We collect personal information about you such as your name and email address, and phone number as well as other personal information when you message us using our “Contact Us” form, when you subscribe to our Services and pay for them, and when you send an email to us. We also collect details about your transactions when you purchase our Services. Like many companies, we also collect internet and device information, such as from cookies and other automated technologies, when you browse our website.

We collect personal information for our business purposes, namely, to provide and improve our website and Service. Part of this includes compliance with applicable laws, such as responding to legal requests, enforcing this Privacy Policy and our rights, and protecting others and our Service. We may also use personal information for short-term, transient use for interaction with you and to personalize your experience and communications. We use information for security purposes and to protect against harmful activity. Further, we may use personal information for debugging functionality, auditing interactions, and internal research. Moreover, we may use information as otherwise instructed by you and with your consent.

In addition, we collect information for commercial purposes, meaning to market our website and Services. For example, we collect device and other personal information to better target advertisements and other content to create a more personally relevant experience.

Please note that we do not use any automatic decision-making which can harm or otherwise affect your legal rights.

For more specific information on how we use your personal information, please refer to the next section.

Identifiers such as email addresses and passwords, name, postal address, phone or mobile contact number, unique personal identifier (if you log in via Google, Facebook, or other 3rd party applications - If you create an account using your login information from a third-party account we will access and collect the personal information about you that the third-party account provides based on your privacy settings with such third-party account.

We collect and use these types of personal information for all business purposes, such as creating and preserving your account registration, providing and improving our website and Services, responding to communications, and for security and auditing purposes. Depending on the specific purpose (e.g. website access, creating an account, corporate profiles, etc.), we collect one part or a combination of the listed information, but always in compliance with the rule for minimum use of personal information. We might also collect and use your contact information to market our offerings to you, such as through emails. The legal basis for this processing is our legitimate interest to grow our business and open accounts for our users; in addition, by agreeing to our Terms of Use you also lay the contractual basis for the collection of this personal information.

Transactions, purchases made or purchasing tendencies. Financial, such as name, billing address, See also California Civil Code Section 1798.80(e). Inferences, such as creating a profile relating to consumer preferences and trends.

We collect this information when you purchase our Services. We do not collect or store credit card information and details. All payment information is collected and stored by Stripe and/or PayPal and/or Spreedly and/or Shift4. You can review their privacy notices here, here, here and here.

We collect and use these types of personal information with respect to the purchases and subscriptions you make via our website and mobile app. The legal basis for this processing is our compliance with applicable financial laws. In addition, by agreeing to our Terms of Use you also lay the contractual basis for the collection of this personal information.

Internet and network information, such as browsing history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement. See below for more information about cookies and other tracking technologies. Social Media Login email. Further, we may use geolocation information (but not precise location trackers) to provide increased functionality and show offers relevant to you, depending on the country of residence. We gather user information for both city and country locations. This does not include specific locations within a city.

Other Information, such as communications to us, responses to personality tests or promotional offers and/or marketing, if any

● Company Parties; Merger or Sale. We may share information with affiliated companies that are related to us under common ownership where they comply with this Privacy Policy. Such disclosure is for our business purposes, including to provide and improve our Services. Further, we may share information as part of a sale, merger, acquisition, or other change in control or entity status, either in whole or in part. We reserve the right to transfer or assign your information as part of any such transaction or investigation.

● Service Providers and Contractors. We share information with service providers (e.g. for payment processing, service optimization, technical support, storage etc.) that allows us to provide, maintain and improve our Services (they act as our data processors, within the meaning of GDPR). Service providers only use your information for our business purposes, in particular, to provide you with the Services. We may likewise share information with “contractors” that are not service providers but to whom we disclose information for business purposes, namely, to provide you with Services (and/or products, if applicable) that you have requested or considered.

● Legal Process and Protection. We may disclose information as necessary to comply with our legal obligations, such as to respond to government requests, tax and law enforcement inquiries, legal processes, subpoenas, and court orders. We may disclose information when we believe it is necessary to investigate, prevent, or respond to illegal, fraudulent, or injurious actions or security incidents that may cause harm to us, the Service, or others. We may also disclose information in good faith where necessary to investigate or enforce a violation of this Privacy Policy, our terms, or any legal rights.

● Consent. We may disclose information as requested or consented to by you.

You can change your cookie settings in your internet browser and use settings on your device to manage your privacy controls. For more information and ways to opt-out, see https://www.allaboutcookies.org/, and learn how to disable these tools by opting-out of third-party cookies and mobile device ID practices.

As part of our practices, we may use third-party advertising companies to display ads tailored to your individual interests based on your online activity and to provide ad-related services such as analytics and market research. Third parties, in turn, may also use a cookie, web beacon, or other similar technology to collect information. To opt-out of cross-device linking, visit www.aboutads.info/choices or perform a global opt-out on each browser and device. In particular, we may use Google cookies and tools, such as Google Analytics for analytics and advertising and to improve the user experience, and your information may be shared with Google; for more information, visit the Google Cookie Policy, Google Analytics Opt-Out Browser Add-On, or Ads Settings. in rare cases we also use Google Maps e.g., in certain QR Code Types (Business Page and VCard) we generate a link to Google Maps, which points to the address provided by you.

We may also use Meta and other cookies for the purposes stated above, and your information from cookies may be shared with Meta; for more information visit the Meta/Facebook Cookie Policy.

No, we do not sell personal information.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

For US users - If you are visiting the Service from a location outside of the United States, your connection will be through and to servers located in the United States, and all information you provide will be processed and securely maintained in our web servers and internal systems located within the United States.

For EU users - To the extent we collect personal information from EU/EEA residents, it may be transferred to, stored, and processed in the United States and other countries outside the EU/EEA that do not have the same data protection laws as your jurisdiction. In making any such transfer of EU/EEA resident personal information outside the EU/EEA, we will only do so in compliance with EU law, such as by including data processing agreements based on the EU Standard Contractual Clauses and, in the case of transfers to the U.S. by using the Service, you authorize and specifically consent to the transfer of personal information to the United States and its storage and use as specified in this Privacy Policy.

If you are a resident of the United Kingdom (UK), then the countries where we transfer personal information may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law (including by the conclusion of Standard Contractual Clauses).

We retain personal information for the length of time necessary to fulfill the purposes outlined in this Privacy Policy, unless a different retention period is requested by you or required or permitted by law. For example, we will retain your personal information for as long as it is needed to provide you with the Service or fulfill a legal or contractual obligation. We may also aggregate, deidentify, or anonymize personal information as applicable for use in analytics, such as to analyze trends over periods of time without identifying you.

We use the following criteria to determine how long we retain personal information: (a) our relationship with you, such as if there is an open contract or account or a pending transaction or request, (b) legal obligations to retain personal information for certain purposes, such as to maintain transaction records, and (c) other obligations or considerations relating to the retention of personal information, such as (but not limited to) contract requirements, litigation holds, investigations, or statutes of limitation.

As described in the Terms of Use as well, we may close your account and/or delete the personal information on it if there is no activity on it for a period of more than 33 days, if you do not have a subscription with us. Such measures are also in the interest of your security, as it is not necessary for your personal information to be stored in the event that you do not use a given service. Further, if we suspect, in our sole discretion, that there has been a breach of your account security, we reserve the right to refuse access to the Services, terminate your account, suspend or terminate your right to use the Services, or take such other action as we deem necessary.

We value consumer privacy rights and strive to provide flexibility with how your personal information is used and shared. If you want to make a privacy request or have any questions, please contact us through our Contact Form or email [email protected] with your name and email address or other identifier used in connection with our Services so that we can verify your request. If an authorized agent is making a request on your behalf, the agent should provide their name and contact information, such as an email address, in addition to your information.

Please note that not all these rights are absolute, and they do not apply in all circumstances. There may be situations where we cannot grant your request, for example if you make a request and we cannot verify your identity, or if you request deletion of personal information but we have a legal obligation to keep your personal information. Where we deny your request in whole or in part, we will take steps to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

Applicable privacy laws have different requirements and depend on various factors, such as where you live and how much revenue or personal information is at issue. For this reason and wherever possible in this Privacy Policy we have noted the main differences in some of the major legal systems (EU and US). Generally, we adhere to the following set of privacy rights to the extent applicable and subject to any limitations authorized by law:

● Access. You can access and obtain your personal information and ask us for certain information, including the categories of personal information collected and used, the categories of the sources of personal information, the business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom personal information is disclosed, the specific pieces of personal information collected etc.

● Portability. Depending on your state of residence, you have the right to request the personal information that we have collected and maintained about you for you to transmit the personal information to another entity without hindrance. We will provide this information to you via a secure method in a commonly used electronic format that, to the extent technically feasible, is readily usable and transmittable.

● Amend. You can amend, correct, or rectify your personal information if it is inaccurate. To exercise the right to correct, please submit a verifiable request by contacting us using the contact information at the end of this Privacy Policy or by filling out this form

● Delete. You can have your personal information deleted subject to certain legal limitations. To exercise the right to delete, please submit a verifiable request by contacting us using the contact information at the end of this Privacy Policy or by filling out this form.

● Limit Use of Your Sensitive Personal Information. You have the right to limit the processing of your personal information, in particular of any sensitive personal information. However, we do not generally collect or use your sensitive personal information.

● Right to Opt-Out. You have the right to opt-out of the sale/share of your personal information using cookies and other online tracking technologies. You can opt-out of these online tracking technologies by contacting us. We will also respond to recognized global opt-out preference signals where we can verify the request. You may opt-out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

● Right to Opt-Out of Profiling. You may opt-out of the use of automated decision making technology if applicable. Depending on where you reside, you may have the right to opt-out of such profiling.

● Complaints. You have the right to make certain complaints, including for privacy concerns. We value your feedback and seek the opportunity to work with you on any issues. You have the right to no discrimination for asserting your privacy rights. You can find a list of all EU regulators at https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-bg.

● Managing Communication Preferences. You can unsubscribe from marketing communications by following the opt-out instructions in each message or by contacting us as outlined in this Privacy Policy (please note that we may still send non-marketing messages)

● FOR US users - Specific State Laws. Several states in the US have enacted privacy laws that may apply to you, depending on the circumstances. For example, the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), governs certain California-related conduct. Under California’s “Shine the Light” law, California residents may also request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. Further, if you are a California resident under the age of 18, California Business & Professions Code Section 22581 permits you to request and obtain removal of content you have publicly posted. Please note that such a request does not ensure complete or comprehensive removal of public content. For required disclosures under CCPA, please refer to the section below, titled “Additional Information for California Residents.”

● For EU users - European Laws. Generally, residents of the EU/EEA have the right to access the personal information (under GDPR – “personal data”) we hold about you and to ask that your information be corrected, updated, or erased, and the right to object to, or request that we restrict, certain processing of your information. Our legal basis for collecting and using your personal information can be your consent, performance of a contract, or where the collection and use is in our legitimate interests and not overridden by your interests or fundamental rights, as described in details in the table hereabove (section “How do we use your personal information?”). You may withdraw your consent to our collection and use of your personal information. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information used in reliance on lawful processing grounds other than consent.

● Other Laws. If certain other privacy laws apply to you that afford you with additional rights, please contact us to make a request, as we strive to comply with all privacy rights.

Depending on your country or state of residence, you may appeal our decision to your request regarding your personal information. To do so, please contact us in any of the ways listed in the “How can you contact us?” section. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

No, we do not knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected such information, we will delete it from our database. We have no such information to use or to disclose to third parties or to otherwise report, including under the US Children’s Online Privacy Protection Act (“COPPA”).

We do not generally use or disclose “sensitive” personal data within the meaning of GDPR, nor do we use sensitive information for purposes other than those specified in the US CCPA, which provides for the following uses without additional disclosures where the information is reasonably necessary and proportionate to the use: (a) to perform certain services, such as verifying information or for analytics, (b) to verify or maintain the quality or safety of our Services, (c) to perform services or provide goods reasonably expected, (d) for short-term, transient use where there is no disclosure or profiling, and (e) to resist malicious, fraudulent, or illegal actions or to ensure physical safety.

No, we do not currently offer any financial incentives for your personal information.

No, our Services do not currently respond to DNT requests. DNT is a feature that, when enabled, sends a signal to websites to request that your browsing is not tracked. However, our site recognizes and responds to recognized global opt-out preference signals, such as GPC.

We will update this Privacy Policy when our privacy practices change or as otherwise required or permitted by law. Each time you use the Services, the current version of this Privacy Policy will apply.

California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the privacy policy.

Customers who are residents of California may request information concerning the categories of personal information (if any) we disclose to third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to the address in the “How can you contact us?” section.

We disclose the following categories of personal information for business or commercial purposes to the categories of recipients listed below:

● We disclose Identifiers with businesses, service providers, and third parties, such as advertising networks, analytics and social media networks.

● We disclose Commercial Information with businesses, service providers, and third parties, such as advertising networks, analytics and social media networks.

● We disclose Device Information with businesses, service providers, and third parties, such as advertising networks, analytics and social media networks.

● We disclose Other Personal Information and Other Non-Personal Information with service providers.

Please contact us with any questions or concerns! We can be reached at:

Novomedia EOOD 60 Major Thompson blvd., bl. 12, entrance A

1407 Sofia, Bulgaria [email protected]

You can request further information about the way we manage the personal information that we hold by contacting us using the details set out below:

Data Protection Officer

Novomedia EOOD,

Novomedia EOOD,

60 Major Thompson blvd., bl. 12, entrance A

1407 Sofia, Bulgaria