“Inclusive Bulgaria” AD (“Company,” “Administrator,” “We”) acknowledges the need for adequate protection of personal data of data subjects (“You,” “Your,” “You”) and is committed to respecting your privacy. This Privacy Policy (“Policy”) is created to help you understand how we collect, use, and protect your personal data, including when you agree to use our website.

For the purposes of its activities as a real estate transaction intermediary, the Company processes your personal data in strict compliance with Regulation (EU) 2016/679 (General Data Protection Regulation) (GDPR), the Personal Data Protection Act, and other applicable regulations and the Policy.

According to the General Data Protection Regulation:

“Personal data” means any information related to an individual or an identifiable individual (“data subject”).

“Processing” means any operation or set of operations performed on personal data or sets of personal data by automated or other means.

“Controller” means a natural or legal person, public authority, agency, or other body that determines the purposes and means of processing personal data, alone or jointly with others.

“Processor” means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

“Recipient” means a natural or legal person, public authority, agency, or other body to whom personal data is disclosed, whether or not it is a third party.

This Policy provides information on:

Data identifying the Controller and its contact details

Data subjects whose personal data are processed

Categories of personal data

Purposes for which personal data is processed

Legal basis for processing personal data

Recipients of personal data

Retention periods for personal data

Rights of data subjects and methods to exercise them

Giving and withdrawing consent

Right to complain to the supervisory authority

Data security measures

Data identifying the Controller and its contact details

The personal data controller is “Inclusive Bulgaria” AD, located at: Sofia, Blvd. Todor Alexandrov №71 / Opalchenska metro station /, email: office@inclusive.bg; website – https://inclusive.bg/; phone/fax: 0889365036

Categories of personal data

The Company processes the following categories of personal data, ensuring their accuracy:

· Full name, unique civil number, date and place of birth, ID card number and issue date, address, phone number, email, bank account, income, photos, marital status, comments;

· Personal data contained in CVs and Visa L-1;

· Special category of personal data related to the health status of the Company’s employees.

Data subjects whose personal data are processed

The Administrator processes personal data of the following categories of data subjects:

· Clients;

· Personnel – current and former employees;

· Job applicants;

· Petitioners, applicants, complainants, and claimants;

· Partners.

Purposes for which personal data is processed

When you provide personal data to the Company through any of the contact forms, we may contact you to make offers or provide services of interest to you. The Administrator also processes personal data for the following purposes:

· Providing consulting services in the field of real estate;

· Complying with labor and social legislation requirements concerning employees;

· Contract conclusion;

· Compliance with legal obligations related to accounting, tax laws, anti-money laundering, and other laws obliging the Administrator to process personal data in real estate transactions;

· Marketing and advertising information;

· Maintenance and security of the Company’s website and information systems;

· Protection of the Administrator’s legitimate interests.

– Primary accounting documents for tax control, audits, and subsequent financial inspections are to be retained for five (5) years, starting from January 1 of the reporting period following the reporting period to which they pertain;

This Policy may be amended periodically to comply with applicable legal requirements or in the event of changes to the Company’s operations. The new version of the Policy will be published on the Company’s website.