Privacy Policy

Create Ex Ltd is a company registered in the Commercial Register of the Registry Agency with UIC: 204702686, e-mail: office@createx.bg.

The grounds and purposes for which we use your personal data

We process your personal data on the following grounds:

• Terms and Conditions of Use of the Website;
• Explicit consent from you – the purpose is stated on a case-by-case basis;
• Subject to a statutory obligation.

In the following paragraphs, you will find detailed information about processing your personal data depending on the basis on which we process it.

For contract performance

We process your personal data to use the Website following the terms and conditions.

Purposes of the processing (where relevant):

• Establish your identity;
• Provide the functionality of our website.

On this basis, we only process personal data in connection with the user profile you have created.

We delete the data collected on this basis 2 years after the termination of the contractual relationship, whether due to the expiry of the contract, termination, or any other reason.

After your consent

We process your personal data on this basis only after your explicit, unambiguous, and voluntary consent. We do not foresee any adverse consequences for you if you refuse the processing of personal data.

Consent is a separate basis for processing your personal data, and the purpose of the processing is set out in it and is not covered by the purposes listed in this policy. If you give us the relevant consent and until you withdraw it or terminate any contractual relationship with you, we make product/service suggestions that are appropriate for you by carrying out detailed analyses of your basic personal data.

Data we process on this basis:

On this basis, we may process personal data for direct marketing purposes, including website usage data and social media profile data.

Provision of data to third parties

On this basis, we may provide your data to marketing agencies such as Facebook, Google, or others.

Withdrawal of consent

Consents granted may be withdrawn at any time. Withdrawal of consent shall not affect the performance of contractual obligations. If you withdraw your consent to the processing of personal data for any or all of the ways described above, we will not use your personal data and information for the purposes set out above. Withdrawal of consent does not affect the lawfulness of processing based on consent given prior to withdrawal.

To withdraw your consent, you only need to use our website or simply contact us using our contact details.

When we delete data collected on this basis

We delete data collected on this basis at your request or 12 months after its initial collection.

How we protect your personal data

To ensure adequate protection of the company's and its customers' data, we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act.

The company has established rules to prevent misuse and security breaches, which support the processes of protecting and securing your data.

To maximize the security of the processing, transmission, and storage of your data, we may use additional security mechanisms such as encryption, pseudonymization, etc.

Rights of Users

Each user of the Site enjoys all the rights for the protection of personal data under Bulgarian and European Union law.

The user can exercise their rights by sending a message to our email.

Each user is entitled to:

• Awareness (in relation to the processing of their personal data by the controller);
• Access to their data;
• Correction (if data is inaccurate);
• Erasure of personal data (right to be forgotten);
• Restriction of processing by the controller or processor;
• Portability of personal data between controllers;
• Objection to the processing of personal data;
• The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them;
• The right to a judicial or administrative remedy if the data subject's rights have been violated.

The user may request deletion if one of the following conditions applies:

• The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• The user withdraws their consent on which the data processing is based, and there is no other legal basis for the processing;
• The user objects to the processing, and there are no legitimate grounds for the processing that override;
• Personal data has been unlawfully processed;
• The personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject;
• Personal data was collected in connection with the provision of information society services to children, and consent was given by the person responsible for the child.

The user has the right to restrict the processing of his/her personal data by the controller when:

• Challenging the accuracy of the personal data. In this case, the restriction of processing shall be for a period that allows the controller to verify the accuracy of the personal data;
• The processing is unlawful, but the user does not wish the personal data to be deleted, but requests instead that its use be restricted;
• The controller no longer needs the personal data for the purposes of the processing, but the user requires them for the establishment, exercise, or defence of legal claims;
• Objecting to processing pending verification of whether the legitimate grounds of the controller override the interests of the user.

Right to portability

The data subject shall have the right to obtain the personal data concerning them, which they have provided to a controller in a structured, commonly used, and machine-readable format, and shall have the right to transfer those data to another controller without hindrance from the controller to whom the personal data have been provided, where the processing is based on consent or a contractual obligation and the processing is carried out by automated means. When exercising their right to data portability, the data subject shall also have the right to obtain a direct transfer of the personal data from one controller to another where this is technically feasible.

Right to object

Users have the right to object to the controller to the processing of their personal data. The data controller shall be obliged to terminate the processing unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims. If you object to the processing of personal data for direct marketing purposes, the processing shall cease immediately.

Complaint to the supervisory authority

Each user has the right to lodge a complaint against the unlawful processing of his/her personal data with the Personal Data Protection Commission or the competent court.