POLICY OF AVANGARD REAL ESTATE.BG LTD FOR THE PROTECTION OF PERSONAL DATA PURSUANT TO REGULATION (EU) 679/2016 of 27.04.2016.

In accordance with the mandatory requirements of Article 13 and Article 14 GDPR, the policy of AVANGARD REAL ESTATE.BG Ltd. is focused entirely on compliance with any applicable legislation in the field of personal data protection, including the GDPR, as well as any applicable local legislation in the Republic of Bulgaria related to the protection of personal data and the privacy of electronic communications.

The policy of "AVANGARD REAL ESTATE.BG" Ltd. is fully aimed at the implementation and compliance with the requirements of Regulation (EU) 679/2016 of 27.04.2016. On the protection of personal data of natural persons and in relation to the processing of personal data and the free movement of data.

"AVANGARD REAL ESTATE.BG" Ltd. is the Administrator of personal data within the meaning of the European legislation and the Legislation of the Republic of Bulgaria for the protection of personal data.

Contact information for the data controller:

"AVANGARD REAL ESTATE.BG LTD.
Registered office and registered address : Plovdiv city, Dragoya Bozhilov 9 str.
UIC:205957825
Contact person : Vanya Karamfilova
Phone : 0883355517
Email: info@avangardrealestate.bg

"AVANGARD REAL ESTATE.BG" Ltd. is the administrator of personal data that will be processed in the course of and in connection with the company's commercial activities, as stated in the TR.

In connection with the implementation of information security requirements, the controller shall take adequate technical and organizational measures, in accordance with the requirements of the legislation on the protection of personal data and/or measures pursuant to other applicable legislation, to ensure an appropriate level of security.

As a personal data controller, AVANGARD REAL ESTATE.BG Ltd. shall consider and ensure an appropriate level of security, taking into account the risks associated with processing in relation to the Services pursuant to the contractual relationship, including the risk of inadvertent or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or processed in any way.

All transfers of personal data to any person in connection with the commercial activity will be carried out under a high level of security and in ways that ensure the protection of personal data as agreed between the parties.

2. Basis for processing personal data. Purposes.

For the purposes of the commercial activity "AVANGARD REAL ESTATE.BG" Ltd. may collect, process and store the following information provided by its counterparties, including information provided via e-mail or the company's website.

Information regarding personal data is requested and received when registering users, customers, in connection with booking events, applying for employment.

In case of interest in the offered offers / properties "AVANGARD REAL ESTATE.BG" Ltd. requires and collects information on personal data, family and judicial status, property status, family relations and information on de facto cohabitation on family basis. The information requested relates solely and exclusively to the relations of AVANGARD REAL ESTATE.BG Ltd. in relation to the activities and services provided in connection with the contractual relationship.

Contracts shall be concluded in writing, and they may also be concluded by consensual acts at the moment of coincidence of wills/agreement on the subject matter of the assigned work, the remuneration due and other elements.

An individual may be identified by an identifier such as three names, an identification number, identity card details, an online identifier or more factors specific to their identity.

A legal entity can be identified by its name, identification code from the Commercial Register Office, registered office and registered address and the person representing it.

To carry out its activities, AVANGARD REAL ESTATE.BG Ltd. collects, organizes, stores, uses, spins personal data in accordance with Article 6, Paragraph 1, letter "a", letter "b" and letter "c" of Regulation No. 679/2016 (EU).

3. Provision of data to third parties outside AVANGARD REAL ESTATE.BG Ltd.

The receipt, processing, handling and storage of personal data by AVANGARD REAL ESTATE.BG Ltd is strictly confidential.

As a personal data controller, AVANGARD REAL ESTATE.BG Ltd. does not disclose or provide personal data to third parties outside the arising legal or contractual grounds or if the data is not publicly available and included in a public register.

"AVANGARD REAL ESTATE.BG" Ltd. provides personal data only in case of necessity in connection with the activities of the company and the contractual relationship.

Outside the cases of general availability of data included in public registers, recipients of data in relation to the activity may be:

- Institutions/state bodies carrying out functions within their competence (Ministry of Interior, NRA, NSSI, Supreme Bar Council, etc.);

- Lawyers /notaries, lawyers, legal advisors and other persons with legal education/ for the preparation of written documents, certification of documentation and other work in connection with the activities of the company;

- Banking institutions with a view to making payments and banking transactions for remuneration and/or in connection with lending;

- Companies carrying out courier activities and delivering parcels in connection with correspondence.

4. Control of access to data in connection with the performance of the activity.

As a personal data controller, AVANGARD REAL ESTATE.BG Ltd. shall take proportionate measures to prevent unauthorized access to the database storing the personal data provided by:

- use of passwords;
- limited access to data storage systems;
- restrictions on the use of removable storage media such as flash drives, CD/DVDs or portable hard drives, and encryption requirements;
- restricted access to information provided and stored on paper;

Personal data shall be processed by AVANGARD REAL ESTATE.BG Ltd. in a manner that ensures a reasonable degree of security and confidentiality of personal data, including the prevention of unauthorized access to personal data or to personal data processing equipment.

5. Rights of legal entities

"AVANGARD REAL ESTATE.BG" Ltd. takes the following security measures to protect the personal data provided to the legal entities in accordance with the imperative rules laid down in Regulation 679/2016:

- Right of access;
- Right to rectification of personal data submitted incompletely or inaccurately;
- Right to restriction of processing;
- Right to erasure in case of application of Article 17 of Regulation 679/2016;
- Right to data portability if the conditions for portability under Article 20 of Regulation 2016/679 are met;
- The right not to be subject to a decision based solely on automated processing, including profiling;
- The right to make requests in relation to the rights described above;

The aforementioned rights may be exercised by making a request in writing (on paper or in electronic form), which should explicitly state the specific request.

Any request made should be signed and sent to the registered office and registered address of AVANGARD REAL ESTATE.BG Ltd.

6. Violation of rights and right to complaints.

In the event of non-compliance with the provisions of (EC) Regulation 2016/679 regarding the protection of personal data provided by legal entities, they may lodge complaints/complaints with the Commission for Personal Data Protection and the Administrative Court.

7. Storage period of the data provided.

7. Storage period of the data provided.

Data related to employment and social security legal relations within the meaning of the Labour Code and CSR will be stored for a period of 50 /fifty/ years.

The remaining data will be stored for a period of 5 /five/ years.

8. Transfer of personal data to third countries or international organisations.

As a personal data controller, AVANGARD REAL ESTATE.BG Ltd. does not provide any personal data to third countries and international organizations. The exception is the necessity of a contract for the performance of assigned work in and on the occasion of the performance of assigned and undertaken obligations.

9. Measures taken by AVANGARD REAL ESTATE.BG Ltd to protect personal data.

In compliance with the mandatory provisions of Regulation 2016/679 for the protection of personal data of legal entities, AVANGARD REAL ESTATE.BG Ltd. adopts internal rules that take measures to effectively protect the personal data provided for processing, as well as to exercise the rights of legal entities.

Information about the measures taken to protect personal data can be obtained by the legal entities upon request from the controller "AVANGARD REAL ESTATE.BG" Ltd.

10. Compliance with the basic principles under Regulation 2016/679 for the lawful storage and processing of personal data.

As a personal data controller, AVANGARD REAL ESTATE.BG Ltd. is committed to processing the data provided by the legal entities in a lawful, fair and transparent manner.

Personal data will be requested, collected, processed and stored for specific, explicit and legitimate purposes and will not be processed in a way incompatible with those purposes.

The controller shall "minimise data" in accordance with the purposes of its activities.

Personal data will be stored in strict compliance with the principles of accuracy, "storage limitation", integrity and confidentiality, accountability.

The information on the protection measures that AVANGARD REAL ESTATE.BG Ltd. takes to protect personal data in accordance with the requirements of EU Regulation 2016/679 of 27 April 2016 will be updated, supplemented and developed in accordance with the mandatory rules of European legislation and the legislation of the Republic of Bulgaria.

"AVANGARD REAL ESTATE.BG Ltd reserves the right and ability to amend its privacy and confidentiality policy.

The changes will be published in a timely manner on the website of the administrator "AVANGARD REAL ESTATE.BG" EOOD in view of the free access to information of legal entities.