right to appeal to the Commission for Personal Data Protection, which is submitted in the form and with details according to the law.

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