We, the EstateAssistant Team, value highly your privacy. In the hereby Privacy Policy (“Policy), We describe how We use your personal data (“Personal Data”) which We collect upon the delivery of our services (“Services”) through the EstateAssistant Mobile Application (“Application”).
This Policy describes how We may collect, use, protect or otherwise process your Personal Data in accordance with the applicable data protection legislation, including the General Data Protection Regulation (GDPR), the Bulgarian Personal Data Protection Act and Google Play Policy Requirements.
By registering, downloading, installing, accessing, activating or otherwise using our Application and Services, you acknowledge the terms and the practices described in this Privacy Policy, including without limitation with respect to the collection and processing of your collected information as set forth herein.
Personal Data (or Data) - Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data - Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User - The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject - The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor) - The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller.
Data Controller (or Owner) - The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application - The means by which the Personal Data of the User is collected and processed.
Service - The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU) - Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookies - Small sets of data stored in the User's device.
1. Owner and Data Controller
Estate Assitant Ltd. (“Controller”, “We”) is a legal entity duly entered into the Commercial Register at the Registry Agency of the Republic of Bulgaria with UIC 203088413, having its seat and registered address at: Sofia 1229, Bulgaria, 1 Vrabnitsa residential quarter, block 538, entrance B, floor 3, apartment 33.
We act as a Data Controller within the meaning of the European Data Protection Law (the General Data Protection Regulation 2016/679).
2. General Principles
EstateAssistant is committed to ensuring transparency by compliance with relevant legislative acts such as the General Data Protection Regulation, as well as with specific policy requirements, like Google Play’s, aimed at safeguarding the Users’ privacy rights. It is important for us to notify our Users that we may collect and/or use Personal Data that is essential information (“Essential Information”). Essential information is Personal Data that We receive from Users of the Application necessary for the functionality and use of the Service(s) (see section 3.1.1. below). We need Users’ Essential Information in order to provide the requested Service(s).
When processing Personal Data, we adhere to general principles such as:
3. Types of Data collected and Use
3.1. What Data do We collect from you?
Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Essential Information; Cookies; Usage Data. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its Services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
In the table below you’ll find an overview of the Personal Data We may collect from you, for what purposes We collect the Data, on which legal basis We process your Personal Data and how long We retain your Personal Data:
| Purpose | Personal Data | Legal basis | Retention Period |
|---|---|---|---|
| Registration and authentication (see also section 3.1.2. below): |
|
Necessary for the performance of a contractual obligation We have towards you or to take steps at your request before entering into an agreement. | The Personal Data of your user account will be stored until the moment you withdraw your consent by requesting the deletion/erasure of your Personal Data. |
| To deliver the requested Services like contact organisation, reading call history, task management, scheduling meetings for real estate enterprises: | Essential Information such as:
|
Your consent.
Also necessary for the performance of a contractual obligation we have towards you – and to provide you with the Service – or to take steps at your request before entering into an agreement. |
The personal data of your user account will be stored until the moment you withdraw your consent by requesting the deletion/erasure of your personal data. |
| For communication purposes – to contact you and provide you with customer support when requested: |
|
Necessary for the performance of a contract with you. Necessary to protect our legitimate interest as well – providing and personalising our services. | No longer than it is necessary for fulfilling the purposes the Data has been initially collected for. |
| To personalise your customer experience and to provide content, suggestions and offers that you may be interested in, as well as to improve the quality of our Services: |
|
Your consent. | Personal data collected through Cookies and similar technologies will be processed until your preferences for the use of Cookies change. |
| For marketing purposes - to send you notifications and bulletins about our products and Services or any such offered by our partners: |
|
Your consent. | The Personal Data required to send communication will be processed until you withdraw your consent to receive any such communication. |
| To maintain a followers’ base on social media and to provide our followers with access to special posts, publications and materials in our social media accounts (e.g. Facebook, Twitter, Telegram, etc.) |
|
Necessary to protect our legitimate interest - providing and personalising our Services. | Personal data will be processed until you stop following us on social media. |
3.1.1. Essential Information. Call history In order for us to be able to deliver the requested Service(s), the Application will also require permission (in accordance with the applicable Permissions Policy Requirements of the provider like Google Play) to access Essential Information from the User’s device and read and/or modify:
3.1.2. Registration and Authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service:
Google OAuth (Google Ireland Limited)
Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Calendar widget (Google Ireland Limited)
Google Calendar widget is a calendar content visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy. Privacy Shield participant.
The use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited use requirements.
3.2. How do We use the stored Data?
a) We use Data from User and/or User devices:
b) We use Usage Data and Data from Cookies:
4. Do We use Cookies?
Our Application and Website use Cookies. Cookies do not typically contain any information that personally identifies a User but Personal Data that We store about you may be linked to the information stored in and obtained from Cookies. We use the following types of Cookies:
You have the ability to change your Cookie preference at any time by changing your browser options. To block Cookies in a particular browser, learn more here:
The refusal of Cookies may result in a limitation of functionality or in an inability to use the Services of our Website and Application.
5. Disclosure of Personal Data to Third Parties
The collected Personal Data is not sold, exchanged or in any other way transferred to outsiders. It may be made available to the judiciary, if legitimately requested and if necessary to comply with the law, the rules of the Application or to ensure protection of ours and other persons’ rights, property or safety. All information collected that does not qualify as Personal Data or does not contain classified information may be provided to other parties for marketing, advertising or other similar use.
6. Data Security
The Owner takes all possible technical and organizational measures, recognized by the applicable data protection legislation, in order to protect all Data that may be stored and/or processed. We ensure all required technical and organizational measures, including but no limited to data encryption, in order to protect the data from accidental or illegal destruction or from accidental loss, from unauthorized access, amendment or distribution, as well as other illegal forms of processing. There are policies and procedures designed to protect information from loss, misuse and improper disclosure. Although We work hard to protect your personal information, We cannot guarantee that our actions will prevent any unauthorized attempt to access, use or disclose personal information. However, if you consider that there is a threat to the security of your Personal Data, please contact us immediately via the contact options specified in section 11 of this Privacy Policy.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. To the extent that We may transfer and store Personal Data to a third country outside the EEA that does not provide an adequate level of protection, in any such case We shall implement appropriate safeguards to protect the Personal Data as per the applicable data protection rules and regulations. In the event of any need to transfer collected Personal Data outside the EU, We guarantee a high level of data protection through contractual clauses or other instruments recognized by applicable law.
We ensure additional information security measures, including access control, strict physical protection and reliable practices for collecting, storing and processing information. Data processing is further ensured by using measures that are consistent with the modern technological achievements as via SSL technology.
7. Your Privacy Rights
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document (section 11).
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through a written request at: office@estateassistant.eu. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
8. Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal Personal Data upon request of public authorities.
Governing Law & Controlling Authority
The governing law and jurisdiction to matters relating to Personal Data protection shall be the applicable laws and regulations of the Republic of Bulgaria. Controlling authority for data protection in Bulgaria is the Commission for Data Protection at address: 1592 Sofia, 2 Blvd. Tsvetan Lazarov; telephone number: 02 915 3555. More information about data protection can be found on the website of the controlling authority at (URL) www.cpdp.bg.
Additional information about User's Personal Data
In addition to the information contained in this Privacy Policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this Policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact details (section 11).
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services the Application uses, honor the “Do Not Track” requests, please read their privacy policies.
Changes to this Privacy Policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
9. Data Retention
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
10. Minimal Age
We do not collect or process Personal Data which is provided by persons under the age of majority according to their jurisdiction without the consent of their parents or legal guardians. The Controller shall delete all information provided by or regarding Users who are under the respective age of majority and did not get the consent of their parents or legal guardians for the use of the Application, Services and content.
11. Contact us!
If you have any questions or complaints with respect to the processing of your Personal Data, please contact us via:
Email: office@estateassistant.eu
Estate Assistant Ltd. | 2021 ©