"GRAVITY HOMES" AD, EIC: 203750126, is entered in the Commercial Register and the Register of Non-Profit Legal Entities and is the administrator of personal data within the meaning of the General Data Protection Regulation. The address of the Company is in the city of Sofia, p.k. 1715, Mladost district, Alexander Malinov Blvd No. 91, floor 5, office 501.

You can contact us by phone 024218233 and by e-mail office@gravityhomes.bg.

Personal data subjects have the following rights in the processing of their personal data:

o right of access – you have the right to receive from us information about whether personal data related to you is being processed; you have the right to access the data and information in relation to the processing;

o right to rectification – you can ask us to correct inaccurate personal data relating to you, as well as to provide additional data;

o right to erasure – you have the right to request erasure of your data and you have the right to have your data erased; the data may not be deleted despite your request when there is a lawful basis for processing it, each case being considered separately and the data subjects being informed of the decision taken;

o right to limit processing – you can exercise this right in the following situations: a) when you dispute the accuracy of personal data, for a period that allows the Company to verify their accuracy; b) when the processing is illegal, but you do not want the personal data to be deleted, but instead request a limitation of its use; c) when the Company no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or defense of legal claims; d) You have objected to the processing pending verification of whether the Company's legal grounds take precedence over your interests;

o right to object to the processing – you have the right to object to the processing of personal data concerning you, which is based on the legitimate interests of the Company;

o right to data portability – you have the right to have the data that we store for you and that you have provided to us be transferred to you or to be transferred to another administrator in cases where they are processed in an automated manner and on the basis of your consent or contract;

o right to withdraw consent – ​​You have the right to withdraw your consent to the processing of personal data at any time (when the basis for processing personal data is consent); the withdrawal of consent is effective in the future and does not affect the consent given before the withdrawal;

o rights in automated individual decision-making, including profiling – you have the right not to be subject to a decision based solely on automated processing, including profiling, which gives rise to legal consequences for you or similarly significantly affects you;

o right to complain to the Commission for the Protection of Personal Data – if you believe that we are processing your personal data unlawfully, you have the right to file a complaint with the Commission for the Protection of Personal Data, whose contact details are available on its website: https: //www.cpdp.bg/: address: Sofia 1592, Prof. Tsvetan Lazarov Blvd. No. 2, e-mail: kzld@cpdp.bg; please contact us first so that we can take action immediately.

You can exercise your rights under the General Data Protection Regulation by submitting a written application electronically to the following e-mail address: dpo@ocean.investments or by submitting a written application to GRAVITY HOMES in person or by post at the address: Sofia, p .k. 1784, Mladost district, Tsarigradsko shose Blvd. No. 141.

In the processing of data by GRAVITY HOMES, reliable technical and organizational data protection measures are applied.

Information about our processing of personal data in the various relationships in which we are involved can be found in the following references.

GRAVITY HOMES processes personal data of its customers or representatives of its customers - legal entities, in the case of requests submitted to the contact details announced by us, in communication through the channels announced by us, in pre-contractual or contractual relationships for the following purposes:

o administration of relations for negotiations, purchase and sale of properties, provision of products and services and receipt of payments for amounts due, and in connection with other related communication;

o administration of inquiries, requests and orders, administration of client documents and files;

o compliance with the regulatory requirements for forming transactions, including their notarization, the Law on Measures Against Money Laundering, etc.;

o realization of the Company's legal rights - for example, to receive payments and perform contracts;

o realization of legitimate interests - advertising and carrying out marketing activities, protection of the Company's assets in its sites through the application of video surveillance for security purposes and other security measures;

o tax, accounting, including for issuing invoices, fulfillment of obligations related to the implementation of obligations stipulated by law, etc.;

o making contact with customers (for example, in connection with an offer or service provided);

o organizing campaigns;

o consideration of claims, appeals and applications to exercise rights under the General Data Protection Regulation, in connection with the Personal Data Protection Act, the Consumer Protection Act and other applicable legislation;

o service of subscriptions to receive informational and marketing messages.

The legal grounds for processing the relevant data in the various cases may be consent of the data subject, performance of a contract to which the data subject is a party, taking steps at the request of the subject prior to the conclusion of a contract, compliance with legal obligations that apply to the Company, legitimate interests of GRAVITY HOMES, as set forth in this notice. The legal grounds are based on the applicable legislation, for example the Accounting Act, the Tax and Insurance Procedure Code, the Obligations and Contracts Act, the Consumer Protection Act, the Electronic Communications Act, the Notaries and Notary Act Act, the Civil Procedure Code, the ownership, the General Data Protection Regulation, the Personal Data Protection Act, other laws and applicable by-laws.

The data is stored for the following terms/terms calculated according to the following criteria:

o for accounting and tax purposes and for services - according to the applicable legislation;

o for the purposes of video surveillance for security purposes - for a period of 60 days, in accordance with the Law on Private Security Activities; video surveillance is carried out in premises in which GRAVITY HOMES carries out its commercial and administrative activities, in view of the Company's legitimate interest in protecting the property, valuables, documents, information and personal data of the persons located in the objects in the relevant building, protection of life and the health of these persons, prevention against illegal encroachments and improvement of security in the building, control of the observance of order in the relevant building, interaction with the authorities of the Ministry of the Interior in the fight against crime, the protection of public order and carrying out preventive activities based on analysis of the reasons and conditions for offenses in the relevant facility;

o for marketing purposes, when data is acquired in the context of a transaction - until the submission of an objection (when the reason is the legitimate interest of the Company to advertise and carry out marketing activities) or the withdrawal of consent (when the processing is based on consent);

o for marketing purposes when subscribing to receive marketing messages and newsletters - until the person's request to be removed from the list of those subscribed to receive marketing messages;

o for the purposes of collecting claims and exercising legal claims - in accordance with the applicable legislation.

Personal data, for which there is no express legal obligation to store, is deleted after achieving the purposes for which it was collected.

The categories of personal data that GRAVITY HOMES can collect for its customers or for their representatives - in the case of legal entities, are as follows:

o identification data for accounting and tax purposes, as well as for the purposes of concluding transactions and their formation according to legal requirements - for example, names, uniform civil number, addresses, data from identity documents, financial data, data on property ownership;

o contact details for communication in relation to requests, pre-contractual and contractual communication - correspondence address, telephone numbers, e-mail addresses;

o video images - during video surveillance;

o data required in connection with electronic signing of documents;

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GRAVITY HOMES is a legal entity and an employer. In performing the activity, fulfilling the legal obligations and for its needs, the Company mainly cooperates with other legal entities (companies providing services to GRAVITY HOMES, banks and other financial institutions, suppliers), which in these relationships are represented by natural persons, for which personal data is processed. The personal data of such persons are processed for the following purposes:

o in connection with the conclusion, execution and termination of contracts, for the receipt of services, for payments under contracts, for contacts on operational and other issues;

o administration of contractual relations;

o providing and receiving communication services (postal, telecommunications, etc.);

o providing and receiving banking and insurance services;

o improvement of processes in connection with the execution of contracts;

o fulfillment of legal obligations of the Company;

o provision of benefits to the Company's employees;

o in connection with the implementation of measures against money laundering and the financing of terrorism, as far as applicable;

o using the services of subcontractors in the provision of security activities;

o investigating the integrity of our employees.

The legal grounds for data processing are compliance with legal obligations that apply to the Company and the administrator's legitimate interest related to the performance of its activity as a legal entity and employer, including obtaining services to support its activity. The grounds derive from existing legislation, for example the Obligations and Contracts Act, the Commercial Act, the Tax and Insurance Procedure Code, the Accounting Act, the Anti-Money Laundering Act, the Anti-Terrorist Financing Act, the Electronic Communications Act, the Protection Act of consumers, the Private Security Act and other laws and applicable by-laws.

GRAVITY HOMES processes personal data of representatives of co-contractors according to the specific case and the need. The data that may be processed are identification data as the case may be, correspondence address, telephone number, email address, other contact data, workplace and employer data, representation data. The information that such persons share in communication with us (in meetings, exchange of letters and emails, telephone conversation, chat, sending of short text messages, emails and others), which may contain personal data, may be processed if has to do with the relationship between the parties.

The data will be collected by our counterparties or by you. If necessary, public sources can be used, for example the counterparty's website, the Commercial Register and the register of non-profit legal entities, etc.

In the event that personal data is required from data subjects and they do not provide it voluntarily, other legal means and methods may be used to obtain this data, including contact with counterparties. For each specific case, individuals are informed of the consequences if they do not provide data.

The data is processed by employees of the Company who have undertaken obligations to protect the confidentiality of the information that has become known to them in the performance of their official duties and who have received this information specifically in connection with their duties in the Company. In compliance with the current legislation and in the cases provided for by law, data may be provided to competent administrative and judicial authorities and institutions. Data may also be provided to processors of personal data and their subcontractors (providing services necessary for the activity of GRAVITY HOMES), with whom contracts have been concluded, in which the corresponding protection of personal data is guaranteed. Data may be provided to operators providing postal services, in connection with these services, to banks, credit bureaus and collection agencies, etc., brokers, etc. sub., and the provision to third parties is carried out after assessment for each specific case regarding the need for their provision and compliance with the regulatory requirements.

GRAVITY HOMES will not provide personal data to representatives of its counterparties to countries or organizations outside the European Economic Area. It is possible to process data outside the European Economic Area when using communication platforms, subject to compliance with the requirements of the regulation and ensuring transparency. In the event that in the future there is a need for other operations to transfer personal data processed by the Company to third countries or international organizations, the provisions of the General Regulation on data protection will be observed, including in the event of a subsequent transfer of personal data from the third country or international organization of another third country or organization.

GRAVITY HOMES is an employer. In this regard, the Company processes personal data of job applicants.

In recruitment procedures, GRAVITY HOMES receives the personal data of job applicants personally, through job application platforms or through recruitment agencies. In the second and third cases, before the data is received by GRAVITY HOMES, the same is processed by the relevant platform/recruitment agency, without GRAVITY HOMES being involved in this processing. It is also possible to process public information in the candidate's LinkedIn professional network profile.

The following categories of personal data are processed during the selection of personnel: identification data, data on acquired educational degree and additional qualifications, data on acquired work experience and experience, telephone number and e-mail address of contact, data from conducted skills and integrity tests for some work positions, video surveillance recordings during the conduct of certain such tests or during on-site interviews in premises where video surveillance is carried out.

The personal data of the applicants are processed on the basis of Art. 6, par. 1, b. "b" of the General Regulation on data protection - to take steps at the request of the applicant before concluding a contract (pre-contractual relations between the applicant and the company), Art. 6, par. 1, b. "f" of the General Regulation on data protection - the legitimate interest of GRAVITY HOMES in selecting employees who meet the requirements for occupying the position for which the application is made, as well as on the basis of Art. 6, par. 1, b. "c" of the General Regulation on data protection - to comply with legal obligations that apply to the company, provided for in labor legislation, for example in the Labor Code.

The processing is carried out for the following purposes: selection of suitable personnel for the vacant jobs in GRAVITY HOMES, as well as for the purpose of preparing the documents for employment of the approved candidates.

In the first stage of the selection procedure, the company processes the personal data of the job applicants indicated in the resumes (CVs), as well as possibly data in the employee's LinkedIn profile and in completed forms on the company's website, if applicable, sent to GRAVITY HOMES by the candidates. Data specified in the motivation letters, if such are sent by the candidates, are also processed.

GRAVITY HOMES has not approved a specific resume form and does not limit applicants to one. The CV can be submitted in the format chosen by the candidate, and it should contain information in accordance with the requirements announced by the company for the vacant position. Using standard European CV formats, applicants can provide the following personal details: three names, address, contact details (telephone number, fax, e-mail), nationality, date of birth, work experience details, education details, qualifications and training, information on personal, social, organizational, technical and other competencies. A recent photograph is attached to CVs according to the standard templates. In their resumes, individuals may also include other information at their discretion. The data in the CV submitted by the applicant will be processed in its entirety during the examination of the application.

When submitting an application through the GRAVITY HOMES platform on the Company's website, the data specified there is processed.

The data in the CVs sent by the candidates or submitted online are processed by the Company's employees performing personnel selection functions or by a data processor on behalf of and on behalf of GRAVITY HOMES, as well as by persons in managerial positions in the Company, for example head of unit, in which the vacant position is. Candidate data may also be disclosed to public authorities, if there is a legal basis for this.

After reviewing the CVs received, GRAVITY HOMES contacts the candidates who passed the first stage of the selection and invites them to participate in the second stage - an interview. This second stage includes an interview in relation to the information provided in the first stage and aims to further analyze the candidate's potential ability to perform the position for which he is applying, as well as the compliance with the set criteria. Interviews are conducted by a team of company employees who have the competence to assess the candidate's ability to fulfill the position, as well as by the department in which the vacant position applied for is located. For some of the positions related to access to information sensitive to the company and its customers, additional tests may be applied, such as skills and orientation, integrity and others, depending on the position applied for. It is possible to conduct interviews both before and after the respective tests.

This notice contains information about the processing of personal data when using this website. "Usage Information" is online activity data that does not in itself identify an individual, such as browser type, operating system, most viewed and visited website pages and links, entry and exit points, number of form completions , the time spent on the page, the most popular keywords used off-site to drive customers to the website, information collected through cookies and other device events such as system activity. Personal data and usage data may be linked.

Different types of usage data can also be linked together and, once linked, can lead to the identification of a particular individual. Also, some usage data may be personal data under applicable law.

GRAVITY HOMES collects the information you provide to us, as well as data from the use of the website and our services offered through it. The information we collect and process depends on how you use and access the website. Some data is collected automatically through the use of cookies and other similar data collection tools over which data subjects have control.

GRAVITY HOMES has implemented a special mechanism for the management of cookies by site users.

GRAVITY HOMES collects personal information and usage data when a user creates a request for some of the services, contacts us, otherwise provides personal information or when using other services. We collect the information and content that you send us when you enter data in contact forms on our website, request additional information about a service, and when we conduct other types of communication.

1. "Cookies" (browser cookies)

A cookie is a small text file or package of information stored on the hard drive of your device (computer, mobile device, tablet) when you visit a website. Subsequently, the website server can recover or read the content of the cookie. Cookies help users to use the Internet pages efficiently and make available certain functionalities of these pages (for example, remembering user preferences such as language, settings, font, etc.). Allowing all cookies is not absolutely necessary for the website to work, but it may contribute to its better use. You can change cookie settings or refuse to accept browser cookies, other than those necessary for the site to function, by activating the appropriate setting in your browser.

On this website, cookies are in the following categories:

1.1. Strictly necessary – essential for the use of the site and for the provision of requested services. Thanks to these cookies, the site can work, and they support basic functions such as navigation between pages and access to secure parts of the site. This site cannot function properly without such cookies. These cookies are enabled by default, given their specifics.

1.2. Functionality cookies - enable the site to store information that changes the way the site behaves or looks, such as your preferred language or the region in which you are located.

1.3. Statistical cookies - help site owners learn how visitors interact with the sites by collecting and reporting anonymous information.

1.4. Marketing cookies - used to track visitors between different sites. Their purpose is to display ads that are relevant to and potentially attractive to the individual user, making them more valuable to ad publishers and third-party advertisers.

1.6. Changes to cookie settings

Most web browsers allow cookies to be placed on the end device by default. Browsers provide the possibility to control the cookies used through the settings of the respective browser.

More information about cookies can be found at www.aboutcookies.org or www.allaboutcookies.org. You can also use the cookie management options for the browser you use (Google Chrome, Microsoft Edge, Mozilla Firefox, Microsoft Internet, Opera, Apple Safari, etc.). You can also find information on the websites of other parties that use information from cookies, for example Google.

2. Flash cookies

Many websites use Adobe Flash Player to deliver videos and content to their users in the form of infographics. Adobe uses its own cookies, which cannot be controlled through your browser settings. They are used by the Flash Player program for the same purposes as other cookies, i.e. to save preferences or track users. Flash cookies work differently than cookies in your web browser. You can control how much information can be stored in this cookie, but you cannot choose what kind of information can be stored.

Some features of our website may work with such locally stored objects (Flash cookies) to collect and store information about your preferences and navigation to, from and on our website. More information on how to control such cookies can be obtained from Adobe.

3. Web Beacons

The pages of our website and our emails may contain small electronic files known as web beacons (also called clear gifs, pixel tags and single-pixel gifs) that allow the company, for example, to count users who have visited those pages or are opened an email as well as for other statistics related to the website (for example, recording the popularity of certain content on websites and checking the integrity of the system and server).

We do not automatically collect personal information through the above methods, but we may, if necessary, tie this information to personal information about you that we collect from other sources or that you provide to us.

4. Third-Party Use of Cookies and Other Tracking Technologies

On our website, as indicated above in the description of cookies used, some content or applications, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website.