Last Updated on 17 July 2023.

This Privacy Policy is effective immediately for Users after that date.

Givvy Ltd. ("Givvy", "we," "us,"), a company incorporated and existing under the laws of the

Republic of Bulgaria, registered under company number 206041372, having its seat and

registered office at Bulgaria, Sofia, Studentski Grad, Prof. Hristo Danov Str., №11, entr. C, ap.

12, respects your privacy and is committed to protecting it through our compliance with this

This Privacy Policy sets out the basis on which any personal data we collect from you, or

that you provide to us, will be processed by us. Please read the following carefully to

understand our views and practices regarding your personal data and how we will treat it.

By using the mobile application (the “Mobile App”), you are accepting and consenting to the

practices described in this Privacy Policy.

The definitions of the terms in this Privacy Policy have been referred by the Terms and

Conditions of the Mobile App.

The mobile application qualifies as a Data Controller under the Regulation (EU) 2016/679

of The European Parliament and of The Council of 27 April 2016 (General Data Protection

Regulation (the “GDPR”)). As such, we aim to comply with all legal obligations which the

GDPR implies on Data Controllers.

The mobile application strives to offer its visitors and Users the many advantages of

Internet technology and to provide an interactive and personalized experience. For these

purposes, we, from the mobile application may use personally identifiable information –

like your e-mail address, which is subject to the terms of this Privacy Policy. We, and we

suppose you too, do not tolerate spam. We will therefore never sell, barter, or rent your

email address to any unauthorized third parties.

1. WHAT INFORMATION DO WE COLLECT FROM OUR USERS?

The mobile application may collect and use information of and regarding its Users. We

collect only data which is essential to our operations and enables us to provide you with

better user experience.

1.1. Information you give us.

You may give us information about you by submitting information such as your name,

images, photo, email address, telephone number or address on the Mobile App, when

prompted or when corresponding with a member of the mobile application team.

1.2. Information we collect about you.

We collect two types of information from and about our Users, including information:

• by which you may be personally identified; and/or

• about your internet connection, the equipment you use to access our Services, your IP

address and your usage details (i.e. your Internet Service Provider).

1.3. The information we collect on or through our Services may include:

(i) Personal information: Your name, email address, telephone number and/or address.

We collect this information in order to allow you benefit from the services offered on

the mobile application Mobile App.

(ii) Preferences: Your preferences and settings such as time zone and language. We collect

this information in order to provide you with a personalised experience.

(iii) Searches and other activities: The search terms you have looked up, in order to reach

the Mobile App. We collect this information in order to monitor our performance

and improve our services.

(iv) Browsing information: How long you used our Services. We collect this information in

order to monitor assess the performance of our services.

(v) Communications: Between you and the mobile application support staff regarding

the Services. We collect this information in order to improve your customer service

experience.

The legal basis for the above processing is GDPR art. 6(1)(b), since the processing is

necessary in order to enter into a contract and for the performance the contract

2. HOW WE GATHER INFORMATION FROM USERS?

2.1. How we collect and store information depends on the pages you are visiting, the

activities in which you elect to participate and the services provided. For example, you

may be asked to provide information when you register for a User Account.

2.2. Like most websites, the mobile application also collects information automatically

and through the use of electronic tools that may be transparent to our visitors and

Users. For example, we may log the name of your Internet Service Provider, your IP

address, or use “cookies” technology to recognize you and hold information from your

visit. Among other things, the cookies may store your username and password,

sparing you from having to re-enter that information each time you visit, or may

control the number of times you encounter a particular part of the Mobile App. As we

use additional technologies, we may also gather information through other means. In

certain cases, you can choose not to provide us with information.

3. WHAT WE DO WITH THE INFORMATION WE COLLECT? HOW LONG DO WE COLLECT IT

FOR?

3.1. Like other websites, we collect information to enhance your visit and deliver more

individualized content. We respect your privacy and do not share your information

with anyone, except in cases when that proves necessary.

3.2. We will retain the information we collect from you for a period of five years. After the

expiry of this period we undertake to delete any information we have collected from

you.

3.3. Aggregate information and information that does not personally identify you, may be

used in many ways. For example, the mobile application may combine information

about your usage patterns on the Mobile App with similar information obtained from

other users to help enhance our Services. This information does not include any

information about you and does not allow anyone to identify you individually.

3.4. We may use personally identifiable information, collected on the Mobile App, to

communicate with you about your User Account; the mobile application Services and

giveaways; our Terms of Service and Privacy Policy; services and products offered by

or through the mobile application Mobile App; and other topics we think you might

find of interest. Personally identifiable information collected by the mobile

application may also be used for other purposes, including but not limited to Mobile

App administration, troubleshooting and other communications with you.

3.5. Certain third parties who provide technical support for the operation of our Mobile

App – our Web hosting service for example – may have access to such information. We

will use your information only as permitted by law. We may also disclose your

information in response to a court order, at other times when we believe we are

reasonably required to do so by the applicable law, in connection with the collection

of amounts you may owe to us, and/or to law enforcement authorities, whenever we

deem it appropriate or necessary. Please note we may not provide you with notice

prior to disclosure in such cases.

4. DISCLOSURE

4.1. Givvy LTD. won’t transfer information about you to third parties for the purpose of

providing or facilitating third-party advertising to you. We won’t sell information

about you.

4.2. We may share your account information with third parties in some circumstances,

including: (1) with your consent; (2) to a service provider or partner who meets our

data protection standards; (3) when we have a good faith belief it is required by law,

such as pursuant to a subpoena or other legal process; (4) when we have a good faith

belief that doing so will help prevent imminent harm to someone.

4.3. If we are going to share your information in response to legal process, we’ll give you

notice so you can challenge it (for example by seeking court intervention), unless

we’re prohibited by law or believe doing so may endanger others. We will object to

requests for information about users of our services that we believe are improper.

4.4. As noted above, certain third parties who provide technical support for the operation

of our Mobile App for example – may have access to such information.

4.5. If your personal data is transferred outside the EU/EEA, we will enter into EU standard

contractual clauses approved by the European Commission prior to such transfer to

ensure the required level of protection for the transferred personal data. If you

require additional information and/or wish to obtain a copy of the standard

contractual clauses (including relevant safeguards put in place), you can request this

by contacting us as set out in section 10.

5. YOUR RIGHTS

5.1. Right to withdraw your consent

You may withdraw your consent for collecting your personal information at any time. To do

so, please contact us at givvy.project@gmail.com.

5.2. Right to change or review your information

If you would like to review, change or delete personal data we have collected from you

or you had submitted or permanently delete your account, please contact us. For more

information regarding the termination or deletion of your information, please refer to

Section 7: Termination of this Privacy Policy.

6. ACCESSING & CORRECTING YOUR PERSONAL INFORMATION.

6.1. We take reasonable steps to accurately record the personal information that you

provide to us, as well as any subsequent updates.

6.2. We encourage you to review, update, and correct the personal information that we

maintain about you. You may request that we delete personal data about you that is

inaccurate, incomplete, irrelevant for legitimate purposes, or are being processed in a

way which infringes any applicable legal requirements.

7. TERMINATION

7.1. As mentioned above, you may at any time review or change the personal information

we maintain about you by contacting the mobile application. Upon your request, we

will delete your contact information and personal data from our active databases.

7.2. This Privacy Policy is effective until terminated by either party. If you no longer agree

to be bound by this Privacy Policy, you must cease the use of Mobile App. If you are

dissatisfied with the mobile application Mobile App, its’ content, or any of these

terms, conditions, and policies, your sole legal remedy is to discontinue using the

Mobile App. The mobile application reserves the right to terminate or suspend your

access to and use of the Mobile App, or parts of it, without notice, if we believe, in

our sole discretion that such use is in violation of any applicable law, or harmful to our

interests or the interests of another person or entity, or where the mobile application

has reasons to believe that their use is in violation of this Privacy Policy or the Terms

of Use.

8. CHILDREN’S PRIVACY

The mobile application

does not knowingly collect personal information from children

under the age of 18. If we learn that we have personal information on a child under the

age of 18, we will delete that information from our servers. The mobile application

encourages parents to go online with their kids.

9. OTHER PROVISIONS

9.1. Changes to This Policy

The mobile application reserves the rights to change this Privacy Policy at any time. Please

check this page periodically for changes. Your use of the services after any such

amendment or change in the Privacy Policy shall be deemed as your express acceptance to

such amended/changed Privacy Policy and an assent to be bound by such

changed/amended Privacy Policy. Information collected prior to the time any change is

posted will be used according to the rules and laws that applied at the time the

information was collected.

9.2. Governing Law

This Privacy Policy and the use of the Mobile App are governed the laws of the Republic of

Bulgaria. The parties undertake to first try to resolve the dispute with by negotiation. If the

parties fail to reach an amicable resolution through negotiation, the parties hereby to

submit the dispute to the competent Court of the Republic of Bulgaria.

10. MISCELLANEOUS

10.1. The mobile application is controlled, operated and administered entirely within

the Republic of Bulgaria.

10.2. If you are accessing The mobile application Mobile App from another jurisdiction,

please be advised that you are transferring your personal information to the mobile

application in the Republic of Bulgaria and, by using the Mobile App, you consent to

that transfer and to abide by the applicable laws concerning your use of the Mobile

App and your agreements with us.

10.3. This statement and the policies outlined in this Privacy Policy are not intended to

and do not create any contractual or other legal rights in or on behalf of any party.

11. CONTACT

If you believe the mobile application does not adhere to this Privacy Policy, in order to

address a question, to resolve a complaint regarding the Mobile App or the mobile

application Services, or to receive further information regarding the Services, please

contact the mobile application using one of the following methods:

e-mail: givvy.project@gmail.com