Who are we?

DIV Motion Ltd. is a company registered under the law of the Republic of Bulgaria, having its headquarters and management address in:

Republic of Bulgaria, Sofia 1407, Triaditsa region, Krastova Vada dstr., Cherni Vrah № 190d blvd., ap. 602

The main activities the company engages in are developing and administering of web-portals, data processing and hosting, IT consulting services, project development and management, innovation transfer and development, intellectual property transactions and more.

As our activities require the processing of personal data, this Privacy Policy serves to give you all necessary information regarding your Personal Data. For any further questions, you can contact us at the above postal address or by e-mail: privacy@divmotion.com

Additional information about our company, our team and other ways to contact us can be found on our website: https://divmotion.com

Scope of the processing

This Privacy Policy applies to the collection of personal data on our website and the subsequent processing of this data by us.

This Privacy Policy further serves towards provision of information pursuant to Articles 13 and 14 of the GDPR for data processing outside the scope of collection via this website. As such we will provide you with separate privacy policies for specific data processing activities on a case-by-case basis.

Collection and storage of personal data and nature and purpose of their processing

a. When you visit the website

When you go to our website https://divmotion.com the browser used on your device automatically sends information to our website's server. This information is temporarily saved in a log file. The following information is collected without your intervention and saved until it is automatically deleted after three (3) days:

• IP address of retrieving computer,
• date and time of access,
• name and URL of retrieved file,
• website from which access occurred (referrer URL),
• website retrieved from our website,
• your computer's browser and possibly operating system as well as name of your access provider.

The aforementioned data is processed by us for the following purposes:

• to ensure trouble-free connection establishment to the website,
• to ensure comfortable use of our website,
• to analyse the system security and stability, and
• for other administrative purposes.

The legal basis for processing of the data is Art. 6(1) Sent. 1 (f) of the GDPR. Our legitimate interest follows from the purposes for data collection listed above.

b. When you contact us by e-mail

You can contact us with questions of any kind via the provided email address(es).

If you do so the personal data transmitted via the email is saved. The legal basis for data processing for the purpose of making contact is Art. 6(1)(f) of the GDPR. If contact is made for the purpose of concluding a contract an additional legal basis for processing is Art. (6)(1)(b) of the GDPR.

We delete the personal data collected by us after processing your inquiry provided we are not legally entitled or obligated to process it further.

c. When you contact us via our contact form

You can contact us via our contact form for any inquiries you may have. In such case, we collect the following data you put in the form:

• Personal Master Data (Names);
• Contact data (Email, Phone);
• Additional data: any data you may disclose in your inquiry.

The legal basis for data processing for the purpose of making contact is Art. 6(1)(f) of the GDPR. If contact is made for the purpose of concluding a contract an additional legal basis for processing is Art. (6)(1)(b) of the GDPR.

We delete the personal data collected by us after processing your inquiry provided, we are not legally entitled or obligated to process it further.

In any of the aforementioned cases you are not subject to automated individual decision-making, including profiling.

Categories of recipients of the data (Who it will be shared with)

If registering interest in our services (via our contact form), the personal information you provide will be stored in a Customer Relationship Management system (CRM) and made available only to the person(s) equipped to handle your request.

In all cases, personal information is not otherwise sold or shared with any third parties, unless:

• you have provided your explicit consent for one or more specific purposes pursuant to Art. 6, par. 1 (a) of the GDPR;
• the disclosure pursuant to Art. 6, par.1 (f) of the GDPR is necessary for the assertion, exercising or defence of legal claims and there is no reason to assume that you have a primary protection-worthy interest in not having your data disclosed;
• for the case that there is a legal obligation for disclosure pursuant to Art. 6, par. 1 (c) of the GDPR and;
• it is legally permissible and necessary for fulfilment of contractual obligations pursuant to Art. 6, par. 1 (b) of the GDPR;
• Pursuant to Art. 28 of the GDPR, we have contracted a data processor, who process the data on our behalf, according to our explicit instructions.

Transmission of your personal data for purposes other than those listed above does not occur.

Cookies

Like most websites, we use cookies when you access and browse our website in order to make your visit as comfortable and effective as possible. Cookies are small files that are created by the website and are automatically stored in the browser of your device (laptop, tablet, smartphone etc). Cookies do not harm your device and do not contain any viruses, spyware, or other malicious software. Information yielded in connection with the specific device used is stored in the cookie. However, this does not mean that we directly receive knowledge of your identity through this.

The use of cookies enables us to offer you a more pleasant experience when visiting out site. For example, we use so-called session cookies to recognize that you have already visited individual pages on our website. These are automatically deleted after you leave our website. Likewise, to optimize the user-friendliness, we also use temporary cookies, which are saved on your device for a specific pre-defined period of time. If you visit our website again to use our services, it will automatically be recognized that you already visited us and the entries and settings you made will automatically be recognized so that you do not have to enter them again.

Cookies are divided up into three categories – “Necessary”, “Statistics”, “Comfort”.

Necessary cookies are required for the operation and the basic functions of our website. They enable the security-relevant functioning of this website.

Statistical cookies are used for improving our service and ensuring a design based on your wants and needs and the future optimization of our website. For this, we collect anonymized data for statistics and analytics, such as to determine site traffic, page view statistics, user behaviour, and to adapt and improve our content and the website experience.

Comfort cookies are used for facilitating the use of our website. If you visit this website again to use our service, it will automatically recognize that you were on our website and the entries and settings you made will automatically be recognized so that you do not have to enter them again. For example, through this, you will not have to re-enter your user data or preferred language every time, but rather you can access the data already entered when you visit the website again.

The data processed through necessary cookies are for the stated purposes for safeguarding our legitimate interests pursuant to Art. 6 par. 1 (f) of the GDPR, such as the proper functioning of the site.

The data from comfort and statistical cookies can only be collected and processed further based on your prior given consent, in accordance with Art. 6 par. 1 (a) of the GDPR for the purposes of providing personalized content, statistics and tailoring the user experience. For these you can change/withdraw your consent through our interactive Cookie banner.

Cookie Management

While it is true that most browsers automatically accept and store cookies, you can configure your browser settings to never store cookies on your device or that a notification prompt always appears before a new cookie is employed. Bellow you can find some helpful links on how to enable cookie management based on your preferred browser:

Microsoft Edge, Mozilla Firefox, Google Chrome, Safari, Opera

Keep in mind that deactivation of all cookies may lead to some inconveniences and dysfunctionalities, when accessing websites.

We use the following cookies:

Social media buttons

We use buttons for social networks such as Facebook, Twitter, LinkedIn on our website. The buttons are simple HTML links. None of your personal data is transmitted in the process. You only become directly connected to Facebook, LinkedIn or Twitter if you perform an action. Before that the social networks cannot collect any data about you. As long as you do not click on a link to share content, you remain invisible to the networks. If you click on a link, the obligation to provide information about data collection and processing no longer rests with us, but rather with the operator of the social network.

Data subject rights

If the legal requirements are met, as a data subject you have the following rights under Articles 15 to 22 of the GDPR:

• Right of accessUnder Article 15 of the GDPR, you have the right to access your personal data processed by the Controller. We inform you that in the event of a request for information that is not made in writing, we may require further proof from you that you are the person you claim to be.
• Right to rectificationPursuant to Article 16 of the GDPR, you have the right to request the rectification of inaccurate personal data or the completion of personal data held by us relating to you, by emailing us at privacy@divmotion.com
• Right to erasure ('right to be forgotten')Pursuant to Article 17 GDPR, you have the right to erasure (“right to be forgotten”) of personal data that is unlawfully processed or for which the legal basis has ceased to exist (expired storage period, withdrawn consent, fulfilment of the original purpose for which it was collected, etc.).
• Right to restriction of processingPursuant to Article 18 of the GDPR, you have the right to request the restriction of the processing of your personal data, provided that the accuracy of the data is contested by you or the processing is unlawful but you do not request its erasure, or in the event that we do not need the data but you require it for the establishment, exercise or defence of legal claims, or you have lodged an objection to processing.
• Right to data portabilityUnder Article 20 of the GDPR, you may request to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to transfer it to another controller.
• Withdrawal of consentPursuant to Article 7(3) of the GDPR, you may withdraw your consent to the processing of personal data that you have previously given us at any time. As a consequence, it will not be possible for us in the future to continue processing the data that was based on this ground.
• Right to objectIn cases where the processing is based on a legitimate interest of the company or the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, you have the right to object to the processing within the legal requirements of Article 21 of the GDPR.
• Right to lodge a complaintPursuant to Article 77 of the GDPR, you have the right to lodge a complaint with the competent court or with the Data Protection Supervisor, namely the Data Protection Commission at the following address: 2 Prof. Tsvetan Lazarov Blvd., Sofia, or at the following email address: kzld@cpdp.bg

Data security

Within the website visit we use the widespread SSL (secure socket layer) method in conjunction with the highest level of encryption supported by your browser. In general this is 256-bit encryption. If your browser does not support 256-bit encryption, we fall back on 128-bit v3 technology instead. You can recognise that an individual webpage in our internet presence is being transmitted in encrypted form by the closed key or padlock icon in the bottom status bar of your browser.

We also take suitable technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorised access by third parties. Our security measures are being improved continuously according to technological developments.

Linking

Our website may occasionally link to other sites that we deem relevant to our users. We are not responsible for the accuracy or reliability of the content on third party websites, nor do we necessarily endorse the sites and their content.

Up-to-dateness and amendment of this Privacy Policy

This Privacy Policy is currently valid and was last updated in September 2021.

We may change this Privacy Policy due to improvements in our website or due to amended legal or official requirements. The current Privacy Policy can be retrieved from our website at https://divmotion.com and printed out at any time.