Privacy Policy

This Privacy Policy regulates the processing of personal information provided by users of the www.bulmint.com Website (the "Site") in connection with the services available on and through the Site.

The site is registered in the name of and managed and maintained by Bulmint Trade EOOD, a solely limited liability company with its registered office, management address and correspondence address: 4109 Branipole village, 50B Anchov Bunar Str., tel .: +359 889683409, entered in the Commercial Register of the Registry Agency with UIC 205579717, represented jointly and separately by Plamen Angelov Zapryanov and Vladimir Angelov Spasov - Managers (hereinafter referred to as Bulmint Trade, Company or We "). This Privacy Policy (the "Policy"), together with the Terms of Use of the Site, the General Conditions for Remote Sales and all other documents mentioned on the Site, sets out the rules that the Company will comply with when processing personal data, that we collect for you or that you provide to us.

This Policy does not affect, restrict or revoke your rights under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals concerning the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (GDPR), Personal Data Protection Act (“LPPD”) and other applicable European and national data protection regulations.

If you have any questions or comments about this Policy, please contact our Data Protection Officer at 4109 Branipole village, 50B Anchov Bunar Str., email: office@bulmint.com, or by phone: +359 889683409.

This policy defines:

• the principles that Bulmint Trade adheres to when processing personal data;
• the groups of persons for whom personal data are processed;
• the categories of personal data processed by Bulmint Trade;
• the purposes for which Bulmint Trade processes personal data;
• the legal grounds for the processing;
• Your rights in relation to your personal data, including the existence of the right to request from Bulmint Trade to access, correct or delete your personal data or restrict the processing of such data, the right to object to the processing, the right to data transfer and the right a complaint to the Commission for Personal Data Protection;
• the period for which your personal data will be stored and, where this is not possible, the criteria used to determine this period;
• the cookies used by the Site;
• the categories of third parties to which Bulmint Trade may provide personal information.

Bulmint Trade complies with the following principles when processing your personal data:

• legality, integrity, and transparency;
• limitation of processing objectives;
• relevance to the purposes of processing and to minimizing the data collected;
• data accuracy and timeliness;
• storage limitation to achieve the objectives;
• integrity and confidentiality of the processing and guaranteeing an appropriate level of personal data security;
• accountability.

As a personal data administrator, Bulmint Trade meets all the requirements arranging the protection of personal data, collecting only data of individuals to the extent necessary, and safeguarding them responsibly and legally. Bulmint Trade maintains internal order as a personal data administrator, applying technical and organizational measures to its staff, premises, software, hardware, networks, encryption, control, reporting, monitoring, vulnerability checks, and more. We have ensured comprehensive and reliable physical, personal, documentary, and cryptographic protection of personal data processed by us against unauthorized or incidental access, loss, alteration, disclosure or destruction of data, taking into account the risks. All our employees have undertaken an obligation of confidentiality regarding personal data that they have access to in the course of their employment.

GROUPS OF PERSONS FOR WHICH PERSONAL DATA IS PROCESSED, CATEGORIES OF PERSONAL DATA PROCESSED, AND PERIOD FOR STORING THEM

• individuals - users of the Site, with or without registration, who have visited the Site without placing an order;
• individuals who placed an order through the Site with or without registration;
• representatives, proxies or employees of legal entities on whose behalf an order has been placed through the Site;
• individuals who corresponded with Bulmint Trade by telephone, regular or e-mail on any matter relating to the services available on and through the Site, this Policy, technical issues, etc., and in rare cases individuals, information for which such correspondence is contained.

• information you provide or update by completing registration forms/fields/forms or posting content on the Site (names, permanent address, delivery address, date of birth, telephone and/or fax number, e-mail (email), information related to payments made and owed, such as bank, bank account (IBAN) and bank card information, a preferred method of communication, invoice data, order history, Site settings, and notifications, etc.). This includes information provided when registering to use the Site, subscribing to our service, purchasing goods through the Trade Web Store, posting materials or requesting new services, and publicly available information we receive, including but not limited to if you link your Site profile to your Facebook account or to your account on another social network / third party application, insofar as such technical ability is available on the Site;
• information you provide when reporting a problem to the Site, reporting against another user of the Site, or contacting us for another reason. If you contact us, we can keep a record of the conversation as well as the result of this processing of information to resolve the issue;
• details of visits to the Site, including, but not limited to, date and time of access to the Site, pages viewed, IP address, hardware, and software used, traffic data, location data, blog and other communication data used and resources, such as the date, time, and IP address of registering with the Site and agreeing to this Privacy Policy;
• if you access the Site through a mobile device, we may process information about your location, as well as information about that site, such as your device identification number and type, to provide greater value to our services. If you do not want us to receive location information, you can turn off the appropriate features of your device that allow tracking if the device offers such a feature;
• only when the anti-money laundering legislation in force requires, in addition to the information in the preceding points, the collection of more personally identifiable information about you, including, but not limited to, information about: an official personal identification number or other unique Identity element contained in an official ID document whose validity has not expired and which has your photograph, for example, a unique civilian number, alien's personal number, personal document number ID issued by the competent authorities of the European Union or a third country; passport data - series, number, date, place and issuing authority and validity of an identity document; country of residence and address; Your participation and/or holding of shares or securities in companies (if applicable); information about the origin of the funds you use to make the transaction and the purpose and nature of your involvement in the business relationship you enter through the Trade e-shop; any citizenship you possess; your marital status; data on your professional and work activity - profession, place of work (employer); information on whether you hold a senior political position within the meaning of the Anti-Money Laundering Act; a copy of your official ID; Your signature; additional documents, data or information that we are required by law to collect and may vary depending on the case.

• personal data of persons under the age of 18, as the services available on and through the Website, are not intended for such persons;
• special categories of (sensitive) personal data revealing racial or ethnic origin, political, religious or philosophical beliefs, union membership, nor genetic, biometric data, health status, sex life, sexual orientation, convictions, or consumer abuse on the website.

Bulmint Trade does not make decisions based solely on automated processing of personal data, including profiling, and have legal or similar effects that significantly affect the users of the Site, unless there are grounds for personal data protection in the privacy law and appropriate safeguards are in place to protect the rights, freedoms and legitimate interests of the users of the Website.

We store your personal data only to the extent necessary for the specific purposes of the data processing in order to provide you with the services available on and through the Site, to ensure their security and reliability, and to meet your needs in accordance with our legal or regulatory obligations so that we can manage our rights (for example, to sue) or for tax and accounting purposes. When we no longer need your personal data and have no legal reason to continue to store them, we take the necessary care to delete them from our system and destroy them without undue delay, or to make them anonymous so that they can no longer identify you. In the event that the storage period of your personal data is required to be extended in order to fulfill the specific predefined processing purposes, to fulfill our contract with you for the provision of distance financial services, legitimate interests of Bulmint Trade, or for any other reason, You will be notified in advance.

Below you can find information on the criteria we apply to determine the retention periods of different types of personal data, the most important of which is the specific quality of Bulmint Trade as a financial institution and a person obliged to implement measures against money laundering and terrorist financing:

• Some of the services available on and through the Site, namely the sale of articles with and from precious metals, are financial services that we, as a financial institution, provide to you remotely. Regardless of the fact that you purchase gold or silver products through our Website on the Internet, this transaction is subject to all rules of the legislation in force in the Republic of Bulgaria, which would be valid even if the same transaction were concluded on the spot at a trade object of Bulmint Trade. In addition to the basic rules applicable to the conclusion of all such transactions, in certain cases regulated by law, Trade has the obligation to identify its customers. “Identification” is a legal concept and according to the Law on Measures against Money Laundering, it is expressed in the requirement of documents, data, and information from the client. In order to carry out proper identification in each transaction, as well as to be in constant readiness to provide all the required information to the control bodies, we are obliged to store the information about your previous purchases from the Site and to consider it in every subsequent order. In this connection, please note that all your personal data collected during or in connection with the purchase of precious metal products and products through this Site, including during the identification process, as well as all your personal data required for tax and accounting purposes of Bulmint Trade as a company, will be retained by us for the appropriate period provided by applicable law, which may exceed the term of your registration on the Site.
• We retain all your personal information that is not within the scope of the previous point until your account is deleted from the Site. Specifically, this is the data that you used to log in to the Site and used to access it, such as your password; the information you provided when subscribing to our service or requesting a new service; the data you provide when posting materials on the Site; the publicly available information we receive, including, but not limited to, linking your Site account to your Facebook account or to your account on another social network / third party application, insofar as such technical ability is available on the Site; information you provide when you report a problem to the Site, report against another user of the Site, or contact us for any other reason, including correspondence records made to resolve the problem and the result of that processing of the information; the details of your visits to the Site from fixed or mobile devices where no purchase was made during the visit, including, but not limited to, date and time of access to the Site, pages viewed, IP address, hardware and software provided, used, such as your device ID and type, traffic data, location data, blog, and other communications and resources used. If part of the data mentioned in this item has a legal obligation to store it (see the previous item), then this part of the data will not be deleted or destroyed when you delete your account.
• When we use cookies, we keep them for as long as it is necessary to fulfill their goals.
• When you have consented to receive communications for direct marketing and advertising purposes, you will receive them as long as you unsubscribe or request to be unsubscribed from our list.

THIRD-PARTY INTERACTIVE APPLICATIONS

At the Company's discretion, the Site may include applications offered by other vendors, such as Facebook, Twitter, etc. You may be offered a "like", "share" feature, or the like, whereby the provider of this application may link the information it collects to you to your profile in its application. In this way, the information in your Site profile may be made available to the provider of the respective application, other users and your friends in the respective application.

OBJECTIVES AND LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

Depending on the purpose for which the data is used, the legal basis for processing your personal data may be one or more of the following:

• creating your Site profile;
• providing access to the Site or parts/segments/modules of the Site and the ability to use the services (or part of them) available services and functions;
• individualization of a party to the contract for the provision of the respective service and ensuring its performance;
• contacting you about items you have ordered through the Bulmint Trade e-shop;
• communication with you regarding a report you have made against another user of the site, a problem with the Site that you have reported, or if you have contacted us for another reason (for example, to request additional information about a service available through the Site);
• personalizing your visit to the Site, thereby enabling you to make the most of the services offered through the Site;
• we may also use the information we collect for you to notify you of changes to the functionality of the Site or to provide you with other information related to its use. Bulmint Trade may provide you with information, products, services, news, newsletters, and special promotions that we think you would be interested in, as well as respond to your requests, and you may request the termination of your personal data for such purposes, in accordance with the following in the "Your Rights" section;
• to fulfill Bulmint Trade's statutory obligations (for example, customer identification and other obligations arising from the Anti-Money Laundering Act, tax legislation, etc.);
• financial and accounting activity;
• for the purpose of direct marketing and advertising of Bulmint Trade products and services, and you may receive messages from us by regular mail, email, or telephone (depending on the information you have provided). You have the right to withdraw your consent to the processing of your Personal Data for direct marketing purposes, as set out below in the "Your Rights" section. The Site may sometimes contain links or hyperlinks to other sites. We may not operate the Linked Sites and disapprove of the content, services, and products of those Sites. We recommend that you use the linked sites carefully and with due care for their content and terms of use. If you transfer to another site through a link from our Site, we may receive aggregated or otherwise anonymous statistical information about your traffic to those sites. Bulmint Trade is not responsible for the privacy policies or content of such sites, and we encourage you to review their privacy policies.
• your consent to the processing of your personal data for one or more of the specific purposes of the said, in which case your personal data will be processed to the extent and under the conditions provided for in that consent.
• the need to execute a contract to which you are a party or to take steps at your request prior to the conclusion of such a contract, including the processing of personal data required for registration, account creation, and service activities, available on and through the Site. In addition, these goals include communicating with you, including by email, required to provide these services and/or notifying you of changes to them.
• the need to comply with a legal obligation that applies to Bulmint Trade. Due to the specific scope of Bulmint Trade's activity, regulations often require us to request more detailed personal information about our customers. This information is needed by Bulmint Trade and the regulatory authorities to ensure the security of your funds and to provide you with services in accordance with applicable law.
• the need to protect and pursue the legitimate interests of Bulmint Trade or a third party. These legitimate interests may include ensuring the proper functioning and use of the Site by you and other users, maintaining and administering services available on and through the Site, resolving disputes, identifying and preventing malicious actions, detecting and resolving technical or functional issues, development, and improvement of services available on and through the Site, communication with you, including by electronic means, on important issues related to these services, receiving and processing any alerts or requests you receive for further information, exercising and protecting the rights and legitimate interests of the Bulmint Trade, including in court, and assisting in the exercise and protection of the rights and legitimate interests of other users of the Site or third parties involved.

In connection with the processing of your personal information, you have the rights listed below that you can exercise by submitting a hard copy application to the Bulmint Trade correspondence address listed in the Introduction section or electronically at office@bulmint.com.

The application should be in free text and, if necessary, our Data Protection Officer will be fully assisting in formulating it. Bulmint Trade is committed to timely responding to your requests regarding your personal information. Any received application, request, inquiry, or any other communication related to the protection of personal data will be answered within one month and you will be informed of the extension as well as the reasons for the delay if necessary.

To avoid abuse, we reserve the right to request additional data and actions from you with a view to establishing the identity of the applicant and the data subject, such as, for example, presenting an identity card or entering your personal data for login to the data subject's profile in front of a Bulmint Trade employee.

The right to request access to personal data relating to you, and in particular to request to receive from the Company:

• confirmation that personal data relating to you are being processed;
• information about the purposes of such processing, the categories of personal data, recipients or categories of recipients to whom personal data relating to you are disclosed;
• communication in an understandable form containing your personal data and any available information about their source;
• information about the logic behind any automated processing of personal data relating to you.

• personal data are no longer needed for purposes for which they were otherwise collected or processed;
• when you object to processing - where the processing of your personal data is necessary for the purposes of the legitimate interests of Bulmint Trade or a third party or your personal data is processed for the purposes of direct marketing, and there are no legal grounds for the processing, to have an advantage;
• when processing was unlawful;
• when your personal data must be deleted in order to comply with a legal obligation under European Union or Member State law that applies to Bulmint Trade;
• where you have withdrawn your consent on which the processing of the data is based and there is no other legal basis for the processing;
• when your personal data have been collected in connection with the provision of information society services.

In these cases, Bulmint Trade may refuse to delete your personal information for the following reasons:

• A) to exercise the right to freedom of expression and the right to information;
• B) to comply with a legal obligation requiring processing as provided for in European Union law or the law of the Member State applicable to Bulmint Trade, or for the performance of a public interest task or in the exercise of official powers conferred on Bulmint Trade;
• C) for reasons of public interest in the field of public health;
• D) for purposes of archiving in the public interest, for scientific or historical research or for statistical purposes;
• E) to establish, pursue, or defend legal claims.

Bulmint Trade does not delete the data that it has a legal obligation to keep, including for the protection of legal claims against him or for proving his rights.

The right to ask Bulmint Trade to restrict the processing of your personal data when one of the following hypotheses is met:

• You dispute the accuracy of personal data for a period that allows Bulmint Trade to verify the accuracy of personal data;
• the processing is unlawful, but you do not want your personal data to be deleted, and only their use will be restricted;
• Bulmint Trade no longer needs personal data for the purposes of the processing, but you require it to establish, exercise or defend your legal claims;
• You objected to the processing pending a review of whether Bulmint Trade's legitimate grounds would prevail over your interests.

Where the processing of your personal data is restricted as a result of your request to that effect, such data shall be processed by Bulmint Trade, with the exception of their storage, only with your consent, or for the establishment, exercise or defense of legal claims, or for the protection of the rights of another natural person or on important grounds of public interest to the European Union or a Member State.

When you have requested a restriction on the processing of your personal data, Bulmint Trade will inform you prior to the cancellation of the restriction on processing.

Right at any time and on grounds related to your specific situation, to object to the processing of personal data concerning you, which is necessary for the purposes of the legitimate interests of Bulmint Trade or a third party, including profiling based on such interests. In such cases, Bulmint Trade will cease processing your personal data unless it proves that there are compelling legal grounds for processing that take precedence over your interests, rights, and freedoms, or for the establishment, exercise or defense of legal claims.

The right to object at any time to the processing of your personal data, including if it is processed for the purposes of profiling or direct marketing and advertising and to the disclosure of your data to third parties and their use on their behalf for the purposes of profiling or direct Marketing and Advertising. In these cases, the processing of your personal data for these purposes will be terminated in the future.

The right to receive personal data that concerns you and which you have provided to Bulmint Trade in a structured, widely used and machine-readable format, and the right to transfer this data to another administrator without hindrance by Bulmint Trade (aka. "Right to data portability"), where the processing is carried out in an automated manner and is: based on your consent to the processing of your personal data for one or more specific purposes, or necessary for the performance of a contract to which you are a party, or necessary to take taking steps at your request before concluding such a contract.

When you exercise your right to data portability, you have the right to receive a direct transfer of your personal data from Trade to another administrator, when this is technically feasible. Exercising your right to data portability is without prejudice to the right to delete your personal data (the "right to be forgotten") and could not be exercised if it would adversely affect the rights and freedoms of others.

The right not to be the subject of a decision based solely on the automated processing of your personal data, including profiling, which has legal consequences for you or similarly affects you significantly, unless provided for in the applicable personal data protection legislation data on this and appropriate safeguards are provided to protect your rights, freedoms and legitimate interests.

The right to ask Bulmint Trade to inform you of any recipients to whom personal data for which correction, erasure, or restriction of processing has been requested have been disclosed. Bulmint Trade may refuse to provide this information if this would be impossible or would require a disproportionate effort.

The right to be notified by Bulmint Trade without undue delay when, due to a breach of security of your personal data, high risk to your rights and freedoms may be created, including the right to be informed of the measures taken or are about to be taken. Bulmint Trade has no obligation to notify you if:

• has taken appropriate technical and organizational safeguards with respect to data affected by a security breach;
• subsequently took measures to ensure that the violation would not pose a high risk to your rights;
• a notification would require a disproportionate effort.

The right to be notified should Bulmint Trade find that for any reason it is unable to fulfill its obligations under this Policy or the applicable data protection regulations.

The right to be notified in advance in the event of a merger, acquisition, or sale of an asset of Bulmint Trade affecting the processing of your personal data.

Right to contact the Trade Data Protection Officer at 4109 Branipole village, 50B Anchov Bunar Str., Email: office@bulmint.com, or at +359 889683409.

Right to lodge a complaint with the competent supervisory authority - Commission for Personal Data Protection, address: 1592 Sofia, Prof. Tsvetan Lazarov № 2, phone: +359 2 915 35 18, e-mail: kzld@government.bg, kzld@cpdp.bg, website: www.cpdp.bg, if you believe that your rights related to the protection of personal data have been violated.

In order for the Site to work according to the functionality set by the Bulmint Trade team, as well as to improve your experience on the Site and to personalize your visits, we sometimes store small data files on your device, called "cookies". It is a standard practice widely used in almost all sites around the world. This document explains how we do this.

What are cookies? Cookies are small text files saved by your browser to your device's hard drive. They allow us to identify the device of the user and to achieve the correct behavior of a web page according to his individual preferences. This improves the functionality of the Site. For example, using cookies can save the password for each session, so you don't have to enter it every time you visit. Cookies usually contain the website name, storage time of the device, and a unique number. In certain cases, cookies also allow personal identification of users.

How do we use cookies? Cookies are used to adapt the content of the Site to the user's preferences and to optimize the use of the Site. They are also used to create anonymous statistics (about user behavior on the Site) in order to improve the structure, design, appearance, and content of the site.

What types of cookies do we use?

Bulmint Trade uses the following types of cookies:

• "session cookies", which are temporary and are usually deleted by your device when you leave the relevant web page, close the web browser or turn off your device; and
• Persistent cookies that are stored on your device for a specified period of time, which are specified in the cookie parameters and may exceed one year, or until you manually delete them. These cookies can be used again the next time you visit the Site.

Bulmint Trade may also allow the use of third-party cookies. These are cookies associated with software products that record anonymous user statistics (Google Analytics, CrazyEgg, Kissmetrics, and others).

Alternatively, third-party cookies may be linked to social buttons and plugins that allow for page sharing and interaction with social networks. In order for these tools to work, social networks (such as Facebook, Twitter, Instagram, etc.) may record cookies through the Site to interact with the user's anonymous profile on a network or to add data to the information collected in a manner and with goals outlined in their respective policies and websites. Some videos displayed on our Site pages but provided by third parties (such as YouTube) may use cookies to collect anonymous information, such as how a user accessed a video, what videos they watched, and more.

Bulmint Trade does not have access to or control over cookies that are used and provided by third parties. This Policy does not apply to the way in which a third party collects and treats such information. It is a good idea to familiarize yourself with the relevant policies of the third parties in question in order to be aware of their practices and behavior.

The personal data collected from cookies may only be used to perform specific functions on the Site related to the user. The personal data is encrypted to prevent access to it by unauthorized persons and to guarantee the anonymity of the user using the Site.

How to control and/or delete cookies?

Most sites automatically accept cookies, but if you do not want to accept cookies, you can configure your browser to reject them. Most web browsers allow cookies to be controlled through the settings of the browser itself. You can usually find these settings in the Options or Preferences menu. You can delete all cookies that are already stored on your device, as well as set most browsers to block them completely. However, if you do this, you may need to manually adjust some settings each time you visit a site, and some services and features may not work. Unfortunately, in most cases there is no universal option to disable cookies without restricting the functionality they add to the site.

To learn more about cookies - including how to control them - you can visit http://aboutcookies.org.

In some cases, in order to fulfill our obligations under a contract or legal agreement with you, we may be obliged or may need to disclose personal information you provide to third parties, such as our trusted partners or competent authorities, and namely:

• to competent state and local authorities and their administrations, including, but not limited to, the Commission for Personal Data Protection, the Commission for Consumer Protection, the State Agency for National Security, the National Revenue Agency, the Minister of Finance, the Bulgarian National Bank, customs bodies, bodies of the Ministry of the Interior, judicial bodies. Your personal data may be provided to such authorities in order to comply with their order, to fulfill a legal obligation or to protect the rights, property or security of Bulmint Trade, our customers or others;
• to courier service providers, including, but not limited to, Econt Express OOD, UIC 117047646, in order to deliver items that you have purchased through the e-shop of Bulmint Trade, available on the Site;
• IT service providers, hosting services, our database maintenance services, technical equipment, software and applications that may contain data about you (such services are sometimes associated with access to your personal data to perform these tasks), social networks, web analytics, and search engines, use of tools to refine user-generated content;
• for the purposes of carrying out various promotional activities, advertising and marketing campaigns, PR initiatives and implementation of similar events, as well as for analyzing their effectiveness through the use of external services of specialized companies and organizations (advertising, marketing, digital) and social media agencies), with a view to fulfilling their contractual obligations and responsibilities.

Bulmint Trade may provide your personal data to selected third parties unrelated to Bulmint Trade for the implementation of the pre-defined and specific purposes of the processing, provided that these third parties are committed to providing an adequate level of personal data protection, to comply with the regulations in force at European and national level and our instructions in accordance with this Privacy Policy, and refrain from processing your personal data for any purpose except in connection with the services provided to us. Bulmint Trade may also provide aggregated statistics on customers, sales, browser types, operating systems, the Internet, domain, demographic or profile data, traffic patterns, and related information from the Third Party Site, but these statistics do not contain personal data that would identify you.

Bulmint Trade will notify you if you intend to share some or all of your personal data with a third country or an international organization, in which case it will outline the possible risks of data transfer to a third country in the absence of adequate protection and adequate means of protection.

This Policy does not apply to third parties who view/use content generated by a user of the Site after it has been posted on the Site, including, but not limited to, information on your account, the material you have posted/submitted, and etc. The provision of your Personal Data to other users of the Site is at your own risk and Bulmint Trade is not responsible for any damages or violations that you have suffered as a result of such provision.

This Policy is available at https://bulmint.com/terms-and-conditions

Bulmint Trade reserves the right to change and/or supplement this Policy at any time. Changes will take effect immediately upon their publication on the Site unless otherwise provided in the updated version of the Policy. You should periodically visit this Policy Review page. The Policy may be updated at any time without special notice to users of the Site. Bulmint Trade is not responsible if a user of the Site has not read the latest version of this Policy.