Privacy Policy of "Trabado"

Last updated: 18/01/2025

1. INTRODUCTION

This Privacy Policy ("Policy") sets out the rules regarding the protection of personal data of individuals using the website and mobile application ("Platform"/Trabado), owned by https://trabado.app.

Trabado fully complies with the requirements of 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 ("Regulation"), effective from 25.05.2018, and the Personal Data Protection Act ("PDPA").

By using Trabado, you accept and agree to comply with this Privacy Policy, the Cookie Policy, and the Terms and Conditions of the Website.

2. DEFINITIONS

"Personal data" refers to any information relating to an identified or identifiable natural person (Data Subject), who can be identified directly or indirectly by reference to an identifier such as: name, personal identification number, location data, gender, address, phone number, online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
"Processing of personal data" means any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, combination, restriction, erasure, or destruction.
"Data Subject" is any natural person who is a User of the Website.
"Website" refers to the content of the domain https://trabado.app and its subdomains.
"Mobile application" is a software application designed for a smartphone or mobile device, owned by Trabado.

3. PRINCIPLES OF DATA PROTECTION

1. Lawfulness, fairness, and transparency

Personal data must be processed lawfully, fairly, and transparently concerning the Data Subject. Therefore, Trabado collects and processes your personal data solely for the following purposes:

Managing your request and the signed contract.
i. Based on the contract signed between you and us, we process information about the type and content of the contractual relationship:

Contact information – full name, contact address, email, phone number;
Identification data – full name, personal identification number, or equivalent foreign identification number, permanent address;
Emails, correspondence regarding your requests for issue resolution, complaints, applications, grievances;

Retention of correspondence related to completed orders, issue resolution, complaints, etc.;
Contacting the User and sending information to them.
Compliance with legal obligations.

2. Purpose limitation

Personal data must be collected for specific, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes. Trabado collects and processes your personal data for the following purposes:

Creating a profile and providing full functionality when using the online platform;
Fulfilling orders;
Identifying the contractual party;
Accounting purposes;
Statistical purposes;
Protection of information security;

3. Data minimization

Personal data must be adequate, relevant, and limited to what is necessary concerning the purposes for which they are processed. Trabado, as a Controller, applies anonymization or pseudonymization of personal data, where possible, to reduce risks to affected Data Subjects.

4. Accuracy

Personal data must be accurate and, where necessary, kept up to date; reasonable steps must be taken to ensure that inaccurate personal data, considering the purposes for which they are processed, are erased or rectified without delay. Trabado is not liable for incorrect data provided by its Users.

5. Storage limitation

Trabado retains your personal data for no longer than necessary, considering the withdrawal of consent for processing. Upon deletion of your profile or upon completion of service, the Controller ensures the deletion and destruction of all your data without undue delay or anonymization (i.e., rendering it such that your identity is not revealed).

6. Integrity and confidentiality

Trabado processes your personal data in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using suitable technical or organizational measures.

Where required by law, we may share your personal data with competent state authorities, natural persons, or legal entities.

4. USER RIGHTS

Every User of the site enjoys all rights for the protection of personal data under Bulgarian legislation and EU law.

1. Right of Access

Users have the right to request a copy of their data and detailed information on whether and how their data is processed legally. Data Subjects have the right to understand:

The purposes for which their personal data is used.
The categories of personal data processed.
Whether the company has shared the data with third parties, and if so, who those parties are.
The sources from which the company obtained the personal data.
The data retention period.
The rights available to them against the company, including correcting, deleting, or restricting their data processing.
If automated decision-making (e.g., using AI or algorithms) is involved, meaningful information about the logic, significance, and consequences of such processing.
If data is transferred outside the EU, the safeguards in place to protect the data.

2. Right to Deletion

Users have the right to request deletion of their personal data without undue delay when any of the following grounds apply:

The data is no longer necessary for the purposes it was collected or processed.
The User withdraws consent for processing, and no other legal basis exists.
The User objects to processing under GDPR Article 21(1), and no overriding legitimate grounds exist.
The data has been unlawfully processed.
The data must be erased to comply with a legal obligation.
The data was collected in relation to offering services to children as per GDPR Article 8(1).

3. Right to Data Portability

Users have the right to receive their personal data in a structured, commonly used, and machine-readable format and to transfer this data to another controller without hindrance when:

The processing is based on consent or contract as per GDPR Article 6(1)(a) or (b).
The processing is carried out by automated means.

4. Right to Object

Users can object to the processing of their personal data. The Controller must cease processing unless compelling legitimate grounds for processing override the interests, rights, and freedoms of the Data Subject or for legal claims. Objections to direct marketing are acted upon immediately.

5. ANONYMIZED DATA PROCESSING

We process your data for statistical purposes, meaning the results are aggregated, and the data is anonymized. Identification of specific individuals from this information is impossible.

1. Compliance with Legal Obligations

We may be legally required to process your personal data. In such cases, we must perform the processing, for example:

Obligations under the Anti-Money Laundering Act.
Compliance with consumer protection laws regarding distance selling.
Providing information to consumer protection authorities or third parties as mandated by law.
Providing information to data protection authorities under data protection regulations.
Obligations under the Accounting Act and tax laws.
Providing information during legal proceedings as required by applicable law.
Age verification during online purchases.

2. Data Retention Periods

Data collected under legal obligations is deleted after the obligation for collection and retention has been fulfilled or ceases to apply, for example:

11 years under the Accounting Act for retaining accounting data.
5 years for legal obligations related to providing information during legal proceedings.

6. DATA SECURITY

To ensure maximum security during processing, transmission, and storage of your data, we may use additional security mechanisms such as encryption, pseudonymization, and others.

Guaranteeing the security and confidentiality of your personal data is our priority. Trabado implements all appropriate technical and organizational measures under applicable legal provisions, considering the nature of the data provided by you and the risks associated with its processing, to ensure its security and prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

"Pseudonymization" means processing personal data in such a way that it can no longer be attributed to a specific Data Subject without additional information, provided such information is kept separately and is subject to technical and organizational measures to ensure that the data is not linked to an identified or identifiable individual.

7. DATA PROTECTION OFFICER (DPO) RESPONSIBILITIES

The DPO assists the Controller or processor with all matters related to data protection. Their responsibilities include:

Informing and advising the Controller, processor, and their employees about their data protection obligations.
Monitoring compliance with data protection laws and policies, including audits, awareness-raising activities, and employee training.
Providing advice when a Data Protection Impact Assessment (DPIA) is conducted and monitoring its performance.
Acting as a contact point for individuals regarding their data processing and rights.
Cooperating with Data Protection Authorities (DPA) and acting as a contact point for them.

8. INCIDENT REPORTING PROCEDURE

Every User has the right to file a complaint against unlawful processing of their data with the Data Protection Authority or the competent court.

Data Protection Authority

Address:

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

Phone:

+3592/91-53-518

Website:

www.cpdp.bg

9. CONTACTS

Every User may send inquiries or exercise their rights under this Privacy Policy by contacting us at the following email address:info@trabado.app

Date: 18/01/2025

Bulgaria Blv 4, Plovdiv, Bulgaria

info@trabado.app

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