Privacy Policy

 

This policy outlines the basic mindset that GoGoCrypto has with respect to the protection and handling of personal information obtained through business activities.
This Privacy Policy is designed to tell you about the practices regarding collection, use, and disclosure of information that may be collected by us. Please be sure to read this entire Privacy Policy available here, before using or submitting information to the GoGoCrypto website.

1. Consent
By using the Site, you agree to the Terms of this Privacy Policy. Whenever you submit information via the Site, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

2. Information Collected
Personal InformationGoGoCrypto uses fair and proper means to collect your Personal Information (which means information about a living individual which can identify the specific individual by name, date of birth or other description contained in such information (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual) such as your name, date of birth, e-mail address, etc.) to the extent necessary to achieve the purpose for use prescribed in this Privacy Policy.

Information Collected Automatically
GoGoCrypto also automatically collects your IP address and referring website address, browser type, domain name and website access frequency. This information is intended to help facilitate your online experience on the Site. GoGoCrypto uses cookies to track usage patterns on the Site and to control the display of ads, as well as to offer other functionalities. You can turn off cookies, but that will affect your online experience. See below for more detail on cookies.

3. Purposes of Use of Collected Information
GoGoCrypto uses information other than Personal Information you provide for the purpose of fulfillment of your requests and improvement of the Site and materials contained thereon and for any other purposes which we deem reasonable and necessary. GoGoCrypto may, from time to time, produce reports for advertisers, sponsors, Group Companies and vendors containing anonymous, aggregate information about our users and customers, such as demographic, age and online usage information. This information allows GoGoCrypto to provide content and offers that are most relevant to our users to work more closely with advertisers.

GoGoCrypto uses Personal Information only for the purpose described in this Privacy Policy or otherwise. GoGoCrypto uses Personal Information so that we may supply specific information requested by customers, undertake surveys or competitions, etc., send newsletters, mail, e-mails, features, promotional material, surveys and other updates, information or offers to our users. GoGoCrypto also uses collected information to respond to any future problems, such as difficulties in navigating our Sites or accessing certain features. Other uses of Personal Information are described on each Site page on which you record your Personal Information. GoGoCrypto may combine Personal Information with other collected information for the purposes of use unless otherwise specified.

4. Sharing of Collected Information
GoGoCrypto may share your Personal Information as follows:

(1) Joint Users of Personal Information
All companies working for and with GoGoCrypto must comply with our Privacy Policy, and are not permitted to sell or otherwise disclose your Personal Information to third parties except as authorized by us and you, or as permitted or required by law.
(2) Shared Personal DataYour name, address, telephone number, gender, date of birth, occupation and e-mail address.
(3) Purposes of Use of Shared InformationPersonal information is shared to enable joint users to supply specific information requested by customers, undertake surveys or competitions, etc., display or send custom, personalized content to our users and send newsletters, mail, e-mails, features, promotional material, surveys and other updates, information or offers to our users.
(4) Manager of Shared Personal InformationWe can share anonymous, aggregate demographic information, and anonymous information obtained from cookies and similar technologies, with each of our distributors, our sponsors, promotional and business partners, and participating vendors. No Personal Information is disclosed to any of these third parties in sharing such anonymous information.
5. Disclosure to Third PartiesGoGoCrypto will not disclose your Personal Information to any third parties without your consent; provided, however, that GoGoCrypto reserves the right to use or disclose to a third party any information without a customer’s consent in the following circumstances:(i) If it is requested by any laws and regulations;(ii) If GoGoCrypto deems it necessary for protection and security of human life, body or assets (including the Site);(iii) If GoGoCrypto deems it particularly necessary for improvement of public health or enrichment of children’s welfare;(iv) If GoGoCrypto deems it particularly necessary for cooperation with a governmental body or other public organization or its designee in discharging its duties pursuant to the laws and regulations (including investigating breach of laws), or otherwise deems it particularly necessary for the public interest;(v) If GoGoCrypto outsources the handling of personal information to the extent necessary for its business operation.

6. Personal Data Request
(1) The individual customer that is identifiable by the personal information (the “Owner”) may request GoGoCrypto for the notification of the purpose of use of Retained Personal Data as defined in the Japanese Personal Information Protection Law (the “Personal Data”) of the Owner, disclosure of such Personal Data in GoGoCrypto’s possession, correction, addition to or deletion of the content of such Personal Data, cessation of use or deletion of such Personal Data or cessation of supply of such Personal Data to a third party (such request being referred to herein collectively as “Personal Data Request”).
(2) The Owner is requested to submit a Personal Data Request by using the method prescribed on the respective page of the Site on which the Owner recorded the subject personal information or by submitting a written application form prescribed by GoGoCrypto. The prescribed processing fee will be charged if we are requested to deliver a hard copy of our response to the Owner.
(3) In the event of a Personal Data Request, GoGoCrypto will confirm the identity of the applicant and/or the authority if he/she is an agent by one of the following means:(i) Confirmation of the Owner’s Personal Information in our possession such as name, address, telephone number, e-mail address, etc.(ii) Documentary evidence such as driver’s license, passport, basic resident register card, health insurance certificate, certificate of registered seal, etc.(iii) Confirmation by personal phone call, etc. to the Owner.(iv) In the event of an application by the Owner’s agent confirmation of the power of attorney from the Owner.(The agent’s authority will be confirmed by conformance of the seal on the power of attorney with the certificate of registered seal or by personal phone call, etc. to the Owner)(v) Other method of confirmation which GoGoCrypto deems appropriate.
(4) If the applicant’s identity is confirmed pursuant to paragraph (3) above, we will reply in writing or such other means as the Owner and we consider reasonable and respond in the following manner:(i) In the event that the Personal Data Request is for disclosure of Personal Data or notification of purpose of use of Personal Data, we will make disclosure or notification within a reasonable timeframe and to a reasonable extent.(ii) In the event that the Personal Data Request is for correction of, addition to or deletion of Personal Data for the reason that the content of the Personal Data is incorrect, we will correct, add to or delete the incorrect Personal Data within a reasonable timeframe and to a reasonable extent.(iii) In the event that the Personal Data Request is for cessation of use or deletion of Personal Data, or cessation of disclosure of Personal Data to a third party, we will cease use, delete or cease disclosure to a third party within a reasonable timeframe and to a reasonable extent. Please note that if we partly or fully cease use of or delete the Personal Data, or cease disclosure of the Personal Data to a third party, we may be unable to provide services that meet the Owner’s requirements.(5) We may be unable to respond to a Personal Data Request if:(i) We are unable to confirm the applicant’s identity or authority pursuant to paragraph (3) above;(ii) The applicant does not follow the procedures described above;(iii) The information, in relation to which the Personal Data Request is made, does not fall within the definition of Personal Data;(iv) Fulfillment of the request threatens to cause damage or injury to the life, body, assets or other rights or interests of the Owner or a third party;(v) Fulfillment of the request threatens to cause material impediment to our business operation;(vi) Fulfillment of the request constitutes violation of laws and regulations.

7. Web Beacons
Some of our web pages may contain electronic images known as web beacons, which are also called “single-pixel gifs”. These images allow us to count users who have visited those pages and to deliver co-branded services. We may also include web beacons in promotional e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your Personal Information but they are a technique we use to compile aggregated statistics about usage on the Site. Web beacons collect only a limited range of information including the time and date of page view, cookie number and description of the page on which the web beacon resides.

8. Security of Personal Information
We use Secure Sockets Layer (SSL) technology to encrypt important information in an effort to prevent unauthorized access during transmission of your orders over the Internet. We implement standard industry practices internally and with our service providers to maintain the security of your Personal Information depending on its sensitivity and to avoid disclosure of such Personal Information unpermitted under this Privacy Policy.
Although we have implemented systems and procedures to secure the data maintained by us, security during Internet transmissions can never be assured. GoGoCrypto employees are made aware of our privacy practices through periodic communications and training. Our policy is to limit access to Personal Information to those GoGoCrypto employees or agents with a specific need to access or retrieve the information. We store data on multiple service systems, in controlled environments. To maintain security, we conduct internal reviews of our security measures on a regular basis. Please note, however, that any Personal Information you post in chat rooms or message boards is available to anyone. WHILE GOGOCRYPTO HAS TAKEN COMMERCIALLY REASONABLE PRECAUTIONS TO SAFEGUARD PERSONAL INFORMATION, GOGOCRYPTO CANNOT AND DOES NOT GUARANTEE COMPLETE SECURITY OF PERSONAL INFORMATION BECAUSE COMPLETE SECURITY DOES NOT PRESENTLY EXIST ON THE INTERNET.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

9. Transfer of Personal Information
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for GoGoCrypto or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. GoGoCrypto will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

10. Third Party Advertising
Advertisements appearing on our Site may be delivered to users by us or one of our advertising partners. Our advertising partners may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement. In this way, ad servers may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by GoGoCrypto only, and does not cover the use of cookies by any advertisers.

11. Children
We will not knowingly collect Personal Information via the Site from visitors younger than thirteen (13) years of age. We encourage parents to talk to their children about their use of the Internet and the information they disclose on websites.

12. Changes in Corporate Structure
In developing our business, we may engage in the sale or transfer of certain assets and the company itself, or parts of it, may be sold, merged or otherwise assigned. In such transactions and changes in ownership, user information, whether personally identifiable or otherwise, may constitute one of the transferred assets. If required by law, we will notify affected users of such transfer or assignment in accordance with the procedure for changing this Privacy Policy described below.

13. Changes to our Privacy Policy
We will occasionally update this Privacy Policy as necessary to protect our users and to accommodate a changing environment. The changes to our Privacy Policy will be deemed to be effective from the date of posting on our Site unless we specify otherwise. We recommend that you check the Privacy Policy when you visit our Site to be sure that you are aware of and understand our current policy. If we make material changes to this Privacy Policy, we will make efforts to prominently post such changes prior to implementing the change. We will not make any retroactive material changes in how we handle previously collected Personal Information unless you allow us to do so, or unless we are legally required to do so, and in such a case we will make efforts to inform registered visitors of information on material changes to this Privacy Policy via email.

Contact Information for Questions or Complaints
Please contact us if you have any questions, comments or complaints regarding this Privacy Policy, our privacy practices or our treatment of your Personal Information.
Please refer to contact information of GoGoCrypto and the respective Group Companies posted on our Site. The basic mind-set of GoGoCrypto in respect to the protection and processing of (personal) data concerning GoGoCrypto residents can be summarized as follows:

1. GoGoCrypto is the controller within the meaning of the European General Data Protection Act (“GDPR”) for the handling of personal data concerning European residents obtained through the Site(s) in compliance with the obligations set forth by relevant data protection law such as the GDPR, as well as this privacy policy. Which entity is the controller depends on the Site you are visiting. Moreover, depending on the processing activity, other companies within GoGoCrypto may be joint controller(s). Please contact us at [email protected], if you wish to obtain more information.
2. GoGoCrypto will acquire personal data by lawful and fair means.
3. GoGoCrypto will utilize personal data upon making clear the purpose of utilization, and will only use the personal data within the scope of the purpose.
4. GoGoCrypto will not provide acquired personal data to a third party, except in cases described in this privacy policy or the cookie policy.
5. GoGoCrypto will appropriately manage personal data in order to secure its accuracy, and will also take reasonable safety measures in order to prevent leakage, loss, damage, etc. of personal data.
6. GoGoCrypto will manage personal data appropriately and take reasonable safety measures when personal data is utilized internally within the group or by third parties within the scope of its purpose of utilization or if personal data handling is outsourced.
7. GoGoCrypto will announce the procedures regarding inquiries and requests for disclosure of personal data that GoGoCrypto possesses, and will respond promptly and sincerely to such requests. If you accidentally send your inquiry or request to the wrong group company of GoGoCrypto, we will take care that such inquiry or request will be redirected to the correct group company.
8. In order to implement the aforementioned policy items, GoGoCrypto has assigned a privacy department, which can be reached at [email protected]
9. GoGoCrypto will continuously revise and improve its personal data management system and structure in order to effectively protect personal data in accordance with future changes in laws or circumstances.Please be sure to read this entire privacy policy before using or submitting information to the Site. For more information on GoGoCrypto’s use of cookies and similar technologies, please refer to our cookie policy.

1. Legal basis
We will process your personal data obtained through the Site in accordance with applicable law, including the GDPR. When we process your personal data, such processing will be based on any of the following grounds listed in the GDPR:
(a) your consent;(b) the performance of a contract to which you are a party (or in order to take steps at your request prior to entering into a contract);(c) compliance with a legal obligation to which GoGoCrypto is subject;(d) in order to protect the vital interests of you or of another natural person; or(e) legitimate interests of GoGoCrypto or a third party.

2. Purposes for which your personal data may be processed
We may process your personal data obtained through the Site for the following purposes:
(a) to send you information requested by you;(b) to manage your GoGoCrypto account (if any);(c) to send you information about new features that may be relevant for you (d) to ask you to participate in surveys and to manage the outcome of surveys in which you have participated;
(b) to improve your online experience on our websites;
(c) to test information security measures of GoGoCrypto, e.g. by performing pen tests;(g) to send newsletters to you, which messages may be specifically tailored for you(h) to organize joint marketing events with third parties;(i) to satisfy statutory obligations of GoGoCrypto, such as obligations regarding bookkeeping and tax law;(j) for any other purposes made known to you beforehand, e.g. to handle your application for a job or traineeship at GoGoCrypto.

3. Types of personal data we process
We may collect your personal data in the following manner(s):
(a) When contacting us, you may be asked to submit certain personal data, such as contact information 
(b) When you create and maintain a GoGoCrypto account, you may be asked to provide certain personal data, such as name, user name, email address and password, and to keep such personal data up to date.
(c) When you visit and use the Site, our servers automatically record certain data, such as URL, IP address, browser type and language, and the date and time of your visit. Also, we may collect personal data concerning your use of the Site. Your personal data is obtained by cookies and similar mechanisms. The Site will inform you of our use of cookies and similar mechanisms.
(d) By obtaining certain personal data from third parties. We will always ask such third party to confirm that making the personal data available to us is in compliance of law, e.g. because you have consented to such transfer of personal data.When we ask you to submit your personal data, we will indicate which data fields are optional. If you fail to provide us with the obligatory information, we may not be able to adhere to your request (e.g. to create a GoGoCrypto account).

Depending on the purpose of processing, GoGoCrypto may process the following personal data from you: name, contact information, date of birth, gender, etc.
We will not store your personal data for a longer term than necessary for compliance with the storage terms provided for by law and the fulfilment of the purposes as mentioned in this privacy policy.

4. Sharing of personal data
In the event that you provide personal data on the Site, in particular your name, address, telephone number, gender, date of birth, occupation, e-mail address, your response to surveys or competitions, and your requests, we may share internally such personal data. In addition, personal data (e.g. IP-addresses) collected by means of cookies and similar technologies may be shared if you applied the respective approvals. Where we share your personal data within our group, the following principles will be adhered to:
(a) All Joint Users of Personal data, meaning the group companies working for and with GoGoCrypto, must comply with our privacy policy, and are not permitted to sell or otherwise disclose your personal data to third parties except as authorized by GoGoCrypto and you, or as permitted or required by applicable law.
(b) GoGoCrypto has applied adequate safeguards to ensure organizational and technical security measures, including by agreeing on standard contract clauses where your personal data is transferred to group companies that are established outside the EEA.
(c) In exceptional circumstances, GoGoCrypto may share your personal data with other third parties. See Section 7 for more details.
We may make use of processors to support certain of our business functions, such as IT providers that offer storage services. If and insofar as these third parties process your personal data while doing this, they will do so on the basis of a processing agreement in accordance with the GDPR.
We may also share anonymous, aggregate (demographic) information with third parties, such as our distributors, our sponsors, promotional and business partners, and participating vendors.

5. Marketing
Marketing through newsletter and emailsWe may use your contact information to send you newsletters. Also, we may extend e-mail offers to you on behalf of business partners about a particular product or service that may be of interest to you, without sharing your name or e-mail address with or disclosing your name or e-mail address to those business partners. Where required under applicable law, we will only send you such commercial emails if you have consented to receiving such emails.
Sometimes we will give you the opportunity to opt in to receive e-mail offers from third parties not affiliated with us in accordance with applicable laws. If you decide to accept these offers, we will provide, upon your consent, your contact information to the third party. We urge you to review carefully the privacy policies of these firms. We are not responsible for the privacy policies and procedures of any third party.
At any time you may notify us that you no longer wish to receive newsletters or other commercial messages from us via email. We will process your notification in due course and remove you from our mailing list.
Marketing through social media platformsGoGoCrypto may use your profile data like email address or phone number to build audiences in Google, Facebook and other similar channels through a protected way of processing your data, also called hashing. The purpose is to use these audiences to increase the relevancy of ads shown to you. This means that you will either see ads that are relevant based on your interests and/or you will be excluded from seeing ads that are not relevant.
Based on the audiences that are built, you will be shown ads on websites or apps that are part of the network of Google, Facebook and other similar channels.
Based on past visits to GoGoCrypto website or apps and your acceptance of Targeted advertising cookies, audiences will be built to show you relevant ads via Google, Facebook and other similar channels.

Opting out
After you have opted in via the acceptance of cookies or registration for promotional updates, you can always opt out by the below options:
– At any time you can opt out from our promotional emails by hitting the unsubscribe button at the bottom of the mails
– At any time you can opt out from the use of cookies by visiting the settings of Google, Facebook or other similar channels

6. Disclosure to third parties
We reserve the right to use or disclose to a third party any information without your consent in the following circumstances:
(a) If it is requested by any laws and regulations, in order to comply with legal obligations GoGoCrypto is subject to;
(b) If we deem it necessary for protection and security of vital interests of you or third parties, including human life, body or assets (including the Site), such as for improvement of public health or
(c) If we deem it particularly necessary for cooperation with a governmental body or other public organization or its designee in discharging its duties pursuant to the laws and regulations (including investigating breach of laws), or otherwise deems it particularly necessary for the performance of a task carried out in the public interest;
(d) If we outsource the handling of personal data to the extent necessary for its business operation.
We will use best efforts to inform you prior to such disclosure, including of the recipient of your personal data, by means of this privacy policy or, if appropriate, we will make efforts to inform you via other methods (e.g. email) when you are a registered visitor.

7. Cookies
We may collect and process information, including personal data, using cookies and similar technologies when you visit and use the Site. For example, we may collect URL, IP address, browser type and language, and the date and time of your visit. Also, we may collect personal data concerning your use of the Site. Please go to our cookie policy for a detailed overview on how we handle cookies and similar technologies.
Moreover, our advertising partners may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement. In this way, ad servers may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. Please go to our cookie policy for more information.

8. Security of personal data
We maintain state of the industry security measures to avoid unauthorized access to, alteration, disclosure or loss of your personal data. For example, we use Secure Sockets Layer (SSL) technology to encrypt important information in an effort to prevent unauthorized access during transmission of your orders over the Internet. We implement standard industry practices internally and with our service providers to maintain the security of your personal data depending on its sensitivity and to avoid disclosure of such personal data unpermitted under this privacy policy.
Although we have implemented systems and procedures to secure the data maintained by us, security during Internet transmissions can never be assured. GoGoCrypto employees are made aware of our privacy practices through periodic communications and training. Our policy is to limit access to personal data to those GoGoCrypto employees with a specific need to access or retrieve the information. We store data on multiple service systems, in controlled environments. To maintain security, we conduct internal reviews of our security measures on a regular basis. Please note, however, that any personal data you post in chat rooms or message boards is available to anyone. While we have taken commercially reasonable precautions to safeguard personal data, we cannot and do not guarantee complete security of personal data because complete security does not presently exist on the Internet.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We also recommend not to re-use passwords on other websites.

9. Transfer of personal data
We may transfer your personal data collected through the Site to, and store at, a destination outside the European Economic Area (“EEA”). For example, GoGoCrypto staff working outside the EEA may access and further process your personal data. GoGoCrypto will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy and applicable data protection laws, including the GDPR. For example, GoGoCrypto may use contracts approved by the European Commission for the transfer of data to such destinations.

10. Links to websites of others
The Site may contain hyperlinks to third party websites, or embedded content of third party websites. The privacy policy of third parties are subject to the processing of personal data by third parties. GoGoCrypto is not responsible for the content of these third party websites and the processing of personal data by these third parties.

11. Children
We will not knowingly collect personal data via the Site from visitors younger than thirteen sixteen (16) years of age. We encourage parents to talk to their children about their use of the Internet and the information they disclose on websites. If you are younger than 16 and wish to visit the Site, you may only provide your personal data to GoGoCrypto if you have obtained permission from your parent(s) or your legal representative(s).

12. Changes in corporate structure
In developing our business, we may engage in the sale or transfer of certain assets and GoGoCrypto itself, or parts of it, may be sold, merged or otherwise assigned. In such transactions and changes in ownership, user data, whether personal or otherwise, may constitute one of the transferred assets. If required by law, we will notify you of such transfer or assignment in accordance with the procedure for changing this privacy policy described in section 15 below.

13. Your rights
You have the right to request from GoGoCrypto access to and rectification or erasure of personal data or restriction of processing concerning you or to object to processing as well as the right to data portability.
Where the processing of your personal data is based on your consent, you have the right to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint about our processing of your personal data with the Dutch Data Protection Authority (Autoriteit persoonsgegevens) or the possible competent supervisory authority in your country.
You may invoke any of these rights by sending your request to: [email protected]
We reserve the right to refuse any requests if your identity cannot be demonstrated by you and/or we can invoke any of the exceptions stated in the GDPR. In such a case, we will inform you of the refusal.

14. Changes to our privacy policy
We will occasionally update this privacy policy as necessary to protect our users and to accommodate a changing environment. The changes to our privacy policy will be deemed to be effective from the date of posting on our Site unless we specify otherwise. We recommend that you check the privacy policy when you visit our Site to be sure that you are aware of and understand our current privacy policy. If we make material changes to this privacy policy, we will make efforts to prominently post such changes prior to implementing the change. We will not make any retroactive material changes in how we handle previously collected personal data unless you allow us to do so, or unless we are legally required to do so, and in such a case we will make efforts to inform visitors of information on material changes to this privacy policy.

15. Contact information for questions or complaints
Please contact our privacy department if you have any questions, comments or complaints regarding this privacy policy, our privacy practices or our treatment of your personal data, using the following contact details:
[email protected]
This privacy policy was last updated on 1 April 2021.

*Please note that this privacy policy also applies to any processing of personal data concerning non-EU residents obtained through the Site to which the GDPR applies.

Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). 

Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:・To fulfill or meet the reason for which the information is provided. 
・To provide you with information that you request from us.
・To provide you with email alerts, that may be of interest to you.
・To improve our website and present its contents to you.
・For testing, research, analysis and product development.
・As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
・To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
・To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information
We may disclose your personal information to a third party for a business purpose.
When we disclose personal information for a business purpose, we enter an agreement that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We disclose your personal information for a business purpose to the following categories of third parties:
・Our affiliates.
・Service providers.
・Third parties to whom you or your agents authorize us to disclose your personal information.

Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights
・To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at [email protected]

The verifiable consumer request must:
・Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
・Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Contact Information
If you have any questions or comments about the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under Bulgaria law, please do not hesitate to contact us at [email protected]

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