Privacy Policy

date of publication: 04.03.2025
I. Information about the Administrator:

We, “VALUEME” LTD, a company registered in the Commercial Register of the Registry Agency with UIC 205937694, with its seat and registered address: Sofia, p.c. 1729, “Mladost” 1A residential complex, 33 “Alexander Malinov” Blvd., building Campus X, e-mail: office@valueme.bg, in our capacity as a personal data administrator within the meaning of the General Data Protection Regulation (Regulation (EU) 2016/679), in force from May 25, 2018, and the Bulgarian legislation for personal data protection, we are committed to ensuring compliance with the legislation of the European Union and the Republic of Bulgaria regarding the processing of personal data when you visit and use any of our websites.

This Privacy Policy is intended to acquaint you with the rules we observe when we collect and process your personal data when you visit and use any of our websites.

Here you can find information about what personal data of yours we collect, how and for what purpose we use it, to whom we provide it, what your rights are as a personal data subject, as well as how to contact us or the supervisory authority for personal data protection.
II. Who is it intended for?
This Privacy Policy provides information on the processing of personal data of the following categories of persons:
Website visitors without registration;
Users who have registered with a profile on our website;
Persons who contact us by e-mail;

III. What personal data do we collect and for what purposes?

Depending on the purpose for which we process the personal data, we collect different categories of data.

1. The personal data we collect and process when you visit our website:
   When you visit our website, we collect data through so-called “cookies”. Cookies are small text files that are stored on your computer or mobile device when you first visit the site. They help us to provide a better user experience every time you visit our website.
   More detailed information about the types of cookies we process and their functionality can be found in our Cookie Policy.
   
2. Personal data that we collect and process upon registration:
   When registering on our website, you need to provide us with the following personal data: user data (name and surname); contact details (e-mail); data about your educational institution (the school where you teach or study); geographical data (city and country), as well as other relevant data that you decide to provide us with.
   
   Source: We receive the above personal data from you, personally.
   
   The personal data we collect will be used only for legitimate purposes: creating a profile, administering and providing all functionalities to it; individualization of a party to the contract; accounting and statistical purposes; protection of information security; keeping records and conducting or defending legal claims; sending a newsletter and emails with special offers with your explicit consent; responding to inquiries made through the feedback form.
   
   The grounds that give us the right to process your data: The processing is based on our contractual legal relations when you create a user profile on the website, accept the General Terms and Conditions of the website, purchase a monthly, annual or group plan through the website. For the purposes of concluding and performing this contract, we collect and use your personal data with which we identify you and can contact you (e-mail).
   
   The collection and processing of the above information is mandatory for the conclusion and performance of the contract. If this information is not provided to us, we will not be able to conclude and perform the contract.
   
   Period and method of data storage: We will store your personal data for the entire duration of the legal relationship, after which the data is archived until the statute of limitations for seeking liability from/to the subject and/or from a public authority in connection with the legal relationship expires (5 years in the general case), unless a special law requires otherwise.
   
   IV. Recipients of your personal data:
   We will not sell your data to third parties, nor will we transfer it in order to gain any benefit. Only our employees, whose direct duties are related to the activities for the purposes of which the respective personal data are processed, have access to your personal data.
   
   We may provide your personal data to persons who help us achieve the goals described above – processors of personal data (service providers, organizations to which we have assigned individual data processing activities), acting on the basis of a written contract, in accordance with our explicit instructions and in the application of appropriate technical and organizational measures to protect your data.
   
   Personal data will not be provided to third parties or shared outside the European Union or the European Economic Area.
   Recipients of your data may also be state bodies in the cases provided for by law.
   
   V. How we store and protect your personal data that we process:
   We will process your personal data by taking the necessary and sufficient technical and organizational measures for their protection, such as:
   We use secure websites through which we collect your personal data;
   We conduct reviews of our practices for collecting, storing and processing personal data, including physical security measures, in order to prevent unauthorized access to the systems we use;
   We include contractual confidentiality clauses in all contracts we conclude with employees and third parties to whom we entrust the processing of your personal data;
   
   We use only those organizations to which we entrust the processing of personal data that adhere to the highest standards of information security and personal data security, demonstrated both by the presence of relevant certifications and by the ability to conduct regular compliance audits;
   We have taken the necessary internal policies and have taken measures to protect your personal data at the design stage;
   The data protection officers are well acquainted with the requirements regarding the protection of your personal data;
   We have introduced measures in case of a technical incident for the timely restoration of the availability and access to personal data;
   
   An internal process has been created for regular testing, assessment and evaluation of the effectiveness of technical and organizational measures in order to ensure the security of processing;
   A procedure for storing and destroying data has been developed.
   
   VI. We do not perform automated decision-making (without human intervention) when processing your personal data for any of the above purposes.
   
   VII. YOUR RIGHTS as a personal data subject:
   
   At any time while we store or process your personal data, you, as the subject of this data, have the following rights:
   Right of access to your personal data.
   You have the right to receive from us information about whether we are processing personal data related to you, and if so, to gain access to the data itself, as well as to information about:
   the categories of personal data being processed;
   the purposes of the processing;
   the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
   where possible, the envisaged period for which the personal data will be stored, and if that is not possible, the criteria used to determine that period;
   the existence of the right to request from us the correction or erasure of personal data or the restriction of the processing of personal data related to you, or to object to such processing;
   your right to lodge a complaint with a supervisory authority;
   the existence of automated decision-making, including profiling, as well as additional information about it in the cases provided for by law.
   
   We will provide you with a free copy of your personal data that we process, as well as the information listed in the list above. If you request additional copies of the data, we may charge a reasonable fee for each such additional copy based on the administrative costs of creating it.
   
   Right to rectification. You have the right to request the correction of your personal data if it is inaccurate or out of date, as well as the completion of incomplete data.
   
   Right to erasure of personal data. You have the right to request from us the erasure of personal data (the right “to be forgotten”) without undue delay, if and to the extent applicable in view of the grounds under Art. 17 of the GDPR and/or the relevant national law, in a case, among others, such as: the personal data are no longer necessary for the purposes for which they were collected; when you have withdrawn your consent; when you have objected to the processing; when the processing is unlawful; when the personal data must be erased in order to comply with a legal obligation under EU law or the law of a Member State to which we as a personal data controller are subject; when the personal data have been collected in connection with the offer of information society services.
   Right to restriction of processing. You have the right to request from us the restriction of processing, if and to the extent applicable in view of the grounds under Art. 18 of the GDPR and/or the relevant national law, in cases, among others, such as establishing the accuracy or reason for the processing of the data; the restricted processing of the data is usually reduced to their simple storage.
   
   Right to data portability. You have the right to request and be provided with personal data in a structured, widely used and machine-readable format, as well as to request that it be transferred to another administrator without hindrance from our side, if and to the extent applicable in view of the grounds under Art. 20 of the GDPR and/or the relevant national law, in a case, among others, when the processing is based on consent for a specific purpose or is necessary for the performance of a contract and is carried out in an automated manner.
   
   Right to object to processing. You have the right to object to the processing of your personal data in cases where we process it on the basis of public interest or on the basis of our legitimate interests, when you believe that in your particular case this processing is incompatible with the protection of your interests, rights and freedoms. In such cases, if we cannot prove that there are compelling legitimate grounds for the processing that override your interests, rights and freedoms, or that the processing is necessary for the establishment, exercise or defense of legal claims, we will stop processing this personal data.
   When we process your personal data for the purposes of direct marketing (as is the case with the processing of data for the purposes of sending newsletters), you may object to this data processing, in which case we will immediately stop it. In addition to a statement to this effect, you can show us your desire to stop processing for the purpose of sending newsletters and by unsubscribing from all electronic newsletters through the unsubscribe hyperlink (link), which is part of every email with which we send you an electronic newsletter.
   
   Right to withdraw consent. When we process your personal data on the basis of your consent, you may at any time withdraw the consent you have given. You can withdraw your consent with an explicit written statement addressed to us. After withdrawing your consent, we will stop the processing of your personal data processed on the basis of your consent, and the withdrawal of consent will not affect the lawfulness of the processing based on consent before its withdrawal. Nevertheless, we may continue to process the same personal data to the extent that there is another ground (other than consent) for processing the data.
   
   Right to lodge a complaint with a supervisory authority. If you believe that we are processing your personal data in violation of the provisions of the applicable legislation, including, but not limited to, the General Data Protection Regulation and the Personal Data Protection Act, you have the right to lodge a complaint with the supervisory authority in the Member State of the European Union of your habitual residence, place of work or place of the alleged infringement. In the Republic of Bulgaria, the competent supervisory authority is the Commission for Personal Data Protection, with its address: Sofia 1592, 2 “Prof. Tsvetan Lazarov” Blvd. (www.cpdp.bg).
   
   Please note that your rights as data subjects are not absolute. We may refuse to exercise a specific right for legally established reasons. The most common grounds for refusal are: compliance with a legal obligation on our part or the need to establish, exercise or defend legal claims.
   
   VIII. Contact us.
   We create conditions that guarantee the exercise of your rights as a data subject. If you wish to ask a question about the processing of your personal data, exercise your right, withdraw your consent or file a report or complaint, you can contact us in writing at the e-mail address: office@valueme.bg.
   We will respond to your inquiries within two calendar weeks of receiving them.
   In case of significant changes in the circumstances specified in this policy, including if we intend to process your personal data for a purpose other than the original one, we will notify you in a timely manner at the e-mail address you have provided.