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PRIVACY AND PERSONAL DATA PROTECTION POLICY OF "NG CODING" OOD

This Privacy and Personal Data Protection Policy ("the Policy") is intended to inform you, in a transparent and comprehensible manner, of what personal data we collect when you visit our website, contact us, or create a user profile and use the functionalities of the BuildColab Platform.

The protection of your personal data is a key priority for us, which is why this document sets out the purposes and legal grounds for processing, the categories of data processed, the periods for their storage, and your rights under the applicable legislation.

  1. TERMS AND DEFINITIONS USED

The terms used in this Policy have the following meaning:

"Personal data" - any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Controller" – an entity that alone determines the purposes and means of the processing of personal data.

"Data Processor" – an entity that carries out the processing of personal data on behalf of the Controller.

"Processing of personal data" – any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Data subject" – an identified or identifiable natural person to whom the personal data relates.

"Consent of the data subject" - any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Some of the terms in this Policy have the meaning given to them in our General Terms and Conditions, unless expressly stated otherwise.

  1. WHO PROCESSES YOUR PERSONAL DATA

Your personal data are processed by "NG CODING" OOD, UIC 207974225, with registered office and address of management in the city of Varna, postal code 9010, "Primorski" District, "Druzhba" Str. No. 6, apt. 25 ("We"; "the Controller"; "BuildColab"), which operates and maintains the website https://portal.buildcolab.com ("the Platform").

We are the controller of your personal data within the meaning 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 ("GDPR"; "the Regulation").

  1. CATEGORIES OF PERSONAL DATA WE PROCESS

When you use our Platform, we process only the minimum personal data necessary to provide you with secure access to our services and to enable you to work efficiently within your user profile.

The data we collect depend on the manner in which you interact with the Platform – e.g. when you create a profile, use its functionalities, or when you contact us through our contact form.

  1. Data provided when creating an Organization Profile or an Individual Profile of an organization member

When creating the relevant profile on the Platform, we process only the data necessary for identification and to provide access, namely your:

  • First name;

  • Last name;

  • Email address.

When creating a profile on the Platform, a phone number may also be provided. This is not a mandatory field during registration, and the phone number is processed only if voluntarily provided by the User.

  1. Data provided through the "Contact Us" contact form

When you contact us through the contact form, we process the following data:

  • Name;

  • Email address;

  • Any information you have voluntarily provided in your message.

  1. Data contained in documents uploaded to the Platform by a User:

Within the Platform, Users have the option to upload various documents related to their projects, which in certain cases may contain a limited amount of personal data.

These are usually business-related data such as the names of representatives of legal entities, contact persons, telephone numbers, email addresses, as well as other data included in the relevant documents.

BuildColab does not require or encourage the uploading of sensitive or disproportionate personal data, and the content of the uploaded files remains entirely under the control and responsibility of the respective User.

  1. Data provided by counterparties of Clients when completing modules on the Platform

It is possible that, in certain situations, counterparties of Clients may obtain limited access to specific sections of the Platform for the purpose of entering data within the framework of a project or an offer.

When entering such information, limited personal data may be provided – e.g. names, e-mail addresses, contact persons, etc.

The content of the information provided depends entirely on the will of the respective counterparties and their relationships with the Clients.

  1. Data on bank accounts and cards

When you make a payment for a subscription by bank card, BuildColab uses the services of a third party – a payment services provider, which processes the data necessary for carrying out the transaction. In such cases, BuildColab does not process and does not have access to the data of your bank card or your bank account, as the processing of such data is carried out entirely by the respective provider in its capacity as a personal data controller.

Before making a payment, you may familiarize yourself with the manner in which the provider processes your personal data through its published privacy policy, available at the following address: https://buildcolab.com/privacy-policy.

In the event that the payment services provider is changed, or if in the future BuildColab begins to independently process certain data related to payments, the data subjects shall be duly notified of the update to this Privacy Policy.

  1. Data generated through the use of the Platform

In the course of working with the Platform, technical data related to its use are automatically generated – such as logs of actions performed, IP address, timestamps, and information about the device or browser. Such data are processed solely in order to ensure the normal functionality of the services, technical support, information security, and the prevention of misuse.

  1. Data processed for direct marketing purposes

For the purposes of direct marketing, where you have given your explicit consent, we may process your name and e-mail address in order to send information regarding updates, new features, or services related to the Platform.

  1. FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS WE PROCESS YOUR PERSONAL DATA

  1. Creation and management of user profiles

In order to provide access to the Platform and to ensure that each user is able to use the functionalities allocated to them, we process the personal data provided upon registration for the following purposes:

  • Identification of the user upon creation of a profile;

  • Administration of roles and access rights within the Platform;

  • Linking the profile to a specific Client;

  • Maintaining up-to-date information about users.

The legal basis for the processing is the performance of the contract concluded between you and BuildColab (Art. 6, para. 1, point "b" of the Regulation).

  1. Provision of the services and functionalities of the Platform

We process personal data as part of the normal operation of the Platform, in order to ensure its functioning and the ability of users to perform the tasks related to the projects of their organizations. In this connection, the processing serves to:

  • Provide access to the various modules and tools;

  • Process, submit, and review offers;

  • Upload, view, and manage documents;

  • Enable interaction between the various users within the Platform.

The legal basis for the processing is the performance of the contract concluded between you and BuildColab (Art. 6, para. 1, point "b" of the Regulation).

  1. Technical support, security, and optimization of the Platform

The Platform requires regular monitoring, maintenance, and information security measures in order to operate reliably and to protect the data of all users. For these purposes, we process technical and log data, which enables us to:

  • Maintain the stability and security of the system;

  • Prevent and detect attempts at unauthorized access or misuse;

  • Analyze technical problems and carry out diagnostics;

  • Improve the quality and functionalities of the Platform.

The legal basis for the processing of this type of data is our legitimate interest in ensuring the security and normal functioning of the Platform (Art. 6, para. 1, point "f" of the Regulation).

  1. Processing of inquiries and communication through the contact form

When you contact us through the contact form, we process the data provided by you in order to be able to respond promptly and adequately to your inquiries. This processing is necessary for:

  • Providing a response in connection with the inquiry;

  • Conducting follow-up communication when necessary;

  • Identification when additional clarification is needed;

  • Documenting the correspondence for traceability purposes.

The legal grounds here are our legitimate interest in processing inquiries (Art. 6, para. 1, point "f" of the Regulation) and consent, where additional data has been provided at the User's discretion (Art. 6, para. 1, point "a" of the Regulation).

  1. Administrative, contractual and accounting activities

In order to manage the relationships with our Clients and to perform our statutory obligations, we process data for:

  • Administering subscriptions and contractual relationships;

  • Issuing invoices and accounting documents;

  • Maintaining registers required by law;

  • Processing statements related to reporting.

The legal grounds for processing the data are performance of a contract (Art. 6, para. 1, point "b" of the Regulation) and compliance with a legal obligation (Art. 6, para. 1, point "c" of the Regulation).

  1. Compliance with statutory obligations

In certain cases, we are obliged to process or store personal data in order to comply with the requirements of the applicable legislation. This includes:

  • Responding to requests from competent authorities;

  • Storing documents within the periods provided for by law;

  • Performing obligations related to the protection of the rights and legitimate interests of the controller.

The legal ground for the processing is compliance with a legal obligation (Art. 6, para. 1, point "c" of the Regulation).

  1. Direct marketing

In order to inform You about improvements to the Platform, updates, new features or services that may be relevant to Your organization, we may carry out limited direct marketing activities.

In cases of processing Your data for direct marketing purposes, the ground for processing is Your voluntary and informed express consent (Art. 6, para. 1, point "a" of the Regulation).

Recipients of marketing communications always have the right to object to the processing of their data for this purpose or to opt out of receiving such communications at any time.

  1. TO WHOM WE PROVIDE YOUR PERSONAL DATA

In certain cases, where this is necessary for the normal operation of the platform, for the performance of our contractual obligations, or for compliance with legal requirements, BuildColab may share personal data with a limited circle of third parties.

Some of these third parties may be:

  • Providers of IT and hosting services that ensure the support and development of the Platform;

  • Providers of cloud services necessary for the storage, processing or archiving of data;

  • Competent authorities that, by virtue of a normative act, have the power to require BuildColab to provide information, including personal data, such as, for example, a Bulgarian court or a court of another country, various supervisory/regulatory authorities;

  • Clients to which the user profiles are attached;

  • Counterparties of Clients, when they fill in certain modules through limited access granted to them to the Platform.

  • Providers of accounting services for the purposes of recording the issued invoices and other accounting documents in our accounting registers;

  • Legal consultants in connection with the performance or application of the General Terms and Conditions;

  • Other persons, when this is necessary for the protection of our rights or legitimate interests, including in the context of establishing, exercising or defending legal claims.

We require all third parties to whom we disclose personal data to undertake an obligation of confidentiality and to take all technical and organizational measures to protect such data in accordance with the Regulation.

We do not share or sell Your personal data to third parties for the purpose of carrying out their own independent business or marketing activities without Your consent.

  1. RETENTION PERIODS

We store personal data only for the period necessary to achieve the purposes for which it is processed, unless the law requires a longer period. Upon expiry of the relevant period, the data shall be deleted or anonymized.

  • Personal data processed within user profiles shall be stored for the entire period during which your registration is maintained. Following termination of the legal relationship and deletion of the specific user profile, the data shall be stored for a period of up to 5 years, in order to ensure the possibility of resolving any future legal disputes related to the performance of the contract.

  • Documents uploaded by Clients or their authorized Users, as well as by counterparties without their own user profile, shall be stored for the entire term of the contract with the specific Client.

  • Pursuant to the Accounting Act, certain of your personal data shall be stored by BuildColab for a period of 10 years, calculated from 1 January of the reporting period following the reporting period to which the accounting and/or tax information containing personal data relates.

  • Data processed for direct marketing purposes shall be stored until such time as the individual withdraws their consent.

  • Personal data received in connection with inquiries or correspondence submitted through the contact form shall be stored for up to 6 months after the communication has concluded.

  • Where a potential legal dispute, complaint, or regulatory investigation exists, the data may be stored until the final conclusion of the relevant proceedings, even where this exceeds the usual storage periods.

  1. DO WE USE "COOKIES"

In order to improve the quality of our services, we use cookies. More information about the use of cookies can be found in our Cookie Policy, available at the following web address: https://buildcolab.com/privacy-cookies.

  1. WHAT ARE YOUR RIGHTS IN CONNECTION WITH THE PROTECTION OF YOUR PERSONAL DATA

You have the following rights with respect to the processing of data, as well as the data recorded about you:

  • Right to information and access

You have the right to request confirmation from us as to whether we process your personal data, and if so, to obtain access to that data and information regarding the purposes of processing, the retention periods, and the recipients of the personal data. We will provide you with free access to your data, and upon your request we will also provide you with a copy of the data.

  • Right to rectification

You have the right to request the correction of any inaccuracy in your personal data or the completion of incomplete personal data.

  • Right to erasure (the "right to be forgotten")

You have the right to request that we erase personal data related to you which are no longer necessary for the purposes for which they were collected, or in respect of which you have withdrawn your consent to processing or have exercised your right to object to the processing. In certain cases established by law, we may refuse to erase your personal data.

  • Right to restriction of processing

In certain cases, you may request that we restrict the processing of your personal data, in which case the data will only be stored, but not otherwise processed.

  • Right to data portability

You have the right to receive the data that we process about you in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.

  • Right to object to processing

You have the right to object to the processing of your personal data for direct marketing purposes, as well as to the processing of personal data relating to you which is based on Art. 6, para. 1, point "e" or point "f" of the Regulation.

  • Right to withdraw consent

Where we process your personal data on the basis of consent given, you have the right to withdraw your consent to the processing of your personal data at any time, without this affecting the lawfulness of processing based on consent before its withdrawal.

  • Right to lodge a complaint

You have the right to lodge a complaint with the Commission for Personal Data Protection if you believe that there has been a breach of the applicable personal data protection legislation. Complaints to the CPDP may be submitted in person or by letter to the address: 1592 Sofia, 2 "Prof. Tsvetan Lazarov" Blvd.; by fax – 029153525; electronically to the CPDP's e-mail address – kzld@cpdp.bg. More information on the procedure can be found at the following web address: https://www.cpdp.bg/ .

  1. CONTACTS

You may contact us regarding all questions concerning the processing of your personal data, including in connection with the exercise of your rights described in this Policy, in one of the following ways:

  • By post – at the address: 9009 Varna, "Mladost" district, 25A Usta Kolyo Ficheto St.;

  • By e-mail: office@buildcolab.com;

  • Via our contact form.

  1. CHANGES TO THE POLICY

We may periodically amend this Privacy Policy and Personal Data Protection Policy. Any amendments and supplements to the Policy shall take effect upon publication of its updated content, available through our website: https://buildcolab.com/ .

Last updated: 20.02.2026.

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