Privacy policy

This privacy policy (the “Policy”) is intended to inform you what personal data we at Street Guru Ltd. (“Street Guru” or “we/us/our” as applicable) collect, why we collect it and how we process them, as well as what your rights are as subjects of personal data and how you can exercise them.

The policy has been developed and adopted in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC ("GDPR"), as well as with the applicable Bulgarian legislation.

This Policy applies when using our website https://imotco.bg (the "Site" or "Platform"), as well as the services provided through the Platform.

Please read the Privacy Policy carefully before using the Site. By using the Site, you consent to the collection and processing of your personal data in accordance with this Policy.

PERSONAL DATA

What is personal data

Personal data is any information relating to an identified natural person or an identifiable natural person. Different pieces of information collected together that can lead to the identification of a specific individual also constitute personal data.

What personal data we collect

Information you provide to us

We collect the following information that you provide to us through:

The form for registration and profile on our Site:
Name and surname
E-mail address
Phone number
Invoice data (when placing an order for a service provided by the Site)
In case of a broker who works for a specific agency - data about the legal entity - agency
In the case of a broker profile - a photo
In the case of a broker profile - other information that the broker may decide to provide to us in the form of a short biography.
The contact form on our Site:
Name and surname
E-mail address
Phone number
Other information you consider necessary when communicating with us
Payment information
Street Guru does not receive or store information about the cardholder when purchasing any of the paid services on the Site using the payment methods of the Platform. This data is processed by the online payment service provider. For more information, please refer to the respective provider's privacy policy:

Information we collect from third parties

We may receive information about you from other sources. We may add this information to the information we have already collected from you through our services in order to improve them.

Typically, personal data collected by third parties is personally identifiable information such as: IP address, advertiser identifiers and device identifiers, etc. This information is always anonymous.

Links to privacy policies of third parties - service providers used by the Site:

Google Analytics 4
Google Search Console
Google Tag Manager
Hotjar
Information for persons under 18 years of age

We provide services and allow our Platform to be used only by persons over the age of 18. If you are under the age of 18, please seek the assistance of a person at least 18 years of age to use our Services.

If we become aware that we have collected personal data from a person under the age of 18, we will immediately delete it, unless we are legally required to retain such data.

Please contact us if you believe that we have mistakenly or unknowingly collected information from a person under the age of 18.

FOR WHAT PURPOSES AND ON WHAT BASIS DO WE USE YOUR PERSONAL DATA

To provide the Street Guru services for your benefit
This general purpose may include, as appropriate, the following:

Creating and managing a profile on the Platform;
Use of the services provided by the Site;
Processing requests for paid services;
Reimbursement of value of services according to legal provisions
The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between you and Street Guru. In addition, the fulfillment of these purposes requires processing under applicable law, including tax and accounting law.

Answer to your inquiries
We collect the data you provide to us when you send us an inquiry for the purpose of responding to you and we collect it based on your consent.

Improving our services
We would like to always offer you the best experience using Street Guru services. For this purpose, we may use certain information about your user behavior, invite you to complete satisfaction surveys directly or through partners, market surveys and other research. The purpose of these communications is to streamline the work of the end user.

We base these activities on our legitimate interests in carrying out

of our business activity, always ensuring that your fundamental rights and freedoms are unaffected.

For direct marketing
We require your prior express consent to send you various marketing communications. You can change your mind and withdraw your consent at any time by:

- you use the "Unsubscribe" link in the messages you receive from us; or

- contact us using the contact details below.

Protection of our legitimate interests
There may be instances where we use or disclose information to protect our rights and our business. These may include:

measures to protect the Site and the users of the Site 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 main reason for these types of processing is our legitimate interests related to the protection of our commercial activity, with the proviso that we ensure that all measures taken by us ensure a balance between our interests and your fundamental rights and freedoms.

On our Site, we may process information using cookies and similar technologies in accordance with the Cookie Policy below.

HOW LONG WE KEEP YOUR PERSONAL DATA

As a rule, we store your personal data as long as you have a profile on the Site and up to 5 (five) years after its deletion, or after the completion of procedures related to possible disputes.

We store the data from accounting reports and documents related to payments made for services provided on the Site for a period of 10 years, starting from the year following the year of the event on the occasion of which the data was collected.

Personal information collected solely for the purpose of making contact is retained until the relevant communication is completed, unless otherwise required by applicable law.

SENSITIVE DATA

Street Guru does not collect or process sensitive personal data. We ask that you do not send or disclose to us any sensitive data (for example, information relating to racial or ethnic origin, political beliefs, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the Site or otherwise way.

HOW WE MAY DISCLOSE PERSONAL INFORMATION

To the extent permitted by applicable law and as the case may be, we may transfer or provide access to some of your personal data to the following categories of recipients:

companies of the group of companies to which Street Guru belongs;
payment/banking service providers;
accounting and legal service providers;
marketing/telemarketing service providers;
providers of market research services;
insurance companies;
IT service providers;
other companies with whom we may develop joint programs to market our services;
to a third party in the event of a reorganization, merger, sale, joint venture, transfer or other disposition of all or part of our business, assets or stock (including in connection with bankruptcy or similar proceedings);
when we believe it is necessary or appropriate: (a) under applicable law, including laws outside of your country of residence; (b) comply with legal process; (c) to respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence; (d) to protect our operations or those of any of our affiliates and subsidiaries; (e) to protect our rights, privacy, safety or property and/or that of our affiliates, you or others; and (f) allow us to pursue available remedies or limit the damages we may suffer.
We guarantee that access to your personal data by third-party private legal entities is carried out in accordance with the legal provisions in the field of data protection and information confidentiality, based on contracts concluded with them.

USER RIGHTS

Access to your personal data

You have the right to review, amend or delete the personal data we hold about you. To request access, please send an email to info@imotco.bg using the email address we hold for you or otherwise proving your identity. We will provide the information free of charge and within one month, unless the request is unreasonable, excessive or repetitive, in which case we reserve the right to charge a proportionate administrative fee or refuse.

Correction of personal data

If some of the information we store about you is inaccurate or incomplete, you can ask us to correct or complete it at any time by sending an email to info@imotco.bg using the email address we store for you, or by proving otherwise yours

identity. We will provide the information free of charge and within one month, unless the request is unreasonable, excessive or repetitive, in which case we reserve the right to charge a proportionate administrative fee or refuse.

Correction of personal data

Your right to erasure or to be forgotten

You can ask us to delete your personal data, but only if:

they are no longer necessary for the purposes for which they were collected; or
You have withdrawn your consent (if data processing is based solely on consent); or
you exercise a legal right to object; or
they have been unlawfully processed; or
there is a legal obligation in this regard.
We are under no obligation to honor your request to delete your personal data if its processing requires:

to comply with a legal obligation; or
to establish, exercise or defend a legal claim, as well as in other cases expressly provided for by law.
To request deletion of your personal information, contact us at info@imotco.bg using the email address we hold for you or otherwise proving your identity.

Please note that the data deletion process with all data and documents associated with it is irreversible.

Restriction of data processing

You can ask us to restrict the processing of your personal data, but only if:

their accuracy is disputed (see the data rectification section) so that we can verify their accuracy; or
the processing is illegal, but you do not want the data to be deleted; or
they are no longer necessary for the purposes for which they were collected, but we still need them to establish, exercise or defend a legal claim; or
You have already exercised the right to object and are checking whether the dominance of our rights still exists.
We may continue to use your personal data as a result of a restriction request:

if we have your consent; or
to establish, exercise or defend a legal claim; or
to protect the rights of the owner of the Site or any other natural or legal person.
Data portability

You can ask us to provide your personal data in a structured, widely used and machine-readable format, or you can request that it be directly "ported" to another data controller, but only if:

the processing is based on your consent or the conclusion of a contract with you; and
processing is done by automatic means.
Right to object

You can object at any time for reasons related to your specific situation to the processing of your personal data based on our legitimate interests, if you consider that your fundamental rights and freedoms dominate these interests.

In addition, you can object at any time to the processing of your data for direct marketing purposes by following the instructions contained in the emails we send you or by sending an email to info@imotco.bg.

Making automatic decisions

Street Guru does not perform profiling or automated individual decision-making.

Right to lodge a complaint with the local supervisory authority

If you believe that Street Guru is processing your personal data in an unlawful manner, you can contact us at info@imotco.bg.

Notwithstanding the above, you have the right, at any time, to file a complaint with your local supervisory authority if you believe that we are processing your personal data unlawfully or otherwise infringing your rights.

In Bulgaria, the contact details for the supervisory authority for the protection of personal data are as follows:

Commission for the Protection of Personal Data

Bulgaria, Sofia 1592, Prof. Tsvetan Lazarov Blvd. No. 2

Phone: + 359 2 915 35 18

E-mail: kzld@cpdp.bg

OTHER INFORMATION

Other information we may collect

"Other Information" is any information that does not specifically identify you, such as:

browser and device information, operator, internet connection
server log information and Site log files
information collected through cookies, pixel tags and other technologies
demographic information and other information provided by you
location information
We may use and disclose Other Information for any purpose, except as required to do otherwise by applicable law. If we are required to treat the Other Information as personal data under applicable law, then we may use and disclose the Other Information for all purposes for which we use and disclose the personal data.

DATA SECURITY METHODS

For the purpose of protecting the data of users and visitors to the Site against their unauthorized or accidental disclosure, we use reasonable and appropriate technical and organizational measures. Technical measures consist in the application of technologies that prevent unauthorized access to personal data by third parties. For the purposes of maximum protection, we use encryption of user and visitor data, communication on the Site and all data stored on servers. The organizational measures include a set of rules for the conduct of our employees and are included in Street Guru's internal regulations, which are, however, considered confidential for security reasons. Street Guru undertakes to ensure that, in the case of hosting servers in a data center managed by a third party, similar technical and organizational measures are also implemented by such third party.

All data is stored only on servers located within the European Union.

TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATION

As a general rule, your personal data is stored and processed on the territory of the European Union and the European Economic Area (EEA). In the event that your personal data is transferred outside the European Union or the EEA, the transfer will take place:

(a) on the basis of a decision of the European Commission by which it decides that a relevant third country provides an adequate level of protection,

(b) based on binding corporate rules or

In addition, if we determine that one of these measures is not sufficient to provide an adequate level of protection, on a case-by-case basis, we will adopt additional technical and/or organizational security measures in accordance with the recommendations of the European Commission. You can contact us at any time using the contact details listed below to find out more about the countries to which we transfer your data and the safeguards we have put in place in relation to those transfers.

THIRD PARTY SITES

The Site may contain links to other websites, mobile applications and other online services operated by third parties. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of third parties, including third parties operating any site to which such sites link. The inclusion of a link to the Site does not imply endorsement of the linked site by us.

We are also not responsible for the collection, use and disclosure policies and practices (including data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft or any other application developer, application provider, social media platform provider media, operating system provider, wireless service provider or device manufacturer, including in relation to personal data you disclose to other organizations through or in connection with our social media pages.

COOKIE POLICY

What are cookies?

Cookies are small text files that are stored on your computer or mobile device. They are widely used to make websites work or work better and more efficiently. They can do this because websites can read and write these files, allowing them to recognize you and remember important information that will make your use of the website more convenient (for example, by remembering your preference settings).

The site automatically identifies the user's IP address. An IP address is a number that is automatically assigned to a user's computer after connecting to the Internet. All such information is recorded in an activity file by the server, allowing for subsequent data processing.

Types of cookies used by the Site

Necessary cookies

We use necessary cookies to ensure the proper operation of our Site. We would not be able to provide you with access to our services without these cookies and therefore you cannot refuse them. You can use your browser settings to delete and/or remove them later.

If you have set your computer to automatically display images, or if you have "weak" protection, necessary cookies may be set at the same time you download, open or read the Site. If you prefer this not to happen, you should turn off the automatic display of images or strengthen your security settings.

These cookies are based on our legitimate interests and therefore you do not need to give us your consent to store them.

Performance cookies

These cookies are not absolutely necessary for the Site to function, but they nevertheless perform important tasks. Without these cookies, the functions that ensure easy browsing around the Site are not active.

Functional cookies

We cannot exclude these cookies from our systems, we need them to set the Site to function as well as possible. By disabling these cookies, you can disrupt the way your browser loads the Site in terms of using your personal profile in our system or filling out forms for example. They are usually only set in response to actions taken by you. These cookies do not store any personal information.

Cookies for marketing and targeted advertising

These cookies serve to collect information from the platforms we use for marketing analysis and advertising. Through them, we store information about what kind of user you are, what your interests are, what sites you have visited before and others. In this way, we can target ads tailored to your interests when you visit other sites. Marketing and advertising cookies also use information about your browser and device when you access websites to identify you. If you do not allow these cookies, you will receive less targeted advertising.

Analytical cookies

Through these cookies, we manage to improve the content of the Site based on the behavior of our users. We combine this data obtained from the cookies and the data you have provided to us as our customers, so that we can provide you with the necessary service as well and completely as possible.

Third party cookies

The Site may also contain third-party cookie files. This may be, for example, because we have authorized a third party to carry out website analysis. Street Guru uses the following service providers:

Google Inc. (googleapis.com, google-analytics.com, google.com, google.bg, googleadservices.com, googletagmanager.com)

HotjarTM (hotjar.com)

Facebook, Inc. (facebook.com, analytics.facebook.com, developers.facebook.com)

Cookie settings

Most web browsers automatically accept cookies. However, it is possible to use controls that allow them to be blocked or removed. In this way, users of the Site have the right to set their browser in such a way as to prevent the use of cookies on their computer. Detailed instructions for deleting cookies for different browsers and operating systems can be found at http://www.aboutcookies.org/ (in English).

When entering the Site, you can control the loading of your selected cookies in the dialog window by pressing the "Allow all cookies" buttons to select all available cookies, the "Allow selection" button to leave some of them active when using the website, or in case you do not agree with the use of cookies, you can opt out of all, except the mandatory cookies, without which the website cannot function, by clicking on "Only strictly necessary cookies".

ADMINISTRATOR of personal DATA

The personal data controller for the information you provide or we collect under this Privacy Policy is:

"Street Guru" OOD, EIK 207016977

Headquarters and management address: Sofia, Lozenets district, Cherni Vrah Blvd. No. 26, entrance A, fl. 5, apartment 20

HOW TO CONTACT US

If you have any questions regarding our personal data processing practices, you may contact us directly using any of the following communication channels:

Email address: info@imotco.bg

Address: Sofia, Lozenets district, Cherni Vrah Blvd. No. 26, entrance A, fl. 5, apartment 20

CHANGES TO PRIVACY POLICY

We may modify this Privacy Policy at any time. The current version of the Privacy Policy is always available on the Site. If there is a significant change in the way Personal Data is handled within the framework of this policy, Street Guru will inform you by posting a notice in a visible way and sending an email notification to the email addresses used for registration by Users, before the implementation of such changes changes. We agree that changes cannot be retroactive. We recommend that you check the Privacy Policy regularly when using the Site.

Your continued use of the Site after changes to the Privacy Policy are communicated to you constitutes your acceptance of the updated terms.

Updated on 01.07.2023.