Privacy Policy
Last Modified: February, 2023
This privacy policy (“Privacy Policy” or “Policy”) which is an integral part of our End User License Agreement available here (“EULA”) will detail the data collection, processing and privacy practices, in the course of downloading and using our Search App and Services of BG Wallet (“Company”, “we” or “us”). All capitalized words that are not defined herein, shall have the same meaning as defined in the EULA.
This Privacy Policy will provide transparent information regarding our privacy practices and with the applicable privacy protection laws, as required, among others, according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).
Please carefully review this Privacy Policy before you download, access or use the Search App and Services. In the event you are a California or Colorado resident and the CCPA applies to you – please see our designated CCPA Privacy Notice.
Please note that your interaction with Third Party Content (as defined in the EULA) is not covered under this Policy and such third parties’ privacy practices may differ from our practices detailed herein. We do not control the privacy and security practices of these third parties. We will not be responsible or liable for such third parties’ acts or omissions.
CONTACT DETAILS OF THE CONTROLLER
BG Wallet is considered as the “Data Controller” of the Personal Data we collect from you directly, as further detailed below.
By Mail:1612 Sofia, District of Sofia (the capital) Metropolitan Municipality, Krasno Selo Region, Hipodruma Res. Complex, 19 Han Presiyan St. Bulgaria
Email address: support@bgwalletltd.com
DATA COLLECTION AND THE PURPOSES
When accessing or interacting with the Search App and our Services, we may collect certain types of data. In general, we may collect two types of information from you, depending on your interaction with us:
Non-Personal Data
During your interaction with our Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data”). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, operating system type and version, language preference, time and date stamp, country location, etc.
Personal Data
We may also collect from you, during your access or interaction with the Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data” or “Personal Information”). The types of Personal Data that we collect as well as the purpose for processing such data are specified in the table below.
For the avoidance of doubt, any Non-Personal Data connected or linked to any Personal Data shall be deemed as Personal Data as long as such connection or linkage exists.
Please see below the table which specifies the Personal Data we collect and how we use it:
| DATA SETS | PURPOSE OF PROCESSING | LAWFUL BASIS UNDER THE GDPR |
|---|---|---|
| Online IdentifiersCertain technical data may be transmitted to us when using our Search App and Services. The technical data collected shall include: your Internet Protocol (“IP”) addresses, cookie ID, or similar unique online identifiers generated (“Online Identifiers”). | We process this data in order to enable the operation of the Search App, security and for fraud prevention purposes. Additionally, we use this data to improve our Service, as well as enhance your experience while you use our Services.Further, we process this data for analytic and statistic purposes regarding traffic flow and users’ interaction with our Search App, as well as for marketing and promotion purposes. | When we process this data for operational, technical and security (fraud detection, etc.) purposes, we do it subject to our legitimate interest.When we process this data for marketing and analytic purposes, the processing is subject to your consent. |
| App Usage DataWhen you use our Search App, we will collect your browsing such as: referring app or URLs, the content or features you viewed or interacted with, web page visited, access time and date, activity logs (access, time of usage, etc.) and more data regarding the URLs of websites that you visited (“App Usage Data”).In general, such data shall be collected as aggregated Non-Personal Data, however, in some cases, web browsing data contains data that could be considered to be Personal Data.Please note that this data shall be deleted shortly after the following collection. | We process this data for the purpose of providing certain features of the Services, to improve the Services and correct any error in the Search App.We may use such data for internal analytics and measurement to understand how our Services are used, so that we can improve them and to provide you with personalized queries. | We process this data in order to preform our contract with you and enable and provide you with the Services. Other purposes, such as operational and security, are based on our legitimate interest.Where we collect this data for analytic and advertising purposes, we process this data based on your consent provided through the onboarding permissions. |
| Contact DetailsIf you voluntarily contact us through any means of communication, we make available you may be required to provide us with certain information such as your name, organization name and email address (“Contact Details”). | We will process this Contact Details for the purpose of responding to you and providing you with the requested service, information or support, As applicable.Some of the correspondence will be stored by us in the event we believe it is required (i.e. support, F&Q, etc.). | We process this Contact Details subject to our legitimate interest in order to respond to your inquiry. |
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations, made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of Personal Data to third-party countries as further detailed in the “Cross Border Data Transfer” section is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Company’s Search App and Services and to enforce the Terms, as well as to protect the security or integrity of our databases, Search App and our Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with us, we may collect information from you in one or both of the following ways:
- Automatically – we may automatically collect some information from you, such as your IP address, when you use our Search App.
- Provided by you voluntarily – we will collect information if and when you choose to provide us with it such as via communications with us, as explained in this Privacy Policy.
- Provided to us by third parties – we receive information about users from our affiliates, partners and distrusters, as detailed above.
DATA SHARING
We will share Personal Data collected solely in the events detailed below.
| CATEGORY OF RECIPIENT | DATA THAT WILL BE SHARED | PURPOSE OF SHARING |
|---|---|---|
| Service Providers | All data | We may disclose Personal Data to our trusted agents (such as legal counsel) and service providers (including, but not limited to, our Cloud Service Provider, Analytics Service Provider, CRM provider, etc.) so that they can perform the requested services on our behalf. Thus, we share your data with third party entities, for the purpose of storing such information on our behalf, or for other processing needs. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services. |
| Any acquirer of our business | All data | We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy. |
| Affiliated Companies | All data | We may share aggregate or Non-Personal Data with our affiliated companies and additional third parties in accordance with the terms of this Policy. We may store any type of information on our servers or cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our Services, aggregate statistics, marketing and conduct business and marketing analysis, and to enhance your experience. |
| Legal and law enforcement | Subject to law enforcement authority request. | In the case we will be required according to any applicable law, legal process or governmental request as well as for the purpose of enforcing our agreements and policies, establish, exercise or defend our rights and third party’s rights, and any applicable needed action in this regard, we may share your Personal Data in order to comply such requirement. In addition, we may share your Personal Data to prevent or detect illegal activities, as well as suspected fraud. |
When we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit).
TRACKING TECHNPLOGIES
The usage of our Search App and Services may include implementation of “cookies” or similar technologies, as well as software developer kits (“SDK”), on our App and Services.
Cookies are used for many different purposes, including, and not limited to, enrich our Search APP work, as well as to provide the Services and functionalities for users. Cookies enable you to improve your experience while using the Search APP and interacting with the Services. See more information about cookies at: www.allaboutcookies.org. The SDKs create the opportunity to enhance the App with more functionality.
Cookies opt-out
You are able to manage your cookies preferences, including the deletion of cookies, approval or decline of certain cookies, and receive notification prior to the store of a cookie. This can be done through your browser’s settings. For more information please review the below links (click according to the browser you are using): Google Chrome; FireFox; Internet Explorer; Safari; Edge; Opera.
Third party’s cookies which are embedded in our Search App and the Services shall be subject to the applicable third party’s cookie policy. Blocking or erasing certain types of cookies may limit your online experience. Furthermore, disabling cookies will not prevent advertisements from being displayed, however the advertisements will not be personalized.
CROSS BORDER TRANSFER OF DATA
We may store or process the Personal Data we collect in different territories, including the US or EU. If you are a resident of the EU we will take the appropriate measures required under applicable laws to ensure that your Personal Data receives an adequate level of protection upon its transfer outside the EU.
Any information you provide us may be transferred to and processed in countries other than the country from which you accessed the Search App and Services. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such data transfer.
SECURITY MEASURES
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry, such as encryption using SSL, we minimize the amount of data that we store on our servers, contractors, and agents, etc. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
Please contact us at: support@bgwalletltd.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy, or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
DATA RETENTION
We retain Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.
Other circumstances in which we will retain your Personal Data for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
YOUR RIGHTS
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. We provide you with the ability to exercise certain choices, rights and controls in connection with your information.
Depending on your relationship with the Company, data protection and privacy laws provide you with some of the following principal rights regarding your Personal Data, including (and depending on your jurisdiction): The right to access your Personal Data that we process; The right to ensure your Personal Data is accurate, complete and up to date; The right to have your Personal Data amended (by correcting, deleting or adding information); The right to object to the processing of your Personal Data, to the extent applicable; The right to send or “port” your Personal Data; The right to file a complaint with a supervisory authority in your jurisdiction; The right to withdraw consent, subject to legal or contractual restrictions and reasonable notice; Right to Non-Discrimination, etc.
For California or Colorado, please see our CCPA Notice.
For detailed information on your rights and how to exercise your rights, please see the Data Subject Request Form (“DSR”) available here or send it to: support@bgwalletltd.com.
Further, you may execute certain rights without the need to fill out the DSR Form, such as: You can correct or delete the Contact Information or Account information at any time, through the account settings, You can you can opt-out from receiving our emails by clicking “unsubscribe” link, You can withdraw consent for processing Online Identifiers for analytics or marketing purposes, at any time be using the cookie settings on the website, Use the “Do Not Sell or Share My Information” through the first-party business, i.e., through the cookie consent manager presented on the Publisher’s website, etc.
To opt-out from cross contextual ads you can further use these links: the Network Advertising Initiative’s (“NAI”) website: NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website: DAA opt-out page. Or the European Interactive Digital Advertising Alliance (“EDAA”) website: Your Online Choices page.
Please note that:
- We may request additional information from you when you contact us in order to verify your identity and locate your data.
- It may take time to process requests in a way that is consistent with applicable privacy law.
- We may reject your request in case you don’t provide required information or according to applicable law.
CHILDRENS’ DATA
The Services are not intended for use by children (the phrase “child” shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children’s information. We will discard any information we receive from a user that is considered a “child” immediately upon discovering that such a user shared information with us. Please contact us at: support@bgwalletltd.com if you have reason to believe that a child has shared any information with us.
CHANGES AND AMENDMENTS
We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version of the Privacy Policy will always be posted on the website and the update date will be reflected in the “Last Modified” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective within 30 days upon the display of the modified Privacy Policy. We recommend you review this Privacy Policy periodically to ensure that you understand our most updated privacy practices.