FRISBEE GROUP Ltd., hereinafter referred to as "we" "our" or "us", with UIC 201164111, with registered office and address of management: Stara Zagora, Otets Paisiy Str. 56, ent. A, 5th floor, apt. 28, as a controller of personal data, informs you that this General Data Protection Policy ("General Policy") aims to inform you about:

1.  The categories of personal data that we collect and process:

2.  The sources and ways in which we collect and protect the personal data we process.

3.  The purposes for which we process personal data and the legal basis for their processing.

4.  Collection and processing of personal data relating to children.

5.  In which cases we provide your personal data to others.

6.  For how long we store your personal data and when we will delete it.

7.  Your rights in connection with the processing of your personal data.

8.  Protection of your personal data.

9.  Ways to contact us on issues related to the processing of your personal data.

This privacy policy applies in all cases where we process personal data.

We may periodically update this common privacy policy. In these cases, we will post a notice on our website, as well as an updated version of the policy.

If you have any questions regarding this Common Policy, do not hesitate to contact us in any of the ways described at the end of this document.

For the purposes of this Common Policy:

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

"Sensitive personal data" includes personal data revealing racial or ethnic origin, political views, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the sole purpose of identifying an individual, health data or data on the sexual life or sexual orientation of the individual.

We do not process sensitive personal data unless this is necessary for the fulfillment of our statutory obligations, e.g. our obligations arising from labor or anti-discrimination legislation. Please do not send or otherwise provide us with sensitive personal data relating to you (or anyone else) unless we have explicitly and in writing requested this data from you and after confirming that we have the necessary consents and that all other legal requirements for data processing are met.

"Personal data" are not data that cannot be linked to or associated with a specific individual.

WHAT CATEGORIES OF PERSONAL DATA WE PROCESS

The personal data we process include:

Basic information, such as your name (including prefix), the organization you represent or work for, and the position you hold.

Contact information, such as postal address, e-mail address, telephone number, fax number and Skype Name.

Financial information, such as your credit / debit card number or bank account in connection with a specific transaction or series of related transactions.

Technical information, such as data generated as a result of using our website or an integrated application (application, plugin, etc.), as well as information related to materials and communications that we receive from you or send to you electronically road.

Information relating to business meetings, such as information you provide to us in connection with your participation in business seminars, conferences and other similar commercial events organized by us or any of our related businesses.

Other personal data that you have provided to us or that have been provided to us on your behalf, or that have been generated in connection with the preparation and execution of the order you have placed with us, such as the history of orders or payments.

SOURCES AND METHODS OF COLLECTING PERSONAL DATA

Personal data that you provide to us directly

Some of the personal data we collect and process is provided to us directly by you (eg when you register on or use our website, our platform or contact us by phone or online in order to find work or to obtain information about the goods and services we offer or the status of the execution of your order)

The personal data you provide to us directly includes in particular:

1.  Identification data, such as your name, date of birth, permanent address, delivery or correspondence address, telephone number and address of e-mail, password and username, in cases when you register your own client profile on the website or platform that we support;

2.  In some cases, the personal data you provide to us may include age, gender, interests or membership of a branch organization;

3.  Personal data contained in electronic communications that you have sent us, such as the data contained in an e-mail addressed to us or our employee or sales representative;

4.  Data created by you in the context of the award and execution of orders that you have made with the help of a website operated by us or in another way, such as the history of orders, incl. data on the date of award and / or acceptance of the orders and their status of execution;

5.  Financial information, such as your debit or credit card number or bank account, in connection with the execution of a specific financial transaction or series of similar transactions.

6.  Personal data that you generate or that are related to your customer profile on the website or platform, such as data that you enter when updating your customer profile or information about products that you have added to your cart or Wishlist.

7.  Data you generate when you use a particular social plugin, such as the Facebook "like" or "follow" plugin, to express your attitude toward certain material or content that we've posted on our website, platform, or social media page which we support.

8.  Other data that you have provided to us at our request, when we are obliged or legally entitled to collect this data for the purpose of identifying you or confirming the information we have received.

9.  In certain cases, where permitted by law, we collect data related to convictions and violations. For example, if the law obliges us not to hire people who have been convicted of specific crimes, we will process the data you provide to the extent necessary to fulfill our legal obligation.

Personal data that we collect automatically

Some of the personal data we process is collected by us automatically when you register or use the website and the platform to contact us or place an order. This information is provided by the devices (eg your personal or business computer, smartphone or tablet, etc.) that you use to visit our website and platform or our social media page, such as the device ID or unique identifier associated with with the device or browser you are using, location data, device type, or the browser you are using. We collect information about your interaction with the website, platform and social media pages you use, such as location information and IP address.

We do not carry out automated decision-making, including profiling, due to automated processing of personal data.

Personal data we collect from other sources

In addition to the personal information we collect directly from you or the device you use, we also collect information from other sources. For example, in certain cases, we collect information related to your credit history, as well as other similar information provided by credit bureaus or licensed credit or financial institutions with which you have maintained or maintain financial or business relationships, in cases where the law does not prohibit this.

Personal information provided by third parties includes information contained in your public social media account, which we access when you choose to log in to your client account using your social media account, such as Facebook or G +. Keep in mind that much of the information you post on your social media accounts, such as your public profile, location or location data, language, public posts and comments, is publicly available, resulting in certain responsibilities and privacy risks. in your personal space. You control what data is shared with us through the settings of the site of the respective social network, as well as the consents you provide to us in connection with the processing of your data stored by the sites of social networks.

THE PURPOSES FOR WHICH WE PROCESS PERSONAL DATA AND THE LEGAL GROUNDS FOR THE PROCESSING

We collect, store and otherwise process personal data insofar as this is not against the law and in accordance with our own data protection policies. We process personal data for various business purposes, and this processing is carried out on various legal grounds. According to the law, we must have a legal basis to process your personal data. Depending on the basis on which we process your personal data, you have certain rights. More information on your rights can be found in Section IX. In particular, we process the personal data we collect on the legal grounds set out below for one or some of the following purposes:

We process your personal data in connection with the conclusion and execution of a contract with you

We may collect and process your personal data for the purpose of concluding and executing a contract with you, as well as in cases where, at your request, we take certain steps before concluding a contract. The main purposes for which we process personal data on this basis are:

•  identifying the customer who wishes to order or has ordered products and services offered by us, as well as the persons who wish to become or have already become our suppliers or subcontractors;

•  establishing the legal possibility for concluding a contract, as well as the additional requirements for the validity of the contract, such as the presence of consents from third parties;

•  preparation and communication of proposals for concluding and amending a contract and draft contracts, including distance contracts;

•  providing additional information and explanations about the characteristics and the way of using the products and services we offer.

•  fulfillment of an order of products and services made by the client;

•  preparation of accounts, invoices, credit / debit notices and protocols for our sales or gratuitous deliveries of products and services,

•  tracking of payments made on orders made;

•  contacting customers, suppliers and subcontractors on issues related to the implementation or amendment of a contract for the supply of goods and services

•  providing oral and written technical advice and information, including advice on the optimal and safe use of our products and services;

•  sending messages, newsletters and notifications to withdraw certain products from the market,

•  fulfillment of our obligations under product guarantees issued by us.

•  coordination of the activities for implementation of a concluded contract with a client or subcontractor;

•  performing credit risk assessment, including in cases where deferred payment of contractual obligations is envisaged or is envisaged;

•  consideration and analysis of complaints and signals related to our products and services, as well as taking the necessary measures to eliminate problems arising in the implementation of contracts concluded by us or the use of products and services provided by us;

•  detection and prevention of illegal actions taken by a client, including actions contrary to a valid contract concluded by us;

•  prevent the unauthorized disclosure, use, modification or destruction of confidential information or other information protected by law;

•  ensuring the normal functioning of our e-shops and other similar channels for the sale and distribution of our products and services;

•  registration of client profiles on the websites we maintain and operate;

We process your personal data in order to fulfill regulatory obligations that we have under the laws of the European Union and EU member states.

In particular, we process personal data in fulfillment of our legal obligations arising from the fact that we are both an employer and a buyer and seller of goods and services. In this regard, we process personal data in order to fulfill our specific obligations arising out of or in connection with:

•  the social security of our employees and subcontractors, including the obligations arising from the Social Security Code, the Health Insurance Act and the laws in the field of personal income taxation, as well as their equivalents in other EU member states;

•  the sale (including distance selling) of goods and services to consumers within the meaning of the Consumer Protection Act;

•  identifying customers when necessary to fulfill our obligations under the Anti-Money Laundering Measures Act or the Anti-Terrorist Financing Measures Act;

•  the lawful accounting of the business operations in which we participate, including the taxation of the supplies and services made and received by us;

•  our obligation to assist the competent authorities in the course of their inspections, audits and inspections, as well as in all other cases in which these authorities exercise their supervisory powers on a legal basis;

•  our participation in legal proceedings and related proceedings in our capacity as a party or a third party obligor, such as our obligation to provide data and information relevant to the resolution of a specific litigation;

We may collect and process your personal data with your consent

In certain cases, after we have received your consent for a certain way of processing your personal data, we may use this data:

•  for the purposes of direct marketing of products and services offered by us or by persons related to us, which may be marketed in the form of telephone calls, sending letters or short text messages or emails. For example, if you subscribe to our newsletter or wish to receive promotional offers, we may ask you to provide information such as your name, telephone number, email address, and other relevant information. In case you do not wish to receive more promotional and marketing messages from us, you can notify us at any time or simply follow the "unsubscribe" instructions contained in the communications and messages sent to you. We take steps to limit the marketing content we submit to a reasonable and proportionate volume by sending you only content that we believe may be of interest to you or that may be relevant to you based on the information we have.

•  for the purposes of your participation in various surveys, polls, events and manifestations of a commercial or non-commercial nature, e.g. parties organized by us or any of our related businesses;

•  to fulfill specific obligations to you arising from law or contract, insofar as the processing of relevant personal data (eg health information or other sensitive personal data) is not prohibited by law.

You have the right to withdraw your consent to the processing of your personal data at any time. More information about this right can be found below.

We may process your personal data when we have a legitimate interest in doing so, such as our legitimate interest:

•  continuously and continuously improve and develop our products and services, including their functionalities, design and / or content

•  encourage and monitor the introduction and implementation of improved and / or innovative measures for the safe use of products and services offered by us or our affiliates;

•  to monitor and analyze our performance in the relevant market;

•  to develop the skills of our staff and subcontractors to work with clients from the respective markets;

•  to personalize the products and services we provide in order to increase your overall satisfaction with them and your communication with us;

•  monitor the technical condition of our information systems and resources, including our e-shops and other websites, as well as eliminate any problems related to their proper functioning or their security and integrity;

COLLECTION AND PROCESSING OF PERSONAL DATA RELATING TO CHILDREN

We understand the importance of taking additional measures to protect the personal data of children who use our products and services, including the websites we operate. We do not collect personal data from children under the age of 16 or data relating to children under the age of 16 without parental responsibility.

consent or, if applicable, without the consent of another person who may by law consent to the processing of a child's personal data (eg a child's guardian).

We do not allow children under the age of 16 to create their own customer profiles on the websites we operate or otherwise provide us with their personal information.

If we become aware that we have collected from or processed personal data of a child without the required parental consent, we will take steps to destroy this information without undue delay.

IN WHICH CASES DO WE PROVIDE YOUR DATA TO THIRD PARTIES

To persons processing data on behalf of the Company

We may subcontract the processing of your personal data to third parties who assist us in processing this data. These third parties process your data on our behalf and in accordance with our instructions for all or some of the purposes set out in this policy. We do not allow subcontractors to use your personal data for their own purposes, including direct marketing purposes.

We require all third parties who process your personal data on our behalf to process this data in accordance with the law, as well as to ensure their security, including by taking the necessary technical and organizational measures to protect personal data. The categories of recipients who process personal data on our behalf are:

•  accounting and auditing companies that process personal data for the purposes of accounting and auditing of our financial statements, as well as for the implementation of our regulatory obligations in the field of labor, tax and social security legislation;

•  persons who provide information society services, including hosting services, and / or information and technical services related to the maintenance, security and development of our information and communication infrastructure and resources

•  licensed postal operators and transport or forwarding companies, in cases where we send you products ordered by you licensed payment service providers for the purpose of processing payments from / to you;

•  security companies licensed to carry out private security activities for the purposes of ensuring security and access to the buildings and premises that we own or use legally

•  To public authorities to which we are obliged by law to provide your personal data, such as courts or administrative bodies performing regulatory, supervisory or other similar functions (eg Consumer Protection Commission, Data Protection Commission, Data Protection Commission, protection of competition and other competent authorities which are permitted by law to collect and process personal data);

To protect our legitimate interests

In certain cases, when this is dictated by our legitimate interests, we may disclose your personal information to third parties, such as:

•  our legal advisers and legal representatives in connection with obtaining legal advice or preparing and organizing our defense in a current or potential legal dispute, including for the purpose of our participation in a mediation procedure or other procedure for voluntary dispute resolution.

•  persons who have acquired part or all of our enterprise or activity as a result of our reorganization (eg merger, incorporation, etc.), a transaction concluded by us (eg sale, exchange) or an act of a competent authority;

To persons for whom we have received your explicit consent, such as:

•  companies that can provide you with information or offers for their own products and services.

FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA AND WHEN WILL WE DELETE IT

We store your personal data for the period that is necessary or permitted in view of the purposes for which we process them. Once these objectives have been achieved or after our legitimate interest or legal basis for processing the data has ceased (eg when consent to the processing of certain data is withdrawn), we will delete personal data without undue delay.

The criteria on the basis of which the retention period of your personal data is determined include: (a) the period during which we maintain business relations with you and provide you with our services, (b) the retention periods provided for in the applicable us, and (c) the period for which it is necessary to keep the data in connection with our participation and protection of our rights and legitimate interests in judicial and administrative proceedings and the expiration of the relevant limitation periods.

For example, we will store personal data contained in our accounting records for the timeframes provided for in the Accounting Act.

HOW WE PROTECT YOUR PERSONAL DATA

When processing your personal data, we take the necessary technical and organizational measures to protect this data from unauthorized access, alteration or deletion. These measures include:

•  establishing internal policies for the processing of personal data, which aim to prevent unauthorized access to the systems we use and to the premises where we store your personal data;

•  establishing a confidentiality obligation for our employees, subcontractors and suppliers;

•  entrusting the processing of your personal data only to those organizations that process personal data in accordance with the law, ensuring their security, including by taking the necessary technical and organizational measures to protect personal data.

YOUR RIGHTS REGARDING THE PROCESSING OF YOUR PERSONAL DATA

At any time during the processing of your personal data by us, you have certain rights, as set out below.

You can exercise your rights under this policy and the General Data Protection Regulation by sending an email or letter to our Data Protection Officer, which contains your specific request and, if possible, signed by hand or with a qualified electronic signature. If you are unable to sign your request in one of our preferred ways, we may ask you to provide additional information in order to establish your identity.

We will respond to your request free of charge and without undue delay. In cases where we receive repeated requests from you, we may refuse to take action on the request or set a fee (based on the costs we will incur) to pay for providing the information or communication or taking the requested action, or

RIGHT OF ACCESS AND INFORMATION

You have the right to request and receive:

•  information for the purposes of processing your personal data, what categories of personal data we process and which are the recipients or categories of recipients to whom your personal data are or will be disclosed, as well as any information about the source of your personal data;

•  a copy of your personal data that we process, in electronic or other appropriate form;

RIGHT TO CORRECT AND COMPLETE

If you find that the personal data we process is inaccurate and / or incomplete, you may ask us to correct and / or supplement it.

RIGHT TO OBJECT

When we process your personal data based on our legitimate interest, you have the right to object to such processing. We will terminate such processing without undue delay and delete your data, unless we provide reasonable reasons for continuing to process your data, which reasons outweigh your rights and legitimate interests or the processing of your personal data is necessary to establish, the exercise or defense of legal claims. In addition, you have the right to object at any time to the processing of your personal data for marketing and advertising purposes. We will terminate such processing without undue delay as soon as we receive your objection.

RIGHT TO RESTRICTION ON PROCESSING

You have the right to ask us to restrict the processing of your personal data in the future when:

•  you believe that the personal data we process are inaccurate and require us to correct it, for the time while we check the accuracy of your data and until we make the necessary correction;

•  it has been established that for some reason we are processing your personal data illegally, but you do not want your data deleted, but instead want to process some of your data;

•  we no longer need your personal data, but you require us to keep this data for the purpose of exercising rights or protecting against third party claims;