Balkanbyte Ltd.

Privacy Policy

(Last updated on June 15, 2022 and effective as of this date)

This privacy statement ("Privacy Policy") governs your use of online services and/or websites and software applications for mobile devices (together "Services") that are created and/or provided by Balkanbyte Ltd. (“We”, "Us" or "our"). The Privacy Policy only governs information that has been provided to Us and/or automatically collected by the Services either directly or through embedded technologies within the Services, not information that you provide to third parties or such information that is made publicly available.

What information we collect and how we use it?

User Provided Information

We may collect certain personal information that you choose to provide to Us either by using the Services, in the process of communication with Us, when you contact Us for help or when you provide Us with feedback, or in any other way, such as by e-mail or telephone. Such information may include your name, mailing address, e-mail address, phone number, year of birth, gender. We may use the personal information that you choose to provide to Us to respond to your questions and/or feedback or to contact you from time to time to provide you with important information or with required notices.

Automatically Collected Information

The Services may collect, either directly or through embedded technologies, certain information automatically, including, but not limited to, the type of device you use, your unique device ID, IP address, and information about the way you use the Services.

Do the Services collect precise real time location information?

The Services do not collect precise information about the location of your computer or mobile device.

Do third parties see and/or have access to the collected information?

We will not share your information with third parties except as described in this privacy statement. We may disclose User Provided Information and Automatically Collected Information:

as required by law, such as to comply with a subpoena, or similar legal process;
when We believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
with our trusted services providers who work on our behalf and do not have any right to use personal information or other information We share with them beyond what is necessary to assist Us. You hereby consent to our sharing of User Provided Information and Automatically Collected Information with our service providers.
if We are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via e-mail and/or a prominent notice on our websites of any change in ownership or uses of this information, as well as any choices you may have regarding this information;

We may also share Automatically Collected Information with advertisers and third party advertising networks and analytics companies as described in the section below.

Automatic Data Collection and Advertising

We may work with analytics companies that help Us understand how the Services are being used, such as the frequency and duration of usage by the means of aggregated Automatically Collected Information.

We may also work with advertisers and third party advertising networks, who need to know how you interact with advertising provided in the Services which helps Us keep the cost of the Services low. Advertisers and advertising networks use some of the Automatically Collected Information that is collected by the Services and may also obtain anonymous information about other applications you′ve downloaded to your device, the websites you visit, your non-precise location information (e.g., your zip code), and other non-precise location information in order to help analyze and serve anonymous targeted advertising on the Services and elsewhere. We currently work with the following advertising networks and/or analytics companies:

For all of our apps that are available free of charge:

AdMob - a mobile advertising network provided by Google.
Personal Data collected: contextual information including coarse general (city level) location, cookies, mobile ad identifiers
For further information see: https://policies.google.com/technologies/partner-sites

Cookies

A cookie is a string of information that a website stores on a visitor′s computer, and that the visitor′s browser provides to the website each time the visitor returns. On this website cookies are used to:

correctly redirect this website’s domain to the server that hosts the data;
hide the information on the website's cookie usage once the user has agreed to their usage;

If you wish to not have cookies placed on your computer and/or mobile device you can set your browser to refuse cookies before accessing our website.

Data Retention Policy, Managing Your Information

Information will be retained for as long as you use the Services, or respectively for as long as necessary for the fulfillment of the specified purposes as described in this Privacy Policy and for a reasonable time thereafter in accordance with applicable law.

If you′d like Us to delete User Provided Information that you have provided to Us either through the Services or by other means as described in this Privacy Policy, please contact Us. Please note that some or all of the User Provided Information may be required in order for the Services to function properly.

User Provided Information as well as Automatically Collected Information may be transferred to and/or stored on servers which may be located on any territory, including the United States. Such transfers of your personal data will be carried out in compliance with applicable laws.

Children

We do not use the Services to knowingly solicit data from or market to children. If a parent or guardian becomes aware that his or her child has provided Us with information without their consent, he or she should contact Us. We will then delete such information from our files within a reasonable time.

Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information We process and maintain. For example, We limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Services. Please be aware that, although We endeavor to provide reasonable security for information We process and maintain, no security system can prevent all potential security breaches.

Changes

This Privacy Policy may be updated from time to time and for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here. You are advised to consult this Privacy Policy regularly for any changes.

Contact Us

If you have any questions regarding privacy while using the Services, or have questions about our practices, please feel free to contact Us via email.

Data Controller

Balkanbyte Ltd.
ul. Bacho Kiro 3 et.1 ap.1
6300 Haskovo
Bulgaria
Email: info@balkanbyte.eu

Legal basis of processing

We may process your personal data if one or more of the following applies:

you have given consent to the processing of your personal data for one or more specific purposes;
processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
processing is necessary for compliance with a legal obligation to which We are subject;
processing is necessary in order to protect your vital interests or of another natural person;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Us;
processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data. Such legitimate interest could exist for example where there is a relevant and appropriate relationship between Us and you in situations such as where you are our client or in our service.

Rights of the Data Subject

Right to information

You have the right to be informed about the collection and processing of your personal data. We should provide you with the information necessary to ensure fair and transparent processing while taking into account the specific circumstances and context in which your personal data is processed.

Right of access

You have the right to obtain from Us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information:

the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient 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, or, if not possible, the criteria used to determine that period;
the existence of the right to request from Us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;
the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from you, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

Right to rectification

You have the right to obtain from Us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Right to erasure (‘right to be forgotten’)

You have the right under certain circumstances to obtain from Us the erasure of personal data concerning you without undue delay as long as the processing is not necessary. Where We have made the personal data public and are obliged to erase the personal data, We, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the you have requested the erasure of those personal data.

Right to restriction of processing

You have the right to obtain from Us restriction of processing where one of the following applies:

the accuracy of the personal data is contested by you, for a period enabling Us 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;
We no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
you have objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether our legitimate grounds override yours.

Right to data portability

You have the right to receive the personal data concerning you which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from Us, where: the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR; and the processing is carried out by automated means.

In exercising your right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have your personal data transmitted directly from Us to another controller, where technically feasible and when such action does not adversely affect the rights and freedoms of others.

Right to object

You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. We shall no longer process the personal data unless We demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

If personal data are processed by Us for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. If you object to Us to the processing for direct marketing purposes, the personal data will no longer be processed by Us for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications. If personal data are processed by Us for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) of the GDPR, you, on grounds relating to your particular situation, shall have the right to object to processing of personal data concerning you, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Rights in relation to automated individual decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except if the decision (1) is necessary for entering into, or performance of, a contract between you and Us; (2) is authorized by Union or Member State law to which We are a subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (3) is based on your explicit consent.

In the cases referred to in points (1) and (3), We shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express your point of view and to contest the decision.

Right to withdraw consent

You have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Legitimate Interests pursued by Us

For the cases of processing of personal data based on Article 6(1) lit. f GDPR our legitimate interests are in the economic operation and safety of our products as well as in carrying out our business in favor of our well-being.

Information whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and of the possible consequences of failure to provide such data

The provision of personal data can be required for the purpose of us to comply with our legal obligations or for the fulfillment of a contractual requirement. Provision of personal data is also a necessary requirement in order for you to enter into a contract with Us. You are obliged to provide personal data to Us when We sign a contract with you.

If you fail to provide to Us personal data required for a contractual requirement that will have the consequence that the contract with you could not be concluded.

Automated individual decision-making

We do not use your personal data for any automated individual decision-making.