PERSONAL DATA PROTECTION POLICY, in accordance with EU Regulation 2016/679 and the GDPR in force in the Republic of Bulgaria. Bulgaria ("GDPR")



I PERSONAL DATA CONTROLLER AND DLSD


I.1. Information about the owner of the website oikia.com, as the DATA ADMINISTRATOR

(1) From the very date of its creation Publidok S.r.l., with registered office in Milan (MI) Foro Buonaparte, 59 20121 and operational headquarters in Busca (CN) Via Po, 2 12022 - VAT number 09705620962, tel.: 0171.937225 - Fax: 0171.940614, owner's e-mail address: [email protected] is symbol of safety, quality service and high standard. Through energy and comitment we achieve the results that the clients of Publidok S.r.l expect. We strive to exceed the expectations of our clients and this is why the right choice for REAL ESTATE DEALINGS, EXPRESSED BY PURCHASE & SALE, RENTALS, CONSTRUCTION AND AUCTIONS is Publidok S.r.l., through the website: oikia.com. We respect the right to privacy, to business and work towards keeping the data we process minimized and as protected as possible.

(2) The present Personal Data Protection Policy applies to your personal data, when you visit www.oikia.com or use our services through this site and does not apply to any other sites or services, we possess or control. It is applicable to all visitors of our site and is intended to help you understand what kind of personal data we collect, the reasons for such collection and what we do with it.

(3) We would like you to know how we use your information and the manners in which you can exercise your rights.

(4) This Personal Data Protection Policy is intended to inform you of the manner we manage your personal data, what are your rights of privacy and how the law protects you. When you use any of our services and/or register a profile you accept that you have read and understood this Personal Data Protection Policy, as well as our policy for the use of „cookies”.


1.2. CONTACT DETAILS

(1) ADMINISTRATOR DETAILS
The company, providing you with services on this website in the capacity of Data Controller is

Publidok S.r.l.
Headquarters: Milan (MI), Foro Buonaparte, 59 20121 - Italy
Operational Headquarters: Busca (CN) Via Po, 2 12022 - Italy
VAT number IT09705620962
Tel: 0171.937225 - Fax: 0171.940614
Owner's e-mail address: [email protected]

(2) Data Protection Officer (DPO) details
The Data Protection Officer: [email protected]



II. PRIVACY POLICY


II.1. DATA WE COLLECT AND MANNER OF THEIR USE

(1) The personal data is data, which describe or are related to someone in his/her personal capacity. This is data, which can be used to identify a person. We collect some personal data in order to provide services to all our clients. We process the personal data only on legitimate grounds. We do not sell or disclose your personal data in any manner.

(2) We process the following personal data of individuals for the purpose of achieving the following goals: Data regarding the client in his/her capacity of individual and/or in the capacity of representative of a legal entity, client of Publidok S.r.l.: full name, personal number, data from the identification document, email address, phone number, correspondence address, permanent address.

(3) Identification details such as names, personal number, data from identification document, permanent address and correspondence address, are necessary for us in order to establish your identity when entering into contract relations for the purpose of providing intermediation services in the sphere our company works in, as described above, as well as for the preparation of the documents necessary in that regard.

(4) We need the email address, phone number mobile phone and address in order to contact you at any point of implementation of the services required for the purpose of their successful and timely completion, as well as to answer any questions or queries you may have.

(5) In case you have granted your express consent and subject to the permissions of your device, if you publish on our Site, we automatically collect and process information about your actual location, including IP address, GPS, Wi-Fi access points and mobile stations.

(6) The personal information is collected at the time when the users register, request information, sign un for events, apply for work or publish opinions through discussion forums or surveys. When we receive an enquiry from you through any of our contact forms we will use the contact details we were given in order to contact you and to provide the information or assistance you require.

(7) We do not collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or membership of trade unions, as well as data relating to health, sexual life or the human genome.

(8) When we receive an enquiry from a person through any of our contact forms we will use the contact details provided by such person in order to contact him/her and provide the information or assistance he/she requires.

(9) We would like to use your email and your phone number in order to send you information about our services, promotions, discounts and bonuses you can benefit from. We will do so only if you give us your consent to receive such information:
by email;
by SMS;
by phone;
by all of the above.

(10) Your consent is voluntary and you will be able to use our services regardless of whether you choose to provide or withhold it. Despite that we believe that such information would be useful for you, since it will reflect the development of the services we offer, our newest projects in the sphere of business which Publidok S.r.l. is engaged in, as well as offers, tailored to your individual interests and queries. We will not use your contact details in order to advertise third party products or services.

(11) We will not use your contacts to advertise third party products or services.

(12) You can withdraw your consent to receive such information at any time by sending an email to:[email protected].


II.2. TYPES OF PERSONAL DATA COLLECTED

(1) When you use our services, you agree that we collect some of your personal data.

(2) This page is intended to tell you what data we collect, why and how we use it.


II.3. PERSONAL DATA WE COLLECT AUTOMATICALLY

(1) When you browse the Site, we may automatically collect various information, including:
1.1. Information about your computer/device, such as browser type, operating system, IP address or current (approximate) location, and this data is used solely for the purpose of obtaining anonymous statistical information about your use of the Site and to verify its proper functioning and to identify anomalies and/or abuse.
1.2. Technical and third party cookies (see the section "Cookies" for more details).
1.3. With the use of mobile applications, we also collect your device identification code (UUID) to send you targeted notifications.

(2) In addition to the above, we may also collect information about your interaction with email messages we send you, for example if you have opened, clicked or forwarded a message.


II.4. PERSONAL DATA PROVIDED BY THE USER

(1) When you register, enter or respond to an advertisement or complete a contact form, you agree to provide us with certain data that is necessary for us to provide you with the service you have requested.

(2) Examples of personal data that you may provide to us include: surname, first name, email, password (it will be kept encrypted so that even we cannot see it), phone number, company name, city, residential address, date of birth, gender.

(3) When you post an advertisement, post on our blog or forum, you are providing data that will be published, in which case you should be aware that any information provided in these areas may be read, collected and used by other users who have access to that data.

(4) Sensitive information, such as your credit card number and password, that we request on the Site is protected by encryption, such as the Secured Socket Layer (SSL) protocol, during transmission over the Internet.


II.5. PERSONAL DATA PROVIDED BY THIRD PARTIES

(1) When you register or log in to your account through a third party service provider (such as logging in with Google, Facebook, Twitter, ...), we receive information that constitutes your personal data such as: your username, email address, first name, last name and profile from this service (the data sent is indicated in the corresponding "pop-up" window that appears at the time of the request).

(2) The information indicated that we have received about you pursuant to the foregoing varies and is controlled by that service provider you have used, or is authorized by the user through the privacy settings of the respective service provider you have used.


II.6. THE GROUNDS ON WHICH WE USE YOUR PERSONAL DATA

(1) The processing of your personal data is necessary with a view to the provision by Publidok S.r.l. of intermediary services in the field of real estate, insofar as the current European and, in particular, Bulgarian legislation obliges it to store such data, as well as on the basis of the legitimate interests of Publidok S.r.l. and its contractors to carry out economic activity, insofar as the processing of personal data is limited to the minimum necessary for this purpose.

(2) We accept that every one of you will be providing only his/her own personal data, which is up-to-date as of the moment of their provision. Every person declares that the data belongs to him/her and that he/she is providing them voluntarily.

(3) Publidok S.r.l cannot be held responsible for the collection or legitimate processing of data by third parties, specified by you when visiting our site.

(4) In terms of the persons that we are about to sign an intermediation contract with in relation to our economic activity, we process the following data: Full name, details from the identification document, details from the freight-related documents, the data of the real estate ownership documents, the civil status documents, as well as other data that is necessary for the identification of a person, for the purpose of preparing and issuance of the respective documents in relation to the provision of the services of Publidok S.r.l.

(5) We will use your personal data for marketing purposes only with your express consent. The absence of consent or its withdrawal does not affect the possibility to use our intermediation services in any way.

(6) Every User has the right to withdraw his/her consent for processing of persona data at any time by sending a message to the email address. This does not affect the legitimacy of the processing, which we have performed on the grounds of your advance given consent.


II.7. HOW WE PROCESS AND USE YOUR PERSONAL DATA

(1) The personal data provided to us are processed both with automatically, as well as manually, and are protected with adequate security measures, taking into account the achievements of the technical progress, costs of implementation, as well as the nature, scope, context and purpose of the processing. Publidok S.r.l has introduced suitable administrative, technical, staff and physical measures in order to protect the personal data in its possession from loss, theft, unauthorized use, disclosure or modification.

(2) We use the data collected to ensure you have access to and use our services, including:
2.1. Registration and creation of a reserved area;
2.2. Publishing and managing advertisements;
2.3. Using the "favourites" and "saved searches" functions;
2.4. Confirm your identity when logging into the site;
2.5. Activities of an administrative, financial or accounting nature, such as those related to the purchase of paid services and any credit refunds;

(3) We also use your data to improve and implement the Service, through the following processing:
3.1. Detecting an approximate location in order to deliver content near you;
3.2. Performing technical analyses to determine how to improve the site and services we provide;
3.3. Monitoring activity on the site, e.g. to identify potential fraudulent activity and to ensure compliance with the terms and conditions applicable to the site;

(4) If you have explicitly given us your consent, we may use the data provided to inform you about promotional activities that may be of interest to you, including: newsletters, promotional, commercial and advertising activities, via email, SMS or targeted notifications;

(5) If you receive a promotional email from us, you may unsubscribe at any time by following the instructions contained in that email or by contacting us via the contact form on the Site.


II.8. SECURITY MEASURES AND STORAGE OF YOUR PERSONAL DATA

(1) All information we receive from you is stored on protected servers and we have implemented a wide scope of technical and organizational measures, that are suitable and necessary for the protection of your personal data, including protection from accidental or illegal losses, access or disclosure; for identification of reasonably foreseeable risks for the safety of the network and minimization of the security risks, including by risk assessment and regular testing.

(2) The personal data is only accessible to authorized persons in need of such access for the purpose of performing their work regarding the provision of our services, who have undergone the respective training and are under obligation to treat the information as confidential in compliance with the principles of legitimacy, good faith, confidentiality and accuracy.

(3) We do not provide your personal data to third parties without legal or contractual grounds, we do not sell or distribute such data.

(4) The storage of personal data will be in paper and/or electronic/computer form and for the necessary time, subject to privacy and applicable regulations.

(5) In the case of active users, advertisements and user-generated content will be stored for 5 five years for security, prevention and legal regulations.

(6) Invoices, accounting documents and transaction data will be stored for 10 years in accordance with the law (including tax obligations).

(7) In the event of a request for the explicit cancellation of personal data, we remind you that this data will be stored in a secure form and with limited access, solely for the purpose of identifying and prosecuting criminal offences, for a period of no longer than 5 years from the date of the request and will be securely and permanently deleted thereafter.

(8) Your personal data may be transferred outside the European Union to be processed by some of our service providers. In this case, we ensure that this transfer is carried out in accordance with applicable law and that an adequate level of protection of personal data is guaranteed on the basis of an adequacy decision, standard clauses set by the European Commission or Binding Corporate Rules.

(9) The information related to the placed advertisements will be visible in searches performed on the internal search engine and may be made available to third-party search engines as indexing of content by third-party machines is allowed.

(10) In the event that the page associated with the advertisement has already been removed from our site, it is possible that the cached copy will remain in the search results for several days.

(11) The search results are not managed by the owner, but the user can report the removal of the page and request an update of the cached copy directly to the third-party search engine.

(12) Under no circumstances do we give or sell personal data to third parties.


II.9. PROVIDING SERVICES TO CHILDREN

(1) We provide services and allow our website to be used only by persons above 18 years of age.

(2) In the performance of our activities, there is a real possibility for us to process personal data of children in the mediation of real estate transactions owned by children or to be acquired by children.

(3) In the case of purchase of real estate by a child, it is necessary that the child be represented at the transaction by one of his/her legal representatives - parents, guardian or custodian. It is necessary to certify the relationship between the child and the parents. It is possible for a parent, acting on behalf of his or her child, to grant a power of attorney to a third party, whereby the property purchased becomes the property of the child. It is also necessary to prove the origin of the funds with which the property is to be purchased and, if the funds are on deposit in a bank in the child's name, prior permission from the court is required to withdraw the funds.

(4) Pursuant to Article 130, para. (3) of the Family Code, the disposal of immovable property owned by a child shall be permitted with the permission of the district court of the child's present address if the disposal is not contrary to the child's best interests. For this purpose, an application is filed by the parent on behalf of the child and the court assesses whether the sale (or exchange) is necessary and in the best interests of the child. The child's need and benefit from the sale must be substantiated, not the parents' benefit. Before making a judgment, the court may require an opinion from the Social Assistance Department of the child's home address as to whether the request is beneficial to the child and in the child's best interests, and may require additional documents from the parents, such as income statements, etc. It is only after the court has issued a judgment granting the application that the transaction itself can proceed.

(5) If we need to process a child's personal data, we always ask for explicit consent to process the data from the child (if over 14 years of age) and from their legal representatives (parents or guardians).

(6) If you are under the age of 18, you cannot register on our website nor can you provide us with personal data. In any event, we do not accept responsibility for any false statements provided by you. If we become aware of the existence of any false statements, we will proceed with the immediate cancellation of all personal data acquired.


II.10. WHO HAS ACCESS TO YOUR PERSONAL DATA

(1) The company grants access to your personal data to the following categories of recipients within the European Union.
1.1 Third party suppliers of services, to whom were entrusted activities related to the processing and who have been duly appointed as data processors, if required by the acting legislation, suppliers of ancillary or maintenance services for Publidok S.r.l. and similar entities, providing IT services, experts, consultants, lawyers;
1.2 Associated parties in their capacity of data controllers or data processors;
1.3 Competent authorities for the purpose of compliance with the acting legislation.
1.4. Third Party "Company Representative/Partner" - when applying for credit through the option presented to each customer/user on the website by clicking on the "Apply for Credit" button, the customer/user personally enters their personal data and by which the latter agrees to their being provided to Third Parties - representatives/partners of the Company. For the purposes of this clause, this is the company providing the credit application facility listed on the website.

(2) The personal data collected, except in the cases referred to in par. 1, may also be disclosed to:
2.1. Companies that perform functions closely related and instrumental to the operations, including companies that provide backup, administration, payment and billing services, and companies that provide technical components to deliver certain service functions.
2.2. Data may be reported following inspections or checks (if necessary) to any inspection bodies responsible for checks and controls on the regularity of legal obligations.
2.3. By responding to an advert or activating an alert with the request sent to the agencies, the data entered on the contact form can be shared with the agencies themselves.



III. CONSUMER RIGHTS. STORAGE DURATION AND SAFETY.


III.1. CONSUMER RIGHTS

(1) You have the right, at any time:
1.1. to request a confirmation whether any personal data related to you has been processed and to request a copy of your personal data, as well as information, regarding the collection, the processing and the storage of your personal data.
1.2. to request your personal data to be deleted on any of the following grounds: the personal data is no longer necessary for the purposes it was collected for; in case you have objected against the processing, in case the processing is unlawful; in case the data is processed on the basis of your consent and you choose to withdraw that consent; in case the personal data must be deleted for the purpose of complying with a legal regulation under the EU law or the legislation of a member-country, which is applicable to the data controller.

(2) You can access some of the personal information we collect about you by logging into your personal area.

(3) At any time, you may request access to the personal data we have collected, request that we update, amend and correct any errors in that data, and withdraw your consent to data processing (in which case we may deactivate your account or the data you have entered on our site).

(4) We remind you that for any question or request related to your personal data and respect for your privacy, you can contact us via the contact form on the site.

(5) The deletion of your personal data can be refused on the following grounds: exercising freedom of expression and the right to information, for the performance of a legal obligation of Publidok S.r.l. or for the performance of a task of public interest, or in the course of exercising official powers granted to Publidok S.r.l.; for the establishment, exercising of, or protection against, legal claims.

(6) to request your personal data to be corrected, in case they are inaccurate, or supplemented in case they were incomplete.

(7) to request the processing of your personal data to be restricted if applicable and provided the grounds for such restriction exist, such as: you object against the accuracy of the personal data, for a period allowing Publidok S.r.l. to verify the accuracy of the personal data; the processing is unlawful, but you do not wish the personal data to be deleted, but only their use to be restricted; Publidok S.r.l. no longer needs the personal data for the purposes of the processing, but you request them for the establishment, exercising or defence of your own legal claims; you have objected against the processing and are waiting for a verification whether the legal grounds of Publidok S.r.l. have priority over your interests.

(8) to request to receive the personal data related to you that you have provided to Publidok S.r.l., in a structured, commonly used and machine-readable format and you have the right to transfer this data to another data controller, in case the processing is based on consent or contract obligation and the processing is being done automatically;

(9) to submit an objection before the personal data protection officer against such processing of your personal data, provided there are grounds to do so.

(10) You can sent your request to email address [email protected]. Please include in your request the email address, name, address and phone number and state clearly what information you wish to receive, change, update, hide or delete.

(11) You should know that even after removing your profile or after requesting a deletion of your data, copies of certain information from your profile may remain visible in certain circumstances, for example, in case you have shared information with social media or other services, or in case the keeping of such copies is necessary for the purpose of compliance with certain legal obligations or legal protection. Due to the nature of cashing, your profile may not become immediately invisible to the others. We can also keep archive information on our servers, related to your profile, for a certain time, after the deletion or the request for deletion, provided that is necessary for the purpose of compliance with the applicable legislation.

(12) You can withdraw your consent for receipt of electronic messages sent by us. In case you no longer wish to receive advertisement or marketing email letters from us in the future, you may opt-out of receiving such e-letters by following the instructions for unsubscription found in our messages. You can also send a request to the address indicated below.

(13) In order for us to be able to provide you with our complete assistance please provide us with accurate information about you and please provide details in your request. It is possible that we may ask you for additional information while you exercise your rights, for the purpose of verifying your identity and granting your request.

(14) Please bear in mind that in case your requests are deemed unfounded or excessive due to their repetitiveness, we may:
1. impose a fee, taking into account the administrative costs for providing the information or communication or undertaking the actions requested, or
2. refuse to undertake any actions under such request.

(15) We will make every reasonable effort to comply with your request within 30 days of its receipt. If necessary the said period can be extended with further two months taking into account the complexity and number of requests.


III.1. PERSONAL DATA STORAGE DURATION

(1) We will store your personal data for the time necessary to complete the tasks which the data was collected for, as described in this Confidentiality Policy.

(2) At the end of the storage period your personal data will be either deleted or anonymized.

(3) The data collected at the time of initial contact with the person shall be stored for a period of 5 years.

(4) The data provided to us when submitting an offer through our site will be stored for a period of 5 years.

(5) In case of signing an intermediation contract the data will be stored for a period of 5 years following the termination of the contract.

(6) Location data will be stored for a period of 5 years.

(7) Data is collected in accordance with the guidelines of the relevant legislation, with particular attention to the security measures provided for by the GDPR (Article 32), using computerised, manual and automated tools.

(8) We store personal information on secure servers that are managed by us and our service providers, and sometimes paper files stored securely.

(9) The personal information we store or transmit is protected by security and access controls and data encryption.



IV. CONSUMER RIGHTS. STORAGE DURATION AND SAFETY.


IV.1. CHANGES IN THE CONFIDENTIALITY POLICY

(1) Publidok S.r.l. reserves the right to change or update the present Confidentiality Policy including, but not only, in case of changes in the applicable legislation and detailed ordinances, instructions, statements and dispositions related to the acting legislation. Any changes in this Confidentiality Policy will be published on the site in order to keep the users informed.

(2) The data controller reserves the right to make changes to this privacy policy at any time by notifying users of this page, please consult this page frequently, referring to the date of last modification listed at the bottom.


IV.2. SUPERVISORY AUTHORITY

(1) In order to exercise your rights, as well as in case you have questions related to the protection of your personal data, you can contact the supervisory authority - the Commission for Personal Data Protection, as follows:
Address: 1592 Sofia 2 Tsvetan Lazarov blvd
phone: +359 2 915 3580 Fax +359 2 915 3525
Email: [email protected]
Website: http://www.cpdp.bg/


IV.3. CONTACT DETAILS

(1) Should you have any questions regarding the present Personal Data Protection Policy, please do not hesitate to contact us at the following address: [email protected].


IV.4. DATE OF UPDATE:

01 November 2022