PRIVACY POLICY

Freelancers Incubator, part of Net Ai Ti LTD. with registered office in Sofia, 91 Alexander Malinov Blvd., office 601, UIC 201655701 (hereinafter referred to as Net It) carries out its activities in accordance with the Personal Data Protection Act and Regulation (EU) 2016 / 679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation) , hereinafter referred to as GDPR.

This information aims to inform users about all aspects of the processing of their personal data by the Freelancers Incubatorand about the rights they have in relation to this processing.

Information about Freelancers Incubator, which processes personal data:
Name: Freelancers Incubator, part of Net Ai Ti Ltd Bulgaria
Company Number: BG175273680
Correspondence address: blv. Al. Malinov 51, Sofia 1000
Email: info@freelancersincubator.com
Website: https://freelancersincubator.com

Grounds for collecting, processing and storing personal data

Art. 1. Freelancers Incubatorcollects and processes personal data in connection with the use of the sites www.netit.bg, www.designacademy.bg, www.accountingacademy.bg, www.softwareacademy.bg, www.marketingacademy.bg and the e-shops to them, and such exist for the purpose of creating user profiles and concluding contracts with users, and in particular in connection with one or more of the following legal bases:
• Explicit consent from the user;
• Fulfillment of the obligations of Freelancers Incubatorunder a contract with the user;
• Compliance with a legal obligation that applies to the Freelancers Incubator;
• For the legitimate interests of the Freelancers Incubatoror a third party.
• Objectives and principles in the collection, processing and storage of personal data

Art. 2. (1) Freelancers Incubatorcollects and processes personal data provided by the user in connection with the use of e-shops of the company and the conclusion of sales contracts with Freelancers Incubator, including for the following purposes:
• creating a user profile and providing full functionality when using the e-shop;
• individualization as a party to a contract;
• accounting purposes;
• statistical purposes;
• protection of information security;
• ensuring the performance of the contract for the provision of the respective good or service;
• sending newsletters and emails with special offers with the consent of the user;
• remarketing;
• telephone and sms marketing and advertising, with the consent of the user;
(2) Freelancers Incubatorobserves the following principles in the processing of personal data:
• legality, good faith and transparency;
• limitation of processing purposes;
• relevance to the purposes of processing and minimizing the data collected;
• accuracy and timeliness of the data;
• limitation of storage in order to achieve the objectives;
• integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.
(3) Freelancers Incubatormay process and store personal data in order to protect its following legitimate interests:
• fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal bodies.

Types of personal data that are collected, processed and stored

Art. 3. (1) Freelancers Incubatorperforms the following operations with the personal data provided by the user, in view of the described following purposes:
• User registration in e-shops and execution of a sales contract - the purpose of this operation is to create a profile for using the e-shop to purchase services.
• Sending a newsletter - the purpose of this operation is to administer the process of emailing a newsletter with notifications of promotions, new courses, seminars and new features to those users who have stated that they wish to receive them.
• Exercising the right to refuse or make a complaint - the purpose of this operation is to administer the process of exercising the right of refusal or complaint by the user for the services in respect of which these rights may be exercised.
(2) Freelancers Incubatordoes not collect or process personal data relating to the following:
• reveal racial or ethnic origin;
• reveal political, religious or philosophical beliefs, or trade union membership;
• genetic and biometric data, data on sexual life or sexual orientation.
(3) Freelancers Incubatordoes not perform automated decision-making on the basis of personal data.

Purposes and grounds for personal data processing

Art. 4. (1) Freelancers Incubatorprocesses the following categories of personal data and information for the following purposes and on the following grounds:

Individual data (names, email, etc.)

• Purpose for which the data is collected: 1) Making contact with the user and sending information to him, 2) for the purposes of user registration in e-shops, and 3) for sending by email, SMS or by phone of information with announcements about promotions, new courses, seminars and new functionalities.

• Grounds for personal data processing: By accepting the general terms and conditions and registering in the e-shops or concluding a written contract, a contractual relationship is created between Freelancers Incubatorand the user, on which basis Freelancers Incubatorprocesses the personal data of this consumer (Article 6, paragraph 1, item "b" of the GDPR). The data needed to send a newsletter are processed on the basis of explicit consent given by the user (Article 6, paragraph 1, item "a" of the GDPR).
Term of storage of personal data

Art. 5. (1) Freelancers Incubatorstores personal data for a period not longer than the existence of the user profile in one of the company's sites.
(2) After deleting the user profile, Freelancers Incubatortakes care to delete and destroy all user data without undue delay or to anonymize them (ie to bring them in a form that does not reveal his identity). /> (3) Freelancers Incubatorstores personal data provided in connection with online orders for the duration of the user profile, and the accounting documents in connection with an order are stored for the relevant statutory period.
(4) Freelancers Incubatorundertakes to notify the user in case it is necessary to extend the period of storage of his personal data in order to fulfill a regulatory obligation or in view of the legitimate interests of Freelancers Incubator.

(5) Freelancers Incubatorstores personal data in respect of which there is a statutory requirement for storage under applicable law, for the relevant period, which may exceed the period of existence of the user profile or the time of completion of the order. > (6) The user passwords with which the personal data of all users of the Freelancers Incubatorsites are protected are encrypted.

Transfer of personal data for processing

Art. 6. (1) Freelancers Incubatormay at its own discretion transmit part or all of the user personal data to suppliers (such as courier or Bulgarian Post) and to other persons to process personal data in order to fulfill the purposes of processing, with which the user has agreed in accordance with this Policy, subject to the requirements of the GDPR.
(2) Freelancers Incubatorundertakes to notify the user in case he has to transfer part or all of his personal data to third countries or international organizations.

Access to personal data and data portability

Art. 7. (1) Each registered user has the opportunity through his user profile to check and edit the data processed by the Freelancers Incubatorfor him. This is done by logging in with a password set by the user, which is encrypted and not subject to recognition by employees of the Freelancers Incubator.
(2) Each user has the right to request and receive from the Freelancers Incubatorconfirmation whether personal data related to him are processed.
(3) Freelancers Incubatorprovides the processed personal data to the user in electronic form to the email address associated with the user profile.

Correcting or filling in personal data

Art. 8. Each user can correct or fill in their personal data directly through their user profile on the website or by sending an email.

Withdrawal of consent to the processing of personal data

Art. 9. (1) A user who does not wish all or part of his personal data to continue to be processed by the Freelancers Incubatorfor specific or for all purposes of processing, may at any time withdraw his consent for processing by request by email .

(2) With the withdrawal of the consent for processing of personal data, which are obligatory for the creation and maintenance of a profile on the sites of the Freelancers Incubator, the user profile will be deactivated. In this case, the user can continue to browse the sites and products offered or make a new registration.

(3) If there is an received order, which is in the process of processing, the earliest moment in which the user under this order can withdraw his consent for processing is at the successful completion of the order.
(4) The user may at any time withdraw his consent to the processing of personal data for the purposes of profiling or direct marketing.

Deleting personal data ("to be forgotten")

Art. 10. (1) A user who does not wish all or part of his personal data to continue to be stored by the Freelancers Incubator, may at any time express his desire to delete this data.
(2) Freelancers Incubatorhas no obligation to delete personal data if it stores and processes:
• to exercise the right to freedom of expression and the right to information;
• to comply with a legal obligation requiring processing provided for in EU or national law, or for the performance of a task in the public interest or in the exercise of official powers conferred on the Freelancers Incubator;
• for reasons of public interest in the field of public health;
• for archiving purposes in the public interest, for scientific or historical research or for statistical purposes;
• to establish, exercise or defend legal claims;
• when the data is required to be stored for a certain period of time by law;
(3) In case of exercising the right to delete personal data, Freelancers Incubatordeletes all user data, except for the following information:
• information needed to verify that the request for deletion of personal data has been fulfilled;
• technical information about the functioning of the sites, which cannot be connected in any way with the user's personality;
• data on the person required to be stored by law, such as the Vocational Training Act;
(4) Freelancers Incubatordoes not delete the data that it has a legal obligation to store, including for protection in connection with court claims or for proving its rights.

Profiling

Art. 11. (1) Freelancers Incubatorperforms profiling and may, at its discretion, include a user profile in a user loyalty group, which guarantees higher discounts for individual or for all services provided by Freelancers Incubator.
(2) The user may at any time object to the processing of personal data by the Freelancers Incubatorfor the purposes of profiling.

Direct marketing and targeted advertising

Art. 12. (1) Freelancers Incubatorperforms direct marketing by sending newsletters, text messages and making phone calls for notices of promotions, new courses and seminars organized by the company.
(2) The newsletter shall be sent by e-mail only to users who have agreed to receive the newsletter.
(3) The user may at any time unsubscribe from his subscription by following the instructions in each e-mail through which to unsubscribe. Unsubscribe with one click.

Manner of exercising rights

Art. 13. (1) For the purpose of certifying identity between the person to whom the data refer and the person, who has made requests under art. 7–12, the user can exercise all his rights through the functionalities of his user profile in the e-shops of Freelancers Incubator.
(2) Freelancers Incubatordoes not refuse to provide information upon request made by email request@netit.bg or otherwise. In such a case, the Freelancers Incubatorhas the right and obligation to verify the identity between the person to whom the data relate and the person who made requests under Art. 7–12.

(3) The provision of the services under art. 7-12 is free, but Freelancers Incubatorreserves the right to charge a service fee in case of recurrence or excessive requests.

User rights in case of personal data breach

Art. 14. (1) If Freelancers Incubatorfinds a violation of the security of personal data of a user, which is of a nature to pose a risk to his rights and freedoms, without undue delay will notify him by email of the violation and the measures have been taken or are about to be taken.

(2) Freelancers Incubatoris not obliged to make such a notification when:

• take appropriate technical and organizational protection measures with regard to data affected by the security breach;
• subsequently take measures to ensure that the infringement does not lead to a high risk to the rights of the consumer concerned;
• Notification would require a disproportionate effort.
Persons to whom personal data are provided
Art. 15. For the purposes of processing personal data and providing goods and services and in order to fulfill the interests of the user, Freelancers Incubatormay provide personal data to persons processing personal data with the following functions:
• Personal data processor: In fulfillment of the objectives and the grounds specified in Art. 4.
• For email campaigns: Mailchimp
• For advertising and retargeting: Google, Facebook
• For email correspondence: HelpScout.com

The specified processors of personal data comply with all requirements for legality and security in the processing and storage of personal data.

Transfer of personal data to third countries

Art. 16. (1) Freelancers Incubatordoes not transfer personal data to third countries.

(2) If at the request or with the consent of a user a transfer of personal data to a third country is required, the Freelancers Incubatorshall describe the possible risks for the transfer in case there is no solution for adequate protection and appropriate means of protection.

Competent supervisory authority

Art. 17. In the event of a breach of his or her rights under the above or applicable data protection legislation, any user has the right to lodge a complaint with the Data Protection Commission as follows:

Data Protection Commission

National Commission for Informatics and Liberties (CNIL)
3 Place de Fontenoy TSA 80715
75334 PARIS CEDEX 07

Changes to the privacy policy

Art. 18. Freelancers Incubatormay change its Privacy Policy by posting a notice on its website.