PRIVACY POLICY

Personal Data Administrator
BULBERA Ltd. is an Administrator and a processor of personal data, registered under the
Bulgarian legislation, carrying out design, development, implementation and provision of
software solutions and services, with registered office in Sofia, bc. MLADOST-3, bl. 364, ent.
4, floor 8, apt. 35, UIC 1175235853 in the Commercial Register at the Registry Agency of the
Republic of Bulgaria,
Contact: +359 2 4373261 e-mail: info@bulbera.com

By carrying out its activity, BULBERA Ltd. performs lawful and regulated personal data
collection, processing and storage in accordance with Regulation (EU) No 2016/679 of the
European Parliament and of the Council of 27 April 2016 on the protection of individuals
with regard to the processing of personal data and on the free movement of such data and
national data protection legislation.
Reason for collecting, processing and storing personal data
1. BULBERA Ltd. collects or accesses and processes your personal data in connection with
the development, improvement, removal of shortcomings and errors in software programs and
solutions, the offering and sale of reviews, feedback and evaluation of customers and users’
satisfaction on the ground of: explicitly obtained, specific and unambiguous consent, Art. 6,
para. 1, b. (A) of Regulation (EU) 2016/679, or a Personal Data Processing Agreement /
Contract concluded with the Personal Data Administrator.
Objectives and principles of collecting, processing and storing personal data
2. BULBERA Ltd. collects and processes the personal data you provide us for the following
purposes: creating a profile in application and software systems and providing full
functionality when using the application; ensuring the ability to send and receive feedback
and reviews with recommendations to improve the application; ability to perform statistical
processing and evaluate the satisfaction of application users; sending information messages,
that concern application changes and/or the service itself, recommendations to improve the
use of the platform, new and upgraded plans, etc.; improving and personalizing the service by
appropriate renewal offers and other products and services that may be of interest to you;
provision of technical support.
BULBERA Ltd. complies with the following principles when processing your personal data:
– legitimacy, good faith and transparency;
– limitation of processing objectives;
– subordination of the purposes of processing on an equal basis with minimization of the
collected data;
Types of personal data that BULBERA LTD collects processes and stores
3. BULBERA Ltd. collects, processes and stores these categories of personal data and
information for the following purposes and on the following grounds:
– Personalized data: name, surname and last name, phone number, email address.

Purpose of data collection: creating a profile in applications and software systems and
providing full functionality when using the application; ensuring the ability to send and
receive feedback and reviews with recommendations to improve the application; ability to
perform statistical processing and evaluate the satisfaction of application users; sending
information messages, that concern application changes and/or the service itself,
recommendations to improve the use of the platform, new and upgraded plans, etc.;
improving and personalizing the service by appropriate renewal offers and other products and
services that may be of interest to you; provision of technical support.
Reason for processing your personal data – explicitly obtained, particular and unambiguous
consent, Art. 6, para. 1, b. (A) of Regulation (EU) 2016/679, or a Personal Data Processing
Agreement / Contract concluded with the Personal Data Administrator.
BULBERA Ltd. does not collect or process personal data that:
– reveal racial or ethnic origin;
– reveal political opinions, religious or philosophical beliefs, or trade-union membership;
– genetic and biometric data, data concerning health or sex life and sexual orientation.
BULBERA Ltd. collects personal data directly from the individuals it refers to or through the
Google Play platform. By removing errors and bugs, inward processing, maintenance and
other similar software solutions, created by the company which belongs to another
Administrator, as a personal data processor, BULBERA Ltd. has access to the data collected
and stored in the application. The company does not make automated decision making based
on collected data or profiling.
Time limits for storage of personal data
4. BULBERA Ltd. has access to or retains your personal data for a period not exceeding the
time required for program work on the application or no longer than the term of use of the
company’s applications and software systems.
Providing your personal data for processing
5. BULBERA Ltd. may, at its sole discretion, transmit all of your personal data or part of it
for the fulfilment of the processing objectives in compliance with the requirements of
Regulation (EU) 2016/679. BULBERA Ltd. informs you in case it transfers part or all of your
personal data to third countries or international organizations.
Withdrawal of the consent
6. If you do not wish all of your personal data or part of it to continue to be processed by
BULBERA for a specific or all processing purposes, you may, at any time, withdraw your
consent to processing by filling in the application form or by free format request. BULBERA
Ltd. may ask you to certify your identity with the person subject to this data.
By withdrawing the consent to the processing of personal data that is required to create and
maintain your registration for the use of applications and software systems, your account will
become inactive. All data processed until the withdrawal of the consent has been processed
legally.
Consumer rights
Right of access
7. You have the right to require and receive a confirmation from BULBERA Ltd. in case any
personal data relating to you is being processed. You have the right to access your personal
data as well as the information concerning the collection, processing and storage of the above

mentioned data. BULBERA Ltd. provides you with a copy of the processed personal data
relating to you, upon request, in written or electronic form, if possible. Providing access to the
data is free of charge but BULBERA Ltd. reserves the right to impose an administrative fee in
the event of excessive claims and misuse of this right.
Right to rectification or completion
8. You may fill in and / or correct your incomplete / incorrect personal data from your
account, or request BULBERA Ltd. to correct your incorrect or incomplete personal data.

Right to erasure ("right to be forgotten")
9. You have the right to require BULBERA Ltd. to delete your personal data and BULBERA
Ltd. has the obligation to do so without undue delay when any of the following reasons exists:
– personal data are no longer needed for the purposes they were collected for or otherwise
processed;
– you withdraw your consent the processing of the data is based on and there is no other legal
basis for the processing;
– you object to the processing of your personal data and there are no legitimate grounds,
contractual obligations or legitimate interest in the processing that will take precedence;
– your personal data has been unlawfully processed.
– your personal data must be deleted in order to comply with a legal obligation under EU law
or the law of a Member State that applies to BULBERA Ltd.;
BULBERA Ltd. is not obliged to delete personal data if it stores and processes it:
– to comply with a legal obligation which requires processing, provided in EU law or the law
of the Member State applied to the Administrator, to the performance of a task in the public
interest or in the exercise of the official powers conferred on it;
– for the establishment, exercise or protection of legal claims.
To exercise your right to "delete" you should use the option in the application or submit a
written request to the Administrator as well as to verify your identity with the person the data
relates to before BULBERA Ltd. by presenting your ID card to an employee of BULBERA
Ltd.
BULBERA Ltd. does not delete the data which it is legally obliged to store, as well as to
protect against legal claims made by / against it or to prove its rights.
Right to restriction of processing
10. You have the right to obtain from BULBERA Ltd. restriction of processing of your
personal data where one of the following applies:
– you challenge the accuracy of the personal data for a period enabling BULBERA Ltd. to
verify the accuracy of the personal data;
– the processing is unlawful, and you oppose the erasure of the personal data and request the
restriction of their use instead;
– BULBERA Ltd. no longer needs your personal data for the purposes of processing, but you
require them for the establishment, exercise or defense of legal claims;
– you have objected to processing pending the verification whether the legitimate grounds of
BULBERA Ltd. take precedence over your interests.
Right to data portability
11. You have the right to request BULBERA Ltd. to directly transmit your personal data to
another controller, specified by you where technically feasible.

Right to receive information
12. You have the right to request BULBERA Ltd. to inform you of all recipients who your
personal data have been disclosed to, for which correction, erasure, or limitation of processing
was requested. BULBERA Ltd. may refuse to provide this information if this would be
impossible or would require disproportionate effort.
Right to object
13. You have the right, at any time on, to object to the processing of your personal data by
BULBERA Ltd. even if this is done solely for statistical purposes or to assess customer
satisfaction.

Your rights in case of personal data breach
14. When BULBERA Ltd. detects personal data breach, which is likely to result in a high risk
to your rights and freedoms, we communicate the personal data breach to you without undue
delay, as well as the measures taken or proposed to be taken.
BULBERA Ltd. is not obliged to inform you if:
– the company has implemented appropriate technical and organizational protection measures,
and those measures were applied to the personal data affected by the personal data breach;
– the company has taken subsequent measures which ensure that the high risk to your rights is
no longer likely to materialize;
– the notification would require disproportionate effort.

Persons, to whom your personal data is provided
15. In order to fulfil the obligations of the controller in the field of accounting and tax
legislation, in compliance with a legal obligation, BULBERA Ltd may provide your data to
the relevant state bodies and third parties –tax authorities and social insurance institutions,
courts, bailiffs, public contractors and authorities and others.
The administrator does not transfer your data to third countries.
Right to appeal and to judicial remedy
16. In case of violation of your rights according to the above mentioned principles or the
applicable data protection legislation, you could file a complaint before the Personal Data
Protection Commission as follows:
1. Legal name – Commission for personal data protection
2. Seat and registered office – 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
3. Address of correspondence – 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
4. Telephone: 02 915 3 518
5. Email: kzld@government.bg , kzld@cpdp.bg
6. Website: www.cpdp.bg
You have the right to legal or administrative redress if your rights as a data subject have been
violated.
Other provisions
17. (EU) Regulation No. 679/2016, the Personal Data Protection Act and the applicable data
protection legislation apply to all relationships not covered by this Privacy Policy.

18. When providing personal data to a third party who is owner of an application that
BULBERA Ltd. has established and maintains, the company acts as a personal data processor.
In these cases, Bulbera Ltd. acts on the basis of the Agreement / Contract for the processing of
personal data with the owner of the application and only to the extent necessary for the
improvement and correction of errors in the application. In these cases, BULBERA Ltd. does
not define the purposes and means for the collection and processing of personal data or
whether the controller has taken any measures for the protection of personal data. BULBERA
Ltd’s liability in such cases is limited to the administrator's instructions under the Regulation
and the agreement.

I declare that I have read carefully, I am familiar with and accept the content of this statement.
I clearly and specifically give my consent to BULBERA Ltd to process my personal data
listed in this appendix.