Privacy Notice

Datе: 05.01.2022

1. Details of the data controller and contact with them

We, Threevita Ltd, UIC: 205364700, contact details: Sofia, 66 Patriarch Evtimiy Blvd., ent. C, floor 1, e-mail: privacy@3veta.com, (also called “the Company” in the document), acknowledge that it is important for you to understand how we collect, store and share personal data processed in the course of our business and in maintaining the 3veta Platform.

The 3veta platform is available at the e-mail address: https://3veta.com  and includes all subdomains through which the system is used, incl. created personal websites of professionals.

2. For whom is this notice intended?

This Privacy notice is intended for all individuals whose personal data we process in the course of our business. Such individuals may be:

1. Visitors to our website;
2. Professionals who use our platform to provide services (natural persons);
3. End Users who use our platform to receive services from professionals;
4. Individuals representing legal entities that have commercial and / or partnership relations with the Company;
5. Employees of legal entities that have commercial and / or partnership relations with the Company, with which the interaction is carried out in relation with the implementation of contracts.

3. To what purpose we process personal data?

We process personal data only for the purpose for which they were collected and do not reuse them for incompatible purposes. Further processing is permissible only for the establishment, exercise or defense of legal claims.

The purposes that require the processing of personal data include:

• Providing the services offered through the 3veta platform – providing access to the platform, providing the selected services, saving information about used services;
• Interaction with clients – when receiving questions, to overcome technical problems, to provide administrative or technical services;
• Analysis and development of the offered services – to track how our product is used and to improve it by changing existing functionalities or by adding new ones;
• Increasing the number of visitors and users of the system – we use what data we have to offer services and conditions that may be of interest to you;
• Organizing our contractual relations – concluding contracts, issuing and receiving payment documents, communication in the implementation of contracts;
• Compliance with legal requirements – e.g. when preserving financial and tax information.

We do not use the data obtained in the implementation of our core business for automated decision-making using computer algorithms that replace human judgment, including through profiling.

4. What personal data do we process and on what grounds do we process it?

The type of personal data we process depends on the purpose for which we need it and the activities in the course of which we receive the data. Processing of personal data is carried out only in the presence of a legal basis for this processing.

4.1. Visiting the website / platform

When you visit the 3veta platform, we register in the so-called log files the following data: IP address; date and time of the visit; browser type and device type used. In case of an error, we will save information about the operating system used by the visitor. The data is stored on our servers for a limited time. We process this information to ensure a connection to the website; to analyze the security of the system to prevent errors in the operation of the site and for other administrative purposes. The basis for the processing of this information is to guarantee our legitimate interests, which consist in achieving the stated goals.

When you visit the website, we create data that we store on your end device. More information about the processed data, the purposes and grounds for their processing is contained in our Declaration on the use of cookies and local storage technology.

4.2. Use of the platform by registered professionals

If you are an individual, all data you provide to us during the registration process and when using the platform are personal data.

Such data are:

• Registration data – names and e-mail; password, photo (at your discretion) – visible to End Users who receive or have received your services and available for viewing when searching through search engines;
• Data for the selected plan – we provide our services against remuneration, therefore it is necessary to process information about the selected plan, the amount of remuneration due, which you have paid us, for issued invoices, if you have requested such;
• Data on past and upcoming events – we store information about the use of the platform in providing you with services such as date and time, End Users and price;
• Payment details – receiving payments from End Users is done through the Stripe platform. To be able to receive payments through the Stripe platform, you need to register your account. The data you need to provide are: the country in which you are located, website, if you have one, description of your business, the area in which you carry out commercial activity, date of birth, name, legal form, UIC, IBAN of the bank account, telephone number for contact. Although the data is provided on the Stripe platform, we also have access to some of it.

We process this data in order to provide you with access to the services offered through the 3veta Platform. The basis for the processing activities is the conclusion and execution of a contract.

4.3. Use of the platform by End Users

In order to use the service provided by the professional through our platform, you need to be registered in the platform. For registration and use of the platform we process the following data:

• Names and e-mails that you provide during registration and which will be visible to the professionals whose services you use or have used;
• Photograph (at your discretion) – visible to professionals whose services you use or have used, and available for viewing when searching through search engines;
• Password;
• Data on past and upcoming events (date and time, supplier and price).

We process this data on the basis of concluding and executing a contract for the use of the Platform to which we are parties.

Payments to professionals are made through the Stripe platform. The platform processes your personal data independently. You can get information about the processing activities performed at: https://stripe.com/privacy . The data you provide when paying the price of the service (card number, validity date, CVC code) is processed by Stripe, and we do not record or process this information in any other way. The Stripe platform provides us with information about the payments made: type of card used and the last 4 digits of its number, your location, currency used, term for periodic payments and e-mail, the amount paid and the professional to whom you paid.

When, while using the platform to receive a service from a professional, you provide personal information during a video call or through an exchange of messages, the responsibility for this information lies with the respective professional. We do not access the exchanged data.

4.4. Administration of contractual relations

To administer the contracts in which we participate, we process the following personal data:

• for the individuals representing legal entities: names, address and contact numbers, e-mail, position, authorization data (only for proxies), etc.
• for the employees of our clients with whom the interaction takes place: names, position, e-mail, contact phone.
• for sole traders – name, unique identification code, registered office and address of management, data for registration under the Value Added Tax Act.

The grounds for these processing activities are the legitimate interests of the data controller, which consist in the effective administration of the contractual relations and the fulfillment of legal obligations provided for in the legislation of the Republic of Bulgaria.

4.5. Answering questions

In order to facilitate the interaction with clients and potential clients, we process data about the persons who have made an inquiry through our site, which include: names and e-mail, as well as any other information that will be provided to us through the contact form. Please do not provide us with information that has nothing to do with our activities!

The basis for these processing activities are the legitimate interests of the data controller, which consist in the effective management of relations with users and potential users.

4.6. Direct marketing

In order to promote our business and to attract new users, we use various forms of direct marketing. We use only the information you have provided to us (for instance, your email address, which you have provided to use with your registration for a promotional campaign) and only with your consent. If you do not wish to receive messages representing direct marketing, you may withdraw your consent at any time through the option contained in the message itself. Withdrawal of your consent has forward implications and does apply retroactively to already received messages.

We use the data obtained through advertising cookies to create behavioral advertising. We use cookies and similar technologies only with your consent.

4.7. Sharing of informational resources

We would like to help you start using or providing online services. That is why we collect and create useful information, that we can later share with you, if you are willing to receive it. In this event, we will regularly send you information about free resources, which we believe could be of interest to you; as well as relevant information about the services we provide.

You can unsubscribe from receiving these emails at any point in time with the ‘unsubscribe’ functionality available at the bottom of each email. Withdrawal of your consent (unsubscribing) has forward implications and does apply retroactively to already received messages.

5. From whom we receive the data?

Most often we receive the data directly from the person to whom it relates, but it is possible that the data is obtained from other persons, e.g. the data on the representatives of the legal entities can be provided to us by other employees or obtained from the public registers.

If you provide us with information about other persons, make sure that you have a reason to provide the data (eg you have the consent of the person) and inform the person about this Privacy Notice.

6. For how long we store data?

We retain personal data only for as long as is necessary to achieve the purposes for which they were collected or as provided by law. Retention periods depend on the type of specific information. According to the requirements of the legislation, the data on our commercial activity are kept for a maximum period of 10 years.

Please contact us in the above ways if you are interested in the retention period for a specific type of information.

7. To whom do we provide your personal data?

In this case, you can provide access to the data for providers that support the activity or provide services necessary for the operation of the platform. Such services may involve technological development and processing of the platform, hosting and data storage, electronic payment, analysis of the proper functioning of the platform, establishing the number of visitors and how to use the platform, managing the electronic correspondence. As our processors, they are obliged to provide a high level of security, and we control the processing activities they perform.

We do not transfer personal data to third countries or international organizations without providing a reliable mechanism to protect your rights in this exchange. A list of the subcontractors we use and the appropriate guarantees provided for data transfer is included in the Agreement on the processing of personal data with the Professionals.

We provide access to End User data only to the Professionals whose services the person has used. The information provided includes: names, e-mail and a photo (where available).

We provide data to the competent state authorities whenever this is provided by law. If there is a reason, we can provide data to private entities that process them as independent data controllers – e.g. banks, postal operators, lawyers (in case of legal disputes), etc.

8. Is your data protected?

Threevita Ltd. undertakes reasonable physical, technical and organizational security measures designed to protect all personal data from loss, misuse, alteration, destruction or damage, as required by law. We determine these measures on the basis of the risks identified by us, we periodically review the measures provided and, if necessary, update them.

9. What rights do you have?

When processing personal data in relation to our commercial activity, Threevita Ltd. conscientiously applies the statutory rules for exercising the rights of data subjects. As a data subject, you have the right to request:

As a data subject, you have the right to request:

1. to be provided with access to your personal data, while respecting the rights of third parties;
2. the removal of inaccurate personal data (including the right to fill in incomplete personal data);
3. the deletion of personal data. Applicable only in the following cases:
   • the personal data are no longer necessary for the purposes for which they were processed;
   • you have withdrawn your consent and there is no other reason for their processing;
   • you object to processing based on our legitimate interests and we cannot prove that our interests take precedence over your rights;
   • the personal data have been processed illegally;
   • deletion is necessary to comply with a legal obligation under Union law or the law of a Member State that applies to the data controller.
4. the limitation of the processing of personal data only to storage when:
   • the accuracy of the personal data is disputed;
   • the processing is illegal, but you object to the deletion of the personal data;
   • we no longer require the personal data, but you still need it to create, exercise or defend a legal claim;
5. the withdrawal of your consent at any time;

The implementation of your right of portability – for data that are processed on the basis of a contract or consent, when their processing is performed in an automated manner.

If you have any questions or concerns regarding the processing of your personal data or wish to exercise any of your rights, please contact us at the following e-mail address: privacy@3veta.com.

In your request, you should provide your names in order to identify yourself as the data subject. Indicate what your request is. Provide the address for correspondence with you (physical address, e-mail address), according to the preferred form of communication. For your convenience, we have prepared a template, that contains instructions on how to send the request and the requirements for each of them.

In order to process your request, we need to identify you. That is why you need to send us your request via the e-mail with which you are registered on our platform or through which we have already communicated (eg when communicating via the contact form). If you use an e-mail other than the one you have already provided, please sign the request form or email with a qualified e-signature.

If necessary, at our discretion, we may request additional identification data as well as an identity document. We will inform you of the reasons that require the provision of additional information.

If you believe that the processing of personal data is illegal or violates your rights, you may file a complaint to the Commission for Personal Data Protection, address: : Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2, with web address: www.cpdp.bg or to the competent court.