Privacy policy

With Regard to The Processing of Personal Data

We consider ensuring the right to personal data protection as a fundamental Profitshare commitment, so we will dedicate all the resources and efforts needed to process your data in full compliance with Regulation (UE) 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as any other applicable Bulgarian legislation. Since one of the key principles of this legal framework is transparency, we have prepared this document through which we want to inform you about how we collect, use, transfer, and protect your personal data when interacting with us about our products and services including through our website or through the applications available on the mobile phone.

We reserve the right to periodically update and modify this Privacy Policy to reflect any changes to the way we process your personal data or any changes to your legal requirements. In the event of any such change, we will display on our website the modified version of the Privacy Policy, which is why we kindly ask you to periodically check the contents of this Privacy Policy.

Who we are and how to contact us

Profitshare is the trade name of Conversion Marketing E.O.O.D, a Bulgarian legal entity, with its registered office in Sofia, 1504, Ul. Sheynovo str. 18, Bulgaria, registered with the Trade Registry of the Registry Agency under no. 203168261, unique tax registration number BG203168261 (hereinafter referred to as “Profitshare”, “we” or “us”). For the purposes of the data protection law, we are a controller when we process your personal data.

Since we are always open to hearing your opinions and providing you with any additional information you may need regarding the processing of your data, we encourage you to contact Profitshare to the e-mail address data.protection@conversion.bg or by mail or courier to the address Conversion Marketing EOOD - Sofia, 1504, Ul. Sheynovo str. 18, Bulgaria .

Which categories of personal data we process

In general, we collect your personal data directly from you, so you have control over the type of information you give us. For example, we receive information from you like this:

When you register and set up your Profitshare account, you are sending us:

• your first, middle and last name;
• phone number;
• email address;
• any other data recorded voluntarily.

For signing the contract, you are sending us:

• national identification number (EGN);
• home address;
• bank account number (IBAN).

To calculate the applicable withholding taxes, you are sending us:

• a declaration for national insurance contributions;
• documents attesting tax-exempt status, if applicable.

We can also collect and then process certain information about your behaviour while browsing our website or using the smartphone application to personalize your online experience.

Our platform logs traffic data (including the IP addresses) provided by the device you use to enter our website or smartphone application to ensure the security and stability of our systems as well as the technical administration of the network infrastructure.

We invite you to find out more details in this regard by consulting the section on processing purposes below.

On our website and in the smartphone application we can store and collect information through cookies and similar technologies according to the Cookie policy.

What are the purposes and grounds of the processing

We will use your personal data for the following purposes:

1. To provide the Service for your benefit

This general purpose may include, as appropriate, the following:

a) Checking consent for entering into the Terms and Conditions of the Service;

b) Creating an Affiliate Account;

c) Identifying Affiliates and providing the Service to them;

d) Performing the payment of the amounts owed, according to Terms and Conditions of the Service;

e) Withholding taxes, in accordance with the legislation in force (income tax, contributions to the social security and health systems, any other withholding taxes);

f) Providing to the Affiliates, upon request, income statements;

g) Sending notifications and non-commercial messages;

h) Reporting and investigation purposes;

i) Providing support services, including providing answers to your questions about the Service and Platform.

Processing your data for these purposes is in most cases necessary for the conclusion and performance of a contract between Profitshare and you. Also, some processing underlying these purposes is required by the applicable law, including the tax and accounting legislation.

2. To improve our services

We always want to offer you the best online experience. For this, we may collect and use certain information about your purchasing behaviour, we may invite you to fill in satisfaction queries or we can conduct, directly or with the help of partners, market studies and research.

We base these activities on our legitimate interest in doing business, always taking care that your fundamental rights and freedoms are not affected.

3. For marketing

We want to keep you informed about the best deals for the products/services you are interested in. In this sense, we can send you any type of messages, through electronic communication channels (e-mail / SMS / mobile push / webpush / etc) containing general and thematic information, information regarding offers and promotions and other business communications, like market research and opinion polls and we can show personalized recommendations on the website and smartphone. In order to provide you with information of interest to you, we may use certain data about your online behaviour to create a profile. We always ensure that such processing is done observing your rights and freedoms and those decisions taken thereon have no legal effect on you and does not affect you in a similar way to a significant extent .

In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by:

• – Changing the settings in the “My account” section

• – Accessing the unsubscribe link displayed in the messages you receive from us; or by

• – Contacting Profitshare using the contact details described above.

In certain situations, we can base our marketing activities on our legitimate interest in promoting and developing our commercial activity. In any situation where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you may, at any time, request us, by the means described above, to stop processing your personal data for marketing purposes, and we will respond to your request.

4. To defend our legitimate interests

There may be situations in which we use or transmit information to protect our rights and commercial activity. These may include:

• Measures to protect the website and the users of the Profitshare platform against cyber attacks;

• Measures to prevent and detect fraud attempts, including the transmission of information to competent public authorities;

• Measures to manage various other risks.

The general reason for these types of processing is our legitimate interest in defending our commercial activity, being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms.

Also, in some cases, we base our processing on legal provisions such as the obligation to safeguard the goods and values provided by the applicable legislation in this matter.

How long do we keep your personal data

As a general rule, we will store your personal data as long as you have an Profitshare account. You may request us at any time to delete certain information or to close the account and we will respond to these requests, subject to the storage of certain information including after the account has been closed, in cases where the applicable law or legitimate interests impose it.

Who we send your personal data to

As the case may be, we may transmit or give access to some of your personal data to the following categories of recipients:

– companies within the same group of companies as Profitshare;

– courier service providers;

– payment / banking service providers;

– marketing / telemarketing service providers;

– market research service providers;

– communications and IT service providers;

– accountants, auditors, lawyers and other professional consultants;

– other business infrastructure providers;

- other companies with whom we can develop joint programs to market our goods and services.

If we have a legal obligation or if it is necessary to protect our legitimate interest, we can also disclose certain personal data to public authorities.

We ensure that access to your data by third-party private law entities is done in accordance with the legal provisions on data protection and confidentiality of information, based on contracts concluded with them.

To which countries we transfer your personal data

We currently store and process your personal data in Bulgaria and Romania.

However, it is possible to transfer some of your personal data to entities located in the European Union or outside the Union, including in countries where the European Commission has not recognized an adequate level of personal data protection.

We will always take steps to ensure that any international transfer of personal data is carefully managed in order to protect your rights and interests. The transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, by other safeguards, such as the standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for Personal Data Protection transferred from within the EU to the United States of America.

You can contact us at any time, using the contact details listed above, to find out more about the countries where we transfer your data, as well as about the safeguards that we have implemented with respect to these transfers.

How we protect the security of your personal data

We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, in line with the industry standards. We keep your personal data on secure servers using state-of-the-art encryption algorithms and ensuring storage redundancy.

Despite the steps taken to protect your personal data, we note that the transmission of information via the Internet in general or via other public networks is not entirely secure, with the risk that the data may be seen and used by unauthorized third parties. We cannot be responsible for such vulnerabilities of systems that are not under our control.

What are your rights

The General Data Protection Regulation recognizes a series of rights with respect to your personal data. You may request access to your data, correct any mistakes in our files, and / or you can oppose the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or to address the courts. As the case may be, you may also have the right to request the deletion of your personal data, the right to restrict your data processing and the right to data portability.

More information about each of these rights can be obtained by reviewing the table below.

In order to exercise your rights, you may contact us using the contact details listed above.

Please note the following if you want to exercise these rights:

Identity. We take seriously the confidentiality of all records that contain personal data. For this reason, please send us your requests regarding such records using the email address of the Profitshare account. Otherwise, we reserve the right to verify your identity by requesting additional information to confirm your identity.

Fees. We will not charge a fee to exercise any right with respect to your personal data unless your request for access to information is groundless, repetitive or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before we resolve your request.

Response time We plan to respond to any valid requests within a maximum of one month, unless this is particularly complicated or if you have made more requests, in which case we will respond within maximum two months. We will let you know if we will need more than a month. We may ask if you can tell us exactly what you want to receive or what you are worried about. This will help us act faster and shorten the response time to your request.

Rights of third parties We do not have to respond to a request if it negatively affects the rights and freedoms of other data subjects.

We remind you that you can contact Profitshare at any time by submitting your request in any of the following ways:

• by e-mail to the address: data.protection@conversion.bg or

• by post or courier to the address: Conversion Marketing EOOD - Sofia, 1504, Ul. Sheynovo str. 18, Bulgaria

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