E-WALLS MOBILE APPLICATION PRIVACY POLICY

This Privacy Policy describes how Walltopia AD, a Bulgarian company, UIC 204143670 (“Walltopia”, “we”, “us”, “our”) collects and processes personal data through our mobile application (“E-Walls” or “App”). This Privacy Policy applies in addition to, and does not limit our rights and obligations under the EU General Data Protection Regulation (“GDPR”) and any other applicable privacy law.

Please read the Privacy Policy carefully as this it is legally binding when you use our services. We reserve the right to change this policy at any time, and we will take reasonable steps to advise affected individuals of any material changes, if required.

We are the “data controller” of your personal data for the purposes of the EU General Data Protection Regulation.

If you have any questions about this Privacy Policy or how we collect or process your personal data, you can contact us at any time.

What is Personal Data?

“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

Personal Data We May Collect from You

We collect your personal data (a) directly from you, (b) through our interactions with us, including when you contact or request information from us, and (c) when you make your personal data public (for example, when you make a public post or let your E-Walls profile become public). We may also obtain data about you from third parties.

We may collect and use the following personal data about you:

- your first and last name, profile picture, gender and date of birth; If you use your Facebook or accounts from other third-party services to create or login to your E-Walls account, we receive information from those accounts such as your name, e-mail address, profile picture, gender and date of birth.

- username and password;

- contact information, such as your e-mail address;

- email and other online communication;

- personal data that you upload or post to E-walls

- personal data that others have shared about you through the App (e.g., posts or comments);

- any other personal data that you voluntarily choose to provide to us (e.g., the indoor climbing routes you have completed);

Our Purposes for Collecting and Processing Personal Information

We collect and process personal data:

• to operate, maintain and improve our App
• to provide you with a ranking service;
• to provide you with customer support;
• to communicate with you, including through a partner, including for marketing and promotional purposes (to the extent you have agreed to receive such marketing and promotional messages);
• to measure and analyze how our App is used;
• to enforce our terms of use and prevent violations of applicable laws;
• for other purposes that we may disclose when we request your personal data to to which you consent; and
• as permitted by, and to comply with, legal requirements.

What is Our Legal Basis for Processing Your Personal Data?

We rely on a number of legal bases to collect and process your personal data for the purposes described in this Privacy Policy, including:

• to fulfill our obligations under the App’s terms of use.
• to comply with legal and regulatory obligations (e.g. accounting and record keeping);
• as necessary for our or others’ legitimate interests, where those interests are not overridden by your interests or fundamental rights and freedoms.

In limited circumstances, where the legal bases for processing set out above do not apply, we may process your personal data with your consent. If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time.

When and How We Share Your Personal Data with Others

We may share your personal data with third parties where required by law, where it is necessary to perform our agreement with you, or where we have a legitimate interest in doing so.

Such third parties may include:

- regulatory authorities;

- our advisors, such as lawyers; 

- professional indemnity insurers;

- our processors to whom we outsource certain services, such as app developers; 

- any party as needed in connection with legal proceedings or as required by law;

Your Rights under the Privacy Law

Under certain circumstances, by law you have the right to:

- request a copy of your personal data;

- correct any inaccurate or incomplete personal data we hold about you;

- request that we erase your personal data;

- request that we restrict the processing of your data;

- have your personal data transferred to another party;

- object to certain types of processing of your personal data by us;

- withdraw your consent; and

- the right to file a complaint with the supervisory authority.

How to Contact Us

If you have any questions, concerns or a complaint regarding the processing of your personal data, please contact us at     Marketing@walltopia.com    or at the following address: 111V Tsarigradsko Shose, 3^rd fl., Sofia 1784, Bulgaria.

Filing a Complaint

If you have any concerns regarding the treatment of your privacy, you may report it directly to the relevant supervisory authority. You may contact the Bulgarian Personal Data Protection Commission at the following address: 2 Prof. Tzvetan Lazarov St., Sofia 1592, email: kzld@cpdp.bg