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PRIVACY and COOKIE POLICY and DATA PROTECTION
INTRODUCTION
When you visit this website www.8topuz.com hosted by 8topuz Consulting LLC and its group of companies (together “Company”, “we”, “us”) and all related websites (the “Website”), or when you correspond with us or send us your details for contacting, we may process personal data about you, as a data controller or as data processor.

This Privacy and Cookie Policy applies to our Data Subjects and sets out the basis on which any Personal information about Data Subjects shall be processed by us. “Data Subject” means any of our client’s UBO’s, directors, representatives, clients, users or you, using or just visiting our Website.

We, 8topuz Consulting LLC, a fintech institution with registration number 205071957 located in 2 Vasil Aprilov 2nd floor, 8000 Burgas, Bulgaria and our group of companies, develop, own and operate certain different services such as software or technology development.

This Policy specifies what information we collect and how we collect the information, how we use the collected information, and how we share the information and protect it. Contact Us details are provided at the end of the Policy, for feedback or any privacy enquiries you may have.

“Personal Information” means information that we directly associate with a specific person, which may include without limitations, name, address, telephone number, email address, 4 digits of payment card, payment information, IP address, credit history etc.

Please note that this Policy is governed by the Bulgarian laws.

Please read the following carefully to understand our practices regarding your Personal Information and how we will treat it.

SCOPE AND CONSENT
By visiting this website www.8topuz.com (the “Website”), you accept and consent to the practices described in this Policy. This Policy (together with any other documents referred to in it) sets out the basis on which we collect and use personal information. It applies, without limitation, to:

Your use of the Website and Services, whether by using your computer, your mobile device or any other device;
Email, other electronic messages including SMS, telephone, web chat, website/portal and other communications between you and Company.
LEARN MORE to understand what we can do if you disagree to this Policy:

THE INFORMATION WE COLLECT FROM YOU
We may collect, receive and process any information, including the Data Subjects’ Personal Information, data and other details submitted, shared or exchanged in connection with the Services. You may provide some of this information to us, for example by filling in forms via the Website, or by corresponding with us by phone, e-mail, web chat or otherwise. We may collect some of it through automatic means, for example by using cookies when you visit our Website. We may also obtain data about Data Subject from third parties, such as resellers/finders. We may also infer from your use of the Services a pattern of your transactions which becomes a separate type of Personal Information.

LEARN MORE to understand which information we collect:

INFORMATION WE COLLECT AUTOMATICALLY
We may collect information about your visit to our Website and your web browsing. That information may include your IP address, your operating system, your browser ID, location data, browser type, domain names, language settings and other information about how you interacted with our Website or other websites. It may also include anonymized demographic information, which is not unique to you or identifying you, such as your ZIP code, age, gender, preferences, interests and favorites. We may collect the abovementioned information as a part of log files as well as through the use of cookies, log files and other tracking technologies on the Services, as specified under clause 11 below.
We may use third party services, such as Google Analytics, to collect and process such data in order to analyze the traffic to the Website and the platform on which our Services are based.
SENSITIVE INFORMATION
We do not intentionally collect sensitive information relating to Data Subject’s health, ethnicity, religious or political beliefs etc., but we may obtain it in specific limited circumstances, for example if you or a User ask us to transfer money to a political party or a religious organization etc.

LEGAL BASIS FOR PROCESSING
We will only process your Personal Information on the following basis:

Where we have a legitimate interest to process data, (e.g. for our legitimate interest of managing our internal administration, claim management, risk management, conducting marketing research to improve our products and services and to offer our customers with tailored products and services), subject to such processing not overriding Data Subjects’ rights and freedoms in objecting to such processing; or
Where it is necessary to comply with legal obligations which we are subject to (for example, money laundering or other anti-financial crime checks); or
Exceptionally, when necessary in the public interest, for example when law enforcement agencies request information to investigate a crime.

HOW WE USE THE INFORMATION
We use Data Subject’s Personal Information to provide and improve our Services, to examine eligibility of onboarding of a Client, and to assess the situation in case of a transaction. for customer service purposes, and to detect, prevent, mitigate and investigate fraudulent or illegal activities. We may also use this information for sending promotional communications with respect to Services that may be of interest to you.

LEARN MORE about the use of your Personal Information by us:

AUTOMATED DECISION MAKING
We use analytics for security and anti-fraud purposes, such as to identify unauthorized use of the Services or to verify and cross-check abnormal transactions that would have been entered into by the Data Subject. In the view of the Data Subject’s previous transactions, we may infer from a request of transaction that it is abnormal, for instance with respect to its amount, the destination of the funds, the currency chosen or the rationale or absence of rationale for such transaction.

DISCLOSING OF INFORMATION TO THIRD PARTIES
We may share Data Subject’s Personal Information with third parties assisting us to provide our Services, with suppliers working on our behalf, where we have your Data Subjects’ permission, or where we are required or permitted to do so by law. We may also share Personal Information with third parties to comply with our legal obligations, to prevent any fraudulent or illegal activities related to our Services, to respond to legal process or to protect the rights or property of the Company, our customers or others. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purposes.

LEARN MORE about the cases of disclosure of information to third parties:

STORING YOUR DATA
The Personal Information that we may collect may be transferred to, stored at and processed in a destination outside your territory and/or outside the European Economic Area (“EEA”), where Personal Information may not be protected by the same standards. When we transfer Personal Information outside the EEA, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy. You expressly agree to such transfers of Data.

LEARN MORE to understand the reasons for storing Personal Information outside EEA and/or your territory:

DATA RETENTION
We may retain Data Subjects’ Personal Information in conformance with applicable laws, usually for 8 to 10 years, in order to: comply with legal requirements or to protect the Company’s legal interests, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contractual terms with the Clients and take other actions otherwise permitted by law.
In addition, we will retain Personal Information after the Client’s registration to the Services is cancelled, or if Client’s application is declined or abandoned, for as long as permitted under any applicable law, for legal, regulatory, fraud and other financial crime prevention purposes.
Personal Information required for legal proceedings and/or compliance purposes (such as AML and KYC procedures), will be retained for a period permitted under the Bulgarian law, usually 8 to 10 years.
Personal Information concerning Data Subject’s transactions, including but not limited to chargebacks and legal proceedings, will be retained for a period of 8 years, or according to the longer of Client’s and/or bank’s relevant policies regarding chargebacks or refunds, as case may be.
THIRD PARTY SOFTWARE/SERVICE
While using the Services we may be using third party software and service, in order to collect or process the information. Such software may include, without limitation, Google Analytics, which privacy policy is available at https://www.google.com/intl/en/analytics/privacyoverview.html.

USE OF “COOKIES”
We use cookies to ensure you get the best experience on our Website. You can choose to enable or disable Cookies in your internet browser or delete them. if you choose to delete them, you may lose any information that enables you to access the Website more quickly and efficiently.

LEARN MORE on what is a cookie and how you can disable it:

THIRD PARTY SERVICES
Without derogation to the foregoing, you confirm that you are aware that your activity on the Website may enable third parties, such as online search engine, to rely on the nature of your activity as stated, even outside of the Website, as an inseparable part of their ongoing activity and in the absence of any affinity to the Company’s activity. The activity of third parties as stated is subject to the privacy policy used by them alone, and is done in their full and exclusive responsibility, without the Company having any responsibility whatsoever for it.

SECURITY PRECAUTIONS TO PROTECT INFORMATION
We take a great care in implementing and maintaining reasonable and appropriate security procedures consistent with prevailing industry standards to protect the security of the Website, the Services, and Data Subjects’ Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.

While we take reasonable precautions against possible security breaches of the Services, no website or internet transmission is completely secure, and we cannot guarantee (i) that unauthorized access, hacking, data loss, or other breaches shall never occur; and (ii) the security of your or Data Subjects’ data while it is being transmitted to and from the Services; any transmission is at your own risk. Company urges you to take steps to keep your Data Subjects’ Personal Information safe, including your account password, and to log out of your account after use.

You are responsible for keeping this password confidential and complying with our instructions. You must not share credentials with anyone else, and you authorize the Company to act upon instructions and information from any person that enters your credentials. You also agree to promptly notify us of any information you have provided to us which has changed.

YOUR PRIVACY RIGHTS
Where applicable, you may have certain rights under data protection legislation, including the right to see the personal information held about Data Subjects and you may ask us to make any necessary changes to ensure it is accurate and up to date.

LEARN MORE on other rights available:

CHANGES TO OUR PRIVACY AND COOKIE POLICY
We may amend this Privacy and Cookie Policy and Data Protection from time to time as needed with a prior notice about updates or changes. Your continued use of the Services will constitute your acceptance of the revised Policy. Therefore, you should periodically check this Website to review the most current terms of the Privacy and Cookie Policy and Data Protection.

CONTACT US
If you have any additional questions or concerns about this Policy, please feel free to contact us any time through the Services or email at info@8topuz.com, or by writing to us at in 2 Vasil Aprilov 2nd floor, 8000 Burgas, Bulgaria or by calling us at +359 569 169 49.

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