PRIVACY POLICY OF EMDI DRUZHBA Ltd.

I. SUBJECT

In accordance with the principle of transparency and Regulation No. 679/2016 of "EMDI DRUZHBA" Ltd., hereinafter referred to as "Supplier", "Administrator", "we" and/or "us", owner/operator of the website: https://mdcapital.bg/bg, hereinafter referred to as the "Website", processes (including, but not limited to, collects and stores) personal data of data subjects, such as users of the Website and the Provider's services, hereinafter referred to as "User(s)", "You" and/or "Yours", as well as the rights of the latter in this regard.

Below you will find brief information about:

•       the Provider,

•       The competent supervisory authority,

•       The legal basis on which we process personal data,

•       The purposes for which we use personal data,

•       Principles of personal data processing,

•       What personal data we collect,

•       The period for which we store personal data,

•       Access to and transfer of personal data, and

•       Rights and safeguards of data subjects.

II. INFORMATION ABOUT THE SUPPLIER

1. Name: "EMDI DRUZHBA" Ltd., UIC 208386118

2. Registered office and management address: Sofia, 1000, Sredets district, 96 Georgi S. Rakovski Street, floor 2

3. Tel.: 0888 575 449, e-mail: office@mdcapital.bg

4. Entry in public registers: Commercial Register at the Registry Agency under the Ministry of Justice of the Republic of Bulgaria.

III. INFORMATION ABOUT THE COMPETENT SUPERVISORY AUTHORITY 

1. Name: Personal Data Protection Commission of the Republic of Bulgaria

2. Address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd. 3.

3. Telephone: 02 915 3 518

4. Email: kzld@cpdp.bg

5. Website: https://www.cpdp.bg/

IV. BASIS FOR THE COLLECTION, PROCESSING AND STORAGE OF PERSONAL DATA

We process (including, but not limited to: collect and store) your personal data solely in connection with our activities and in accordance with the requirements of applicable law, including the Personal Data Protection Act of the Republic of Bulgaria and the General Data Protection Regulation. We process your personal data on at least one of the following grounds:

•       The User's consent to the processing of personal data;

•       We process your personal data in order to respond to your enquiries (by telephone or e-mail), to provide you with the information you have requested about properties available for sale in the projects of EMDY DRUZHBA Ltd., terms and conditions of purchase, as well as upcoming projects.

•       If you have given your explicit consent to receive advertising messages, we will process your personal data in order to provide you with additional information about current and future projects of EMDY DRUZHBA Ltd., programmes and promotions, documents and others.

V. PURPOSES FOR COLLECTING, PROCESSING AND STORING PERSONAL DATA

We collect, process and store Users' personal data in connection with the provision of our services and communication in connection with the use of the Website, as well as for the following purposes:

•       Communication and identification in the performance of a service contract and a purchase-sale contract (including in the performance of the relevant contract);

•       Communication, identification, processing and execution of enquiries, orders, requests, reservations, purchases of goods or services (including preparation for the conclusion of a contract, acceptance of orders, dispatch of goods, resolution of issues related to the cancellation of orders, reservations, refunds of amounts paid, and others);

•       Fulfilment of tax and other legal obligations;

•       Accounting purposes in connection with the use of our services;

•       Protection of our legitimate interests in connection with the fulfilment of our obligations to state and municipal authorities;

•       Protecting our legitimate interests in relation to storing information for the purpose of protecting against legal or tax claims and for the purpose of improving the performance of the website;

•       Protection of the information security of the website;

•       Statistical information about the use of the website;

•       Provision of advertising content tailored to the interests of the User;

If a data subject refuses to provide us with some or all of the personal data necessary for the relevant purpose specified above, we may not be able to provide the relevant service (e.g. to perform a contract concluded with the relevant User).

VI. PRINCIPLES OF COLLECTION, PROCESSING AND STORAGE OF PERSONAL DATA

We adhere to the following principles when collecting, processing and storing your personal data:

•       lawfulness, fairness and transparency;

•       purpose limitation;

•       limiting the storage period to achieve the purposes for which the data is processed;

•       minimising the data processed;

•       accuracy and timeliness of data;

•       integrity and confidentiality of data processing and ensuring an appropriate level of security for personal data.

VII. PERSONAL DATA

We collect the following categories of personal data from Users for the following purposes and on the following grounds:

•       Your identifying data (first and last name, telephone number and email address), as well as other data that you voluntarily provide to us for the purposes of processing your enquiries, providing service offers and providing services on our part, at your request, including communication with you in this regard, and on the basis of taking steps at your request for the possible conclusion of a contract, performance of a contract to which you are a party, or consent to processing provided by you;

•       Your personal data (name and surname, telephone number and email address) and information related to payment and selected payment methods for the purposes of issuing and sending accounting/tax documents (invoices) in connection with the services you use, including communication with you in this regard, and on the basis of taking steps at your request for the possible conclusion of a contract, performance of a contract to which you are a party or performance of our legal obligation;

•       Your IP address, browser settings and language preferences, pages visited, and actions taken for the purpose of sending push notifications, if you have expressed a desire to receive such notifications;

•       Your IP address, pages visited, for the purposes of information security;

•       Other data that may be necessary in certain cases or related to the provision of services to Users by us, including data necessary for the performance of contractual obligations (e.g. date of birth, signature, personal identification number) or other data that Users voluntarily decide to share with us, and on the basis of the performance of a contract to which you are a party, consent to processing provided by you or compliance with our legal obligation.

We use cookies on our website, which are small files downloaded to your computer to improve your experience as a user of the site. You can find more information in this regard on our special page with rules for cookies.

We do not process or collect special categories of personal data from users (e.g. data revealing racial or ethnic origin, political opinions, genetic or biometric data, or data concerning the sex life or sexual orientation of the data subject).

We do not make decisions based solely on automated data processing, including profiling.

VIII. PERSONAL DATA RETENTION PERIOD

We store Users' personal data for no longer than is necessary to fulfil the relevant processing purpose or for the statutory period, where applicable. For example:

•       personal data provided by you when filling in the contact form will be stored until the request or query you have contacted us about has been fulfilled, and for a maximum of one year thereafter for statistical and marketing analysis purposes;

•       personal data of our customers processed in connection with contracts concluded between us and the respective User will be stored for a period not exceeding ten years, starting from 1 January of the year following the year in which the contract was reported for tax purposes;

•       personal data of our customers processed in connection with the issuance of tax documents (invoices) will be stored for a period not exceeding ten years, starting from 1 January of the year following the year in which the document was reported for tax purposes;

•       personal data of our partners/suppliers processed in connection with contracts concluded between us and the respective partner/supplier will be stored for a period not exceeding ten years, starting from 1 January of the year following the year in which the contract was reported for tax purposes;

The storage period depends, among other things, on the duration of the legal relationship between us and the respective User, as well as on the purposes for which the personal data is processed. Where there is an indication of potential legal claims or liability, these periods will be extended accordingly. When the processing is based on the User's consent (e.g. in cases of personal data provided by third parties for direct marketing), we store this personal data for as long as we have valid consent for its processing.

After the expiry of the above periods, we take the necessary care to delete and/or destroy your personal data without undue delay.

IX. ACCESS TO PERSONAL DATA AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES

The personal data of Users that we process is accessible to our employees, representatives and partners who need it to fulfil legal obligations and/or to perform contractual obligations (e.g. providing a service under a contract with a User). In this regard, it is possible, at our discretion and in compliance with the requirements of the General Data Protection Regulation (GDPR), to transfer all or part of your personal data to third parties such as accountants, professional consultants, including lawyers (for the purposes of financial, accounting and administrative services for our business), cloud platforms for data processing/storage (for the purposes of organisational services for our business, e.g. storage and processing of contracts with cloud platform users for greater security), companies providing postal services (for the purposes of organisational support of our activities, e.g. sending paper contracts to users), IT service providers, system administration, marketing services (for the purposes of providing more reliable and higher quality work on the website and more secure data processing), providers of third-party information storage services (i.e. hosting companies) (for the purposes of performing contracts with Users).


Based on applicable law or at the request of public authorities, all or part of your personal data may also be accessible to public authorities.

We do not intend to transfer your personal data to countries outside the European Economic Community or to international organisations.

X. RIGHTS OF DATA SUBJECTS

At any time while we are processing your personal data, and subject to the restrictions set out in applicable law, you, the data subject, have the following rights:

•       Right of access – you have the right to request information about whether we are processing your personal data, as well as to access and obtain a copy of such personal data; 

•       Right to rectification/correction – you have the right to request that your personal data be corrected if you believe it is inaccurate or incomplete. We will make such corrections/rectifications without undue delay;

•       Right to erasure/to be forgotten – in certain circumstances (e.g. the personal data is no longer necessary for the purposes for which it was collected; you have withdrawn your consent to the processing of certain personal data about you, for which there is no other legal basis for processing) you may request that your personal data that we process be erased from our records/database without undue delay. In certain cases, we may refuse to delete such personal data (for example: the processing of personal data is necessary for compliance with a specific legal obligation or for the establishment, exercise or defence of legal claims);

•       Right to restriction of processing – in this case, your data will only be stored but not processed. Our refusal to restrict the processing of your personal data will be explicit and only in writing, and we are obliged to justify it with a lawful reason;

•       Right to portability – when your personal data is provided to us by you and is processed by automated means, you have the right to request that your personal data be transferred to you in a structured, commonly used and machine-readable format, as well as to be transferred to another personal data controller, if technically feasible;

•       Right to object – you have the right, at any time, to object to the processing of your personal data for specific purposes, in which case we will stop using your personal data for that specific purpose, unless we have compelling legitimate grounds for doing so (for example: you have the right, at any time, to object to the processing of your personal data for direct marketing purposes, in which case we will stop processing your personal data for these purposes without undue delay);

•       Right to object to automated processing, including profiling – you have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, and you also have all the rights that arise for you if you are subject to the legal consequences of such processing;

•       Right to withdraw your consent to processing – if we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. The withdrawal will not affect the lawfulness of the processing based on consent before its withdrawal.

If, at the request of a User, we delete his/her personal data from our database, we will only retain information that may be necessary to protect our legitimate interests or for public authorities.


If we are required to transfer personal data to another controller, to correct or delete personal data, to restrict the processing of personal data or to terminate such processing, to provide information about the recipients to whom the personal data for which correction has been requested has been provided, deletion or restriction of processing, or to provide access to personal data, and in case of concerns regarding the identity of the User who made the request, we may first request additional information to confirm the identity of the data subject in question.


If, in the processing of your personal data, there is a third party to whom all or part of your personal data has been transferred (as specified in Section IX above), all of the above requests will be forwarded to that third party.

The exercise of the above rights is free of charge for Users, and you may exercise the above rights by contacting us at:office@mdcapital.bg 

XI. COMPLAINT TO A SUPERVISORY AUTHORITY

If you believe that your personal data is not being processed lawfully or that any of your rights relating to the protection of personal data have been violated, you have the right to lodge a complaint with the competent supervisory authority for the protection of personal data, as specified in Part III above of the Personal Data Protection Policy. You also have the right to seek protection of your rights through legal action.

If the website contains links to other websites, we recommend that you carefully review the personal data protection/privacy policies of these other websites, because when you visit these websites, your personal data may be processed by the websites in question, which processing is not covered by the Personal Data Protection Policy.

In the event of a change/update to this Privacy Policy, a notice will be posted on our website, along with the updated Privacy Policy.