Privacy and data protection policy and information regarding the processing of personal data

The www.riverpark.bg website (the „Website“) and related services are available to visitors and users (or, for short, you) in accordance with the privacy management and protection policy as described in this document.

The website is owned by „Real Estate Developments“ Ltd, UIC 204770872, registered in the Commercial Register and the Register of Non-Profit Entities, maintained by the Registry Agency at the Ministry of Justice, with registered office and registered address. Sofia, ul. „The registered office and registered address of the company is 26-28, Bacho Kiro, Business Park Platinum. Your personal data is collected and processed by “Real Estate Developments„ EOOD, UIC 204770872, with registered office and management address. registered office and registered address:. “Bacho Kiro„ № 26-28, Business Park “Platinum„ (“the Company„ or for short - we).

As a personal data controller, the Company and its employees comply with all requirements of Bulgarian legislation and applicable European legislation related to the protection of personal data. The Company guarantees the confidentiality of non-public information and personal data of all visitors and users of the www.riverpark.bg website.

Please read this Privacy and Data Protection Policy („Policy“) to understand how we collect, process, store and use your personal data in our business. The Policy applies only to the Website and applies to personal data processing activities carried out by the Company or third parties commissioned by the Company.

The Policy contains information on access to and protection of personal data, the purposes, grounds and means for processing personal data and other information of interest to you as a data subject. You can find the information below in this Policy and by contacting us at: office@riverpark.bg. Please read the Policy before you decide to use or register as a user of our Website.

OBJECTIVES

The Company recognizes the right to privacy and personality and is committed to implementing a comprehensive policy to protect against unauthorized access and/or processing of personal data of Website users through compliance with this Policy.

This Policy is intended to inform the users of the Website about the purposes of processing their personal data, the recipients or categories of recipients to whom the data may be disclosed, the basic principles for the collection and processing of personal data, including their voluntary provision, strict compliance with the rights of users and compliance with the Company's obligations as a personal data controller.

For the purpose of compliance with applicable national and European legislation in the area of personal data protection, this Policy is subject to updating and may be amended and supplemented from time to time when the law or the practice of the regulator so requires. Its most up-to-date version is published on the Website.

This Policy applies to information we collect through the Website (including advertisements, services and applications) and through email, text and other electronic communications between you and the Website.

TERMS

For the purposes of this Policy:

- „personal data“ means any information relating to an identified natural person or a natural person who can be identified, directly or indirectly, by various identifiers such as name, identification number, location data, online identifier or by other specific attributes linked to physical, economic, cultural or social identity, etc.;

- „processing of personal data“ means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, use and any other means by which data are made available;

- „data controller“ means a natural or legal person, public authority, agency or other body which processes personal data, either alone or by subcontracting to another person, duly specifying the purposes and means of the processing.

COLLECTION OF INFORMATION AND DATA PROVIDED BY YOU

The Company collects information that you provide to us voluntarily or through your use of the Website, including when you interact with the Website's features, when you register as a user, for example, to learn about the services offered by the Website, when you subscribe to a newsletter, when you register to participate in events and initiatives offered through the Website, etc. The Company also reserves the right to store and process users' personal data in order to comply with Bulgarian and applicable European legislation.

The information we collect and process depends on how you use and access the Website.

When visiting the Website by unregistered users (surfers), the provision of personal data is not required.

When registered users use the Website, we collect information and personal data from you when you create a contact request in connection with our provision of information or services, contact us for help or information, or otherwise provide personal data, including in connection with our news and events, information updates or other services. For the purposes of registering on the Website, you enter the information specified on the Website, including your name, email, contact telephone number, any text addressed to us, and other required information. You also enter similar information when you make comments or send a request or complaint to us.

The provision of personal data by the user is necessary for the performance of the services and functionalities offered by the Website, such as registration on the Website and subscription to newsletters, news, updates on events or other initiatives offered through the Website or promotions. Refusal to provide personal data by the user results in the user's inability to register on the Website or to use services or other initiatives offered through the Website.

Each user is responsible for the truthfulness and accuracy of the personal data they provide. Any loss or damage caused to the Website, the Company or any third party due to the provision of erroneous, inaccurate, or incomplete information will be the sole responsibility of the user.

AUTOMATIC DATA COLLECTION

We may perform automated data collection, including for profiling purposes, while you are browsing or using the Website, such as data about the number of times you visit the Website, your location, the information you use on the Website, your IP address, operating system and browser type.

„BISKWITCHES“

Like many other websites, we also use cookies, which are small files stored on your computer's hard drive. We use cookies to personalize the Website (present different pages to different users), track individual users„ access to the Website, evaluate visitor patterns, evaluate Website content by users, and generally improve the Website. Through cookies, our Website can ”distinguish„ and “remember„ visitors and their individual preferences, settings and actions taken.

Almost any browser can allow you to delete cookies at any time or disable the use of cookies altogether through an appropriate setting. Please see the information in your browser's Help menu, where you will find explanations on how to stop your browser from accepting new cookies, how to change your browser's settings to receive a warning when a new cookie appears, or how to refuse all cookies. Please note that restricting or refusing cookies may result in your access being restricted or you being unable to use certain features of the Website.

IP ADDRESS

An IP (information protocol) address is a number that uniquely identifies a computer or other hardware connected to the Internet and connects it to other devices when they send information over the Internet or a local area network. An IP address alone cannot identify an individual. We store your IP address and its data to ensure the security of our systems and to prevent misuse of information and data.

We use the automatically collected information to improve the Website and user experience by creating and analyzing user patterns, customizing access and use of the Website according to your preferences and interests, and facilitating your searches based on the statistics so collected. We will store this information for a period of 3 years.

The automatically collected information is statistical and does not contain personal data, but in combination with other additional information that we store or receive, it would be possible to reveal the identity of a data subject, in which case this information will be processed, stored and used in accordance with the rules of this Policy.

ONLINE SURVEYS, SOCIAL NETWORKS, LINKS TO OTHER WEBSITES

We may use the Website to conduct online surveys created by the Website team or the Company's partners to research consumer attitudes and desires. If you participate in an online survey, we may ask you for specific information such as your age, gender, education, interests, email address and/or mailing address. This type of information contains personal data and is treated in accordance with this Policy.

The Website may contain links to other websites - for example, to the Website's Facebook page, Google Maps, etc. Please note that this Policy does not apply to information collected through other websites. We encourage you to read the privacy policies of all websites you visit. If you have accessed the Website through a link of one of our advertising, marketing or other partners, pages may be directed to those partners. However, the information you provide will be collected by us, and the provisions of this Policy will apply regarding the use of that information.

GOOGLE ANALYTICS

It is possible that, while users are visiting and browsing the Website, we may track the pages they visit and the time they spend on the Website using the Google Analytics analytics tool. You can object to the collection and processing of your data in this way by downloading and installing a browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout?hl=en

WEBSITE MANAGEMENT AND MAINTENANCE

The management and technical maintenance of the Website is carried out by external content and service providers. These content and services may include distribution of marketing and promotional materials, Website evaluation, data research and analysis, fraud protection and risk mitigation, data cleansing, and more. We provide personal data to these external providers, authorizing and obligating them to use it only for the relevant services and on the condition that they contractually undertake to take the necessary measures to comply with applicable data privacy laws.

THE PURPOSES FOR WHICH THE INFORMATION AND PERSONAL DATA WE COLLECT IS USED

We use this information and data to:

- providing the services offered by the Website;

- improving the Website, personalizing it and making it easier to access and search;

- marketing and advertising purposes;

- online research, analysis, processing and storage of information, including for statistical purposes;

- sending information to you about news, upcoming events, promotions, services and other activities (if you have consented to receive such information) and other communications with you;

- collecting and storing complaints, comments and recommendations and taking action on them;

- fulfilling the Company's legal obligations, protecting the rights and interests of users, the Company and its affiliates, including with a view to preventing misuse of information and data;

- other purposes for which we have obtained your explicit consent.

PROCESSING OF PERSONAL DATA

We process your personal data on the basis of legitimate interest. Our legitimate interest is generally expressed in the legally recognised right to conduct and develop our business. Where we have requested and you have consented to the processing of your personal data, your consent justifies the lawful processing of your personal data. It is also lawful to process your personal data to comply with a legal obligation of the Company as a data controller, and where necessary to protect your interests, such as to detect and prevent theft of that data, fraud or other breaches.

The Company, as the administrator of the users' personal data, processes the same in accordance with this Policy and with the consent given by the user when providing the data. Users' personal data is processed by persons authorised by the Company who have access to it on the basis of their official or contractual obligations and only in connection with and for the purposes of the processing. Upon request in electronic format by email to office@riverpark.bg, each Website user may obtain information about the type of his or her personal data that the Company processes, the authorized employees who carry out the processing, whether third parties process his or her personal data, on what basis and for what purposes his or her personal data has been provided to third parties and other relevant information.

The Company processes personal data in accordance with the necessary security requirements to minimize the risks of destruction and loss of data, unauthorized access, unlawful processing or processing that is not consistent with the purposes for which it was collected. The Website's information system and programs are configured to minimize the use of personal and identifying data so that such data is used only when necessary for the specific purpose of the processing.

STORAGE OF PERSONAL DATA

Your personal data will be collected and processed through an electronic system operated by the Company or third parties commissioned by the Company and stored on secure servers.

The period of storage of your personal data is mainly determined by the duration of your user profile. As long as you have an active profile on the Website, the Company will store your personal data. At the time of deletion or other deactivation of the profile, your personal data information will be deleted, subject to the applicable legal requirements in this respect, within one month.

In other cases, the data necessary to achieve the specific purpose of the processing, including those given on the basis of the user's explicit consent, shall be retained by the Company for a period of 5 years from receipt, or for the period necessary to comply with our legal obligations as a data controller, if this period is longer.

DISCLOSURE OF PERSONAL DATA

We may disclose the personal data we hold in the following cases:

- with your consent;

- for the purpose for which you are providing it, if this requires disclosure;

- to third parties providing Website maintenance and management, analytics and data protection services;

- the Company's pre-contractual and contractual intermediaries, including sales intermediaries, marketing specialists, analysts, technical and other consultants to the Company;

- to comply with our legal obligation or a request by government authorities or judicial authorities to protect the rights, property, or safety of the Company or its affiliates, business partners, customers, or users of the Website;

- in the event of acquisition of control over the Company, its capital or its business assets or part thereof by third parties. Transactions of this nature may also involve the transfer of Website user information, in which case we will notify you via information on the Website of the transfer of data and any new privacy and data protection policy.

We may exchange non-personal information with our marketing partners, analysts, advertisers, consultants and others providing services to the Company. Typically, this information is in numerical form, such as the number of users who visited the Website in a particular period, the information or service most frequently requested, and the like.

WEBSITE USER RIGHTS

Website users have the right at any time to:

- to request from the Company access to their personal data processed by the Company, verification of their content and their correction or completion, updating, blocking, deletion, termination or restriction of their processing, to object to their processing, to withdraw their consent to their processing by email to: office@riverpark.bg, and after the withdrawal they will not be able to use the services of the Website and will not be able to receive messages, emails, sms for advertising, marketing and commercial purposes, as well as to communicate with the Company on matters related to customer programs and other electronically, therefore the withdrawal will be treated as a withdrawal by the user from the provision of services from the Website);

- to check and delete the information (profile) related to their personal data. When a profile is deleted, all personal data related to the data subject is automatically deleted;

- receive information from the Company about the purpose of processing their personal data, how and where their personal data is stored, the third parties to whom it is provided and on what basis, how and for what period their personal data is stored or to request that their data is not used for direct marketing purposes.

Pursuant to Article 20 of Regulation (EU) 2016/679, the Company states that it does not have the technical capability to provide portability of personal data from the Website to other websites.

You may contact us at office@riverpark.bg if you wish to receive the above information from the Company or to exercise your rights.

If you suspect that your personal data has been misused, please contact a representative of the Company at +359 29835690 or by email at office@riverpark.bg.

In case of suspicion of abuse or complaint in connection with the collection and processing of your personal data, you have the right to file a complaint with the Commission for Personal Data Protection at 1592 Sofia Blvd. „+359 2 915 35 18, email: kzld@cpdp.bg, website: http://www.cpdp.bg/

POLICY CHANGES

We will inform users of any material changes to the Policy by notice on the Website. In some cases, we may also send emails to inform our users of this. We encourage you to check the Website regularly for changes to the Privacy Policy.