PERSONAL DATA PROCESSING POLICY

Information about the Personal Data Controller:

MG TechSolutions Ltd., a company registered in the Commercial Register of the Registry Agency under UIC 208220527, with registered office and address of management: Sofia, Pirin St. 91, floor 1, office 2 Tel: +359 876 866778 e-mail: office@mgsolutions.bg.

We process your personal data on the following grounds:

• The contract concluded between us and you in order to fulfill our obligations under it;
• Your explicit consent – the purpose is specified in each particular case;
• A legal obligation provided by law.

In the following paragraphs, you will find information regarding the processing of your personal data depending on the legal basis under which we process it.

FOR PERFORMANCE OF A CONTRACT OR IN THE CONTEXT OF PRE-CONTRACTUAL RELATIONS

We process your personal data to fulfill contractual and pre-contractual obligations and to exercise the rights under contracts concluded with you.

Purposes of processing:

• Identifying you;
• Managing and executing your request and fulfilling a concluded contract;
• Preparing and sending invoices for the services you use with us;
• Keeping correspondence regarding placed orders, processing requests, reporting problems, etc.;
• Creating a user profile.

On the basis of the contract concluded between us, we process information about the type and content of the contractual relationship, as well as any other information related to it, including:

• Personal contact details – contact address, email, phone number;
• Identification data – full name, personal identification number or foreigner’s number, permanent address;
• Data on orders placed through the user profile;
• Emails, letters, information about your requests for troubleshooting, complaints, applications, grievances;
• Information about credit or debit cards, bank account number, or other banking and payment details related to payments made.

Processing of the above personal data is mandatory for us in order to conclude and perform the contract with you.

We provide your personal data to third parties, our main goal being to offer you high-quality, fast, and comprehensive service. Personal data is provided to the following categories of recipients (data controllers):

• Postal operators and courier companies;
• Persons providing consultancy services in various fields.

Data collected on this basis is deleted 5 years after termination of the contractual relationship, regardless of whether due to expiration, termination, or other reason. The term is determined by the 5-year limitation period for possible claims under the contract.

FOR COMPLIANCE WITH LEGAL OBLIGATIONS

It is possible that we are legally required to process your personal data. In such cases, we are obliged to carry out processing, for example:

• Obligations under the Anti-Money Laundering Act;
• Fulfillment of obligations related to distance sales or off-premises sales, provided for in the Consumer Protection Act;
• Providing information to the Consumer Protection Commission or third parties under the Consumer Protection Act;
• Providing information to the Commission for Personal Data Protection in connection with obligations under personal data protection legislation;
• Obligations provided for in the Accounting Act and the Tax and Social Insurance Procedure Code, and other related legal acts, in connection with lawful accounting;
• Providing information to courts and third parties within judicial proceedings, in accordance with applicable legal requirements;
• Age verification for online purchases.

Data collected in compliance with a legal obligation is deleted once the obligation for collection and storage has been fulfilled or ceases to apply. For example:

• Under the Accounting Act, accounting data is stored and processed for 11 years;
• Obligations to provide information to the court, competent state authorities, etc. (5 years).

Where we are legally obliged, it is possible to provide your personal data to the competent authority, natural or legal person.

WITH YOUR CONSENT

We process your personal data on this basis only after your explicit, unambiguous, and voluntary consent. There will be no unfavorable consequences if you refuse to provide consent.

Consent is a separate basis for processing your personal data, and the purpose of processing is specified therein. If you provide consent, and until it is withdrawn or terminated together with any contractual relations with you, we prepare personalized product/service offers.

On this basis, we process only the data for which you have expressly given us consent. The specific data is determined for each case. Usually, it includes:

• Email;
• Phone;
• Address;
• Names.

On this basis, we may provide your data to marketing agencies and third parties.

Provided consents may be withdrawn at any time. Withdrawal of consent does not affect contractual obligations. If you withdraw your consent to processing of personal data for one or all of the above purposes, we will no longer use your personal data for those purposes.

Data collected on this basis is deleted upon your request or 1 year after initial collection.

PROCESSING OF ANONYMIZED DATA

We process your data for statistical purposes, meaning for analyses where the results are aggregate and therefore the data is anonymous. Identifying a specific person from this information is impossible.

How we protect your personal data

To ensure adequate protection of company and client data, we apply all necessary organizational and technical measures provided by the Personal Data Protection Act.

For maximum security during processing, transfer, and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.

User Rights

Every user of the site has all the rights for the protection of personal data under Bulgarian law and EU law.

Every user has the right to:

• Be informed (regarding the processing of their personal data by the controller);
• Access their personal data;
• Rectification (if data is inaccurate);
• Erasure of personal data (“right to be forgotten”);
• Restriction of processing by the controller or processor;
• Data portability between different controllers;
• Object to the processing of their personal data;
• Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or significantly affects them;
• Seek judicial or administrative protection if their rights have been violated.

The user may request deletion if one of the following conditions applies:

• The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• The user withdraws their consent on which the processing is based and there is no other legal ground for the processing;
• The user objects to the processing and there are no overriding legitimate grounds;
• The personal data has been unlawfully processed;
• The personal data must be erased to comply with a legal obligation under EU or Member State law;
• The personal data has been collected in relation to the offering of information society services to children and consent was given by the holder of parental responsibility.

The user has the right to restrict processing when:

• They contest the accuracy of personal data – processing is restricted until the data is verified;
• Processing is unlawful, but the user requests restriction instead of erasure;
• The controller no longer needs the personal data, but the user requires it for legal claims;
• They object to processing pending verification of whether the controller’s legitimate grounds override the user’s interests.

Right to data portability

The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, machine-readable format and has the right to transmit that data to another controller without hindrance, where processing is based on consent or contractual obligation and carried out by automated means. The data subject also has the right to direct transfer of the data from one controller to another, where technically feasible.

Right to object

Users have the right to object to the controller against the processing of their personal data. The controller must stop processing unless it demonstrates compelling legal grounds which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defense of legal claims. When objecting to processing for direct marketing purposes, the processing must cease immediately.

Complaint to the Supervisory Authority

Every user has the right to file a complaint regarding unlawful processing of their personal data to the Commission for Personal Data Protection or the competent court.

Email: kzld@cpdp.bg

Website: www.cpdp.bg

For consultations regarding the application of Regulation (EU) 2016/679 and national legislation on personal data protection – tel. 02/91-53-555

10/05/2025