What and to whom does this data protection policy apply?
TOPIMMO EOOD, with registered office in Varna and address of management in Varna, 38 General Kolev Blvd., ground floor, with UIC 206092300, is the administrator of the personal data and information provided by you, which connects with you and may identify you, and which we collect from and for you, through the services of the company and within the activities of the same. Such information ("Personal Data") is processed in accordance with the terms of this Privacy Policy. This Privacy Policy applies to all users, including those who use the Company's services without being registered or subscribed to the Company's service, as well as to those who have registered or subscribed to the Company's services. The company. The services of the Company are not intended for persons under 16 years of age and no personal data is collected from such persons.

1. What data is personal data?
According to the applicable provisions of Regulation № 2016/679 (EU), personal data are defined as: "Any information relating to an identified or identifiable natural person (" data subject "). An identifiable natural person 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 by one or more features specific to the natural, the physiological, genetic, mental, intellectual, economic, cultural or social identity of that individual. "

2. What types of personal data do we collect about you?
The company collects:
A) Contact details: the information you provide in order to register for a service of the Company, to create your account, to subscribe to a newsletter or to make an inquiry. Contact details may include - names, e-mail address, telephone number, permanent address, country;
B) Information required for and in connection with the conclusion of a contract with the company: Information required for the conclusion of a contract is that which consists of your identification data and serves to verify your identity when entering into a contractual relationship, which may includes three names, civil number, details of an identity document, mailing address and permanent address, as well as certain categories of special data such as marital status;
C) Information you have allowed social media to share with the Company: If you access a Company service through a social media service or connect a Company service to a social media service, the information that the Company collects may also include user information. the identification or username associated with this social media service, any information or content that you have agreed to be shared with the social media service with us, including a profile picture, email address, and any other data, which you have made publicly available in connection with this service;
D) Information about the activity: when you access or interact with a service of the Company: When you access or interact with the services of the Company, we may collect information about these visits.

Cookies and other similar technologies may also be used to collect and store information about your use of the Company's services, such as the pages you have visited, the content you have viewed, the search queries you have made, and ads you have seen, what information may include - IP address; browser type, device data. For more information, please read our Cookie Policy.
The company in any way does not store: financial information; information concerning sensitive personal data relating to origin; political, religious and other beliefs; Health status; judicial past; participation in trade unions and political organizations.

Related Services: The Company's services may also be linked to websites operated by unrelated companies and may include advertisements or offer content, functionality or applications developed and maintained by unrelated companies. The Company is not responsible for the personal data protection practices of such unrelated companies.

3. How do we use your personal data?
The data that the company collects from and about you is used for:
3.1. Providing the services of the company;
3.2. Evaluating, analyzing and improving the company's services according to your expectations and interests;
3.3. Increasing the level of your satisfaction when using the services of the Company by providing you with relevant and interesting content for you;
3.4. Offering quality customer service, to communicate with you and to answer inquiries;
3.5. The protection and preservation of the rights of the Company, in particular, there may be cases in which it is possible for the Company to disclose the data, if the disclosure is necessary (i) for the protection, exercise or preservation of legal rights, privacy, security or the property of the Company, its employees, intermediaries and counterparties, ii) for the protection of the Company against fraud, or (iii) for the purposes of risk management;
3.6. Conducting negotiations for the implementation of a contractual relationship between the Company and you;
3.7. Compliance with the law or legal procedures and / or in fulfillment of requests from public and state bodies;
3.8. Providing social media sharing functionality, if you sign in with or link a social media account to the Company's services, we may share your username, photo and likes, as well as your activity and comments, with other users of the Company's services and with your friends related to the social media service you use. We may also share this personal information with the social media service provider;
3.9. With your prior consent, we will send you (by e-mail, SMS, telephone, chat and social media) offers, promotions and other marketing messages related to the services of the Company, services / products of related parties and / or partner organizations operating. in the field of real estate business, including companies from the group of Topimmo EOOD and branded or co-branded services and functions, conducted jointly with a partner organization or a related party;
3.10. With your prior consent, we send you marketing messages tailored to your individual interests and demands, via e-mail.
The Company may use anonymised information or information that no longer allows Users to be identified directly or indirectly as a specific individual, for any purpose or to share with third parties.

4. On what grounds do we use your personal data?
The processing of your personal data for the purposes of:
  • Section 3: item 3.1. - item 3.5 of this Privacy Policy, is carried out on the basis of a legitimate interest of the company and is necessary in view of the provision of the requested services;
  • Section 3: item 3.6. of this Privacy Policy, is performed on the basis of a legal obligation of the company and is necessary to comply with applicable law;
  • Section 3: item 3.7. of this Privacy Policy is made on the basis of a contract with the company and is necessary for entering into a contractual relationship with the company or, if it has already been concluded, for its implementation;
  • Section 3: item 3.8. - item 3.10. of this Privacy Policy, is based on your consent and you have the right to withdraw your consent at any time without consequences;

5. How do we process your personal data?
Personal data shall be processed both automatically and manually and shall be protected by appropriate security measures, taking into account the state of the art, the cost of implementation, and the nature, scope, context and purpose of the processing. The company introduces appropriate administrative, technical, personnel and physical measures to protect the personal data at its disposal from loss, theft and unauthorized use, disclosure or modification.

6. Who has access to your personal data?
The Company may share your personal data for the purposes of Section 3 with the following categories of recipients located within the European Union:
A) Third party service providers who are entrusted with the processing activities and who are duly appointed to process personal data, where required by applicable law, providers of services ancillary to or supporting the services of the Company and in this context persons providing IT services, experts, consultants, lawyers;
B) Related parties in their capacity as controllers or processors of personal data;
C) Competent authorities in order to comply with applicable law.

7. Is your personal data transferred abroad?
Your personal data may be transferred to countries within the European Economic Area. If the Company makes such a transfer, the Company will use adequate and appropriate measures for the protection of the Data and for the transfer of the Data, which are in accordance with the applicable laws for protection of the personal data.

8. What are your rights regarding your personal data?
According to the General Data Protection Regulation (EU) 2016/679 you have the right at any time to:
  • receive confirmation that your personal data exists, receive a copy of it and be informed about both its content and its source, as well as the right to receive additional information specified in this Privacy Policy regarding the purposes of processing your personal data, the categories of recipients, the existence of any automated decision-making (if any), the envisaged period for which the Company will store them (where possible).;
  • check the accuracy of your personal data and request their correction, updating or modification;
  • request the deletion or anonymization of your personal data in cases where:
  • The data are processed in violation of applicable law;
  • The company no longer needs the data for the purposes for which it was collected;
  • The company has a legal obligation to delete them;
  • You have objected to the processing based on a legitimate interest, and there are no compelling legal grounds which take precedence over such processing;
  • ask the Company to restrict the processing of your personal data in cases where:
  • challenge the accuracy of the data until the Company takes the necessary measures to correct them or verify their accuracy;
  • the processing is illegal, but you do not want the Company to delete the Data;
  • The Company no longer needs your personal data for the purposes of processing, but you require the data to establish, exercise or defend legal claims; or
  • you have objected to the processing based on a legitimate interest, pending verification that the Company has compelling legal grounds to continue the processing.
  • objections to the processing of the Data where it is based on a legitimate interest, including for marketing purposes;
  • request the deletion of the Data without undue delay;
  • receive an electronic copy of the Data ("data portability"), in cases where the Data is processed automatically and the processing is either (i) based on your consent, or is (ii) necessary for the performance of a contract with the company; 
  • lodge a complaint with the relevant supervisory authority.

You can send your request to the address below. Please include your e-mail address, name, address and telephone number in your request and clearly indicate what information you wish to receive, change, update, hide or delete. It's a good idea to know that even after you remove your account or request that your data be deleted, copies of certain information in your account may remain visible in certain circumstances, such as if you've shared information with social media or other services, or where the preservation of such copies is necessary in order to comply with legal obligations or legal protection. Due to the nature of information caching technology, your account may not be immediately inaccessible to others. We may also retain archived information related to your account on our servers for some time after removal or request for deletion, if required to comply with applicable law.
In addition to the above, with respect to your personal data used by the Company for marketing purposes, you may choose not to receive direct marketing messages at any time. If you no longer wish to receive emails from us for future advertising and marketing purposes, you may refuse to receive such emails by following the unsubscribe instructions in our messages. You can also send a request to the address below. We share your personal information with our Affiliates for their marketing purposes: If you would prefer not to share your personal information with our Affiliates for their direct marketing purposes in the future, you may refuse such sharing by sending a request to the address specified below in the Privacy Policy. In all of the above cases, we may contact you and request additional information in order to comply with your request.

9. Periods of storage of personal data
We will keep your personal data for the period necessary to fulfill the purposes for which the data was collected, as described in this Privacy Policy. The most recent retention periods will apply to the processing of your personal data for the following purposes:

Data collected for the purposes set out in Section 3, item 3.1. - 3.7 of this Personal Data Protection Policy are reserved for the time of providing the services of the Company or fulfillment of the contractual relationship with the company, adding the duration of the limitation period according to the applicable legislation after the termination of services or performance of the contract with the Company. ; The data collected for the purposes specified in Section 3, item 3.8 of this Personal Data Protection Policy shall be retained for the time required for registration in the Company's Service via a social network; The data collected for the purposes specified in Section 3, item 3.9. - item 3.10. of this Privacy Policy are retained for a period of 24 months from their collection; At the end of the retention period, your personal data will be either deleted, or anonymized or aggregated.

10. Update this privacy policy
The Company has the right to amend or update this Privacy Policy for any reason (including, but not limited to, changes in applicable law and clarifications, instructions, decisions, opinions and orders related to such applicable law. Any changes. in this Privacy Policy will be announced in advance by publishing on the company's website.

11. Contacts
If you have any questions regarding this Privacy Policy, please contact us at the following e-mail address: