Confidentiality and personal data protection policy

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Elmaz App
We, from the team, appreciate your privacy and trust. In this privacy and data protection policy ("Policy"), we disclose how we process your personal data, for what purposes, with whom we share it, and what your rights are in terms of your personal data. Please familiarize yourself with this Policy carefully before accessing the website. If you do not agree to any of the terms, you should not visit the website and use in any way the services offered through it, no matter in what form the access made to them.

This privacy and data protection policy is in effect from: 25.05.2018

1. About us

Under "we", "us" or "ours" is meant "SINERA BG" Ltd, a company registered under the legislation of the Republic of Bulgaria, with UIC 103980070, with headquarters and business address in city of Varna 9000, Primorski area, №84 "General Gurko" Str., tel.: 390500, fax: 390500.

For the purposes of data protection law, we are a Personal Data Administrator ("Administrator") in relation to personal data collected and processed through this website with the following URL: (the "Website") .

2. Definitions
„Administrator“ in this document means a legal entity (trader) who defines the purposes and means of processing personal data.
„Personal data” means all data that contains identifying information (such as name, address, telephone, email, etc.).
„Processing of personal data” includes any action to collect, receive, record, organize, collate, update, modify, retrieve and in any other way to legally use and share your personal data.
„Consent of the data subject“ means any freely expressed, specific, informed and unambiguous indication of the will of the data subject by means of a statement or a clear confirmatory action expressing his consent to the processing of personal data relating to him. Before we receive and process your personal data, we require your explicit, informed and freely given consent to do so.
„Data subject” means an individual 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 signs specific to the physical, physiological, genetic, psychical, mental, economic, cultural or social identity of that individual.
„Pseudonymization“ means the processing of personal data in such a way that personal data can no longer be linked to a particular data subject without the use of additional information, provided that it is kept separately and subject to technical and organizational measures in order to ensure that personal data is not related to an identified individual or an individual that might be identified.

3. Validity and action
This Policy determines what happens to your personal data that you provide to us through the Website or in the process of using our Services and Resources.
This Policy constitutes an integral part of our General Terms and Conditions for Use of the Website („General terms”), available here. All definitions given in the General Terms and Conditions are also applicable to this Policy, unless otherwise stated.
The access, consideration and use in any way of the Services and resources on the Website requires confirmation that you are familiar with, understand the purpose and meaning and agree to be bound by this Policy. Before you access the Services of the Website, you should express your explicit consent to collect, receive, record, organize, compare, update, modify, extract and otherwise legally process, use and share your personal information under this Policy. Your consent is a necessary and mandatory condition for using the Services offered on the Website, which may be expressed by clicking on the "I Agree" option when registering on the Website.
If you do not agree with this Policy, you should not use the Services on the Website. Details of the rights of the user and the possibilities for withdrawing his consent or limiting the processing of his or her personal data are given in Section 7 of this Policy.
Access to this Policy is permanently active at the following address: link.
Ние сиWe reserve the right at any time to make amendments to this Policy. The new versions will be published on the Website. If you have provided your email address in the process of using the Services on the Website, you will be notified of such changes at the email address you provided. If you disagree with changes to this Policy, you should notify us in writing about this, then your Account will be deleted.
The Policy posted here is applicable and valid only to users of the Administrator's services available through the Website. This Policy does not apply to other websites, social networks, platforms, or companies that the Administrator does not control but to which they refer, directly or indirectly, the services and resources provided through the Website. You should be informed that all such websites, social networks, platforms or companies have their own personal data protection policies and that we are not responsible for them. You need to know the privacy policy of other websites, social networks, platforms or companies before providing personal data through them.

4. What data do we collect about you?

You have the right to access the Website without providing your personal details and registration. However, full access to the services of the Website requires the provision of personal data, for example, when registering, purchasing a paid service etc.

Personal data provided by you:

The identificational data of Users are collected by filling in an online registration form that is required to create a profile on the Website. The data you provide to us during the registration process is necessary in order to provide our Services to you.

To register on the Website, you are required to be at least 18 years of age and agree to this Privacy Policy, the Terms of Service of the Website, and any other written terms of the Administrator posted on the Website.

Successful registration requires the completion of certain mandatory fields marked as mandatory and the creation of a unique password. When creating an Account you should provide your:
  • First name and family name;
  • e-mail address;
  • country and city of residence;
  • sex;
  • age;
  • birth date;
  • interests (male/female)
Granting the above data is a a mandatory condition for creating a user profile. Also, upon registration, you must agree that part of the information provided by you will be published publicly on the Website in the form of your profile.

In the process of using the Website Services, the User has the ability to provide additional information about himself by filling in optional fields in his User Profile, including, but not limited to: height, weight, body type, eye color, hair color, education, income, social status, professional sphere, marital status, etc.

When sending a request to the Administrator through the contact form available on the Website here, you should provide your:
  • First name and family name;
  • e-mail address.
The filling in of the optional fields for registration and during the use of the Services as well as the provision of the optional information (comments, pictures) are entirely at the discretion of the Users. Any non-binding data you provide to us through the use of the Website or through other communication with us that we have not explicitly requested from you but provided to us will be treated as personal data obtained with explicit consent for processing. Such data will be processed legally by applying the principles of minimization and limitation.

The user is responsible for providing the contact information and other data that are untrue, false or relate to third parties (in all cases where third parties have not given their consent for this) and any unlawful or misuse of personal data and information.
As part of the envisaged data protection measures, we use the pseudonymization method of part of the data. Part of the data you provide to us during the use of the Services on the Website can not in themselves identify you directly but may be related to a certain individual by using additional information provided by you, therefore the same shall be regarded as information relating to a natural person who can be identified.

We do not collect personal data that:
  • reveal racial or ethnic origin;
  • reveal political, religious or philosophical beliefs;
  • reveal a membership in political parties or organizations, associations with religious, philosophical, political or trade union goals;
  • relate to health condition, sexual life or the human genome;
  • are provided by users under the age of 18 without the consent of their parents or legal representatives. The Administrator will delete any information sent by or referring to users known to be under the age of 18 and have not obtained the consent of their parents or legal representatives to use the Website, services and content.
Data we collect automatically:

Every time you visit the Website, we automatically collect the following data:

Information about your device

We collect data related to your device (such as model, version of the operating system and browser and IP address used by you).

Location information

When using the Services of the Website, we may collect and process information about your actual location. We use a variety of location-based tools, including IP address, GPS, Wi-Fi access points and cell towers.

Information we collect when using the Services on the Website

Information on internet pages that refer to the Website, as well as such that the Website refers to, date and time of visit, duration of the visit, speed of loading of the Website, and other data related to your interaction with the Website.

  • The website uses cookies. Cookies are small text files that are saved on your computer or mobile device when you visit a website. They allow the website to store your actions and preferences (such as username, language, font size, and other display settings) for a certain amount of time so you do not have to enter them each time you visit the site or go from one page to another.
  • Using cookies, the web server can save, for example, the preferences and settings of the computer, mobile phone or other device of the user, which data is automatically restored at the next visit. Cookies are used, among other ways, to improve user experience, such as not repeating the entry process on a subsequent visit.
  • We use the following types of cookies:
    • Session cookies – allow the Website to link the user's actions during the browser session. They can be used for various purposes, such as storing user preferences while browsing the Web site. They could also be used for security when the user has access to Internet banking or to facilitate the use of web-based mail. Session cookies expire after the browser session and are not stored in the longer term.
    • Persistent cookies - are stored on the user's device between browser sessions that allow preferences or actions of the User throughout the Website (and in some cases on different sites) to be saved. Permanent cookies can be used for various purposes, including the preferences and choices of users when using a website or targeting an ad.
    • First & Third Party cookies - first party cookies are those placed on the Website that is chosen to be visited by the User. Part of the content on the Website may be a third-party vendor (e.g., a video or an ad). These third parties may also set cookies through the Website. These are cookies from third parties. Suppliers, third parties are responsible for complying with the applicable laws and their own cookie policy.
  • The website uses the Google Analytics for Display services, in particular the remarketing service. This service consists of redirecting ads and announcements to users who have already visited the Website.
  • You can opt out of seeing announcements and ads from Google Analytics for Display ads and announcements and from your exposure to ads from the Google Display Network. To do this, you should visit Ads Preferences Manager ( and install the Analytics Opt-out Browser Add-on (
  • The website uses remarketing for the purposes of online advertising, meaning that users who have not denied access to the Google Display Network in the above ways may be exposed to advertisements and ads from the Google Content Network Website. Third parties such as Google or Facebook may display ads and announcements on the Website on sites in their content network (such as Google Analytics and DoubleClick cookies), which helps optimize ads based on information from previous user visits to the Website.
  • We may allow third parties, such as advertisers or analysts, to collect information using these technologies directly from our website. The data they collect is subject to the applicable third-party privacy policy.
  • Each User has the possibility to accept or refuse the use of cookies by choosing one of the following buttons when initially accessing the Website: I accept cookies.
  • Users always have the option to prevent cookies by changing the options of their browser. To block cookies in a specific browser, learn more here:
  • The user's refusal of cookies may result in a limitation of the functionality or inability to use the Services of the Website.
5. What are the purposes of processing your personal data?

The personal data we collect is necessary for the provision of quality services and to provide you with timely technical and other assistance, if necessary.

The User is required to provide information about himself when he:
  • registers;
  • fills in information about himself in his profile;
  • sends a request to the Administrator via the contact form;
  • buys a paid service to the Administrator via the Website.
We use the personal data you provide for the following purposes:
  • For the normal operation of all services on the Website, including but not limited to: creating a profile on the Website, to purchase paid Administrator services, to personalize your profile to increase the likelihood of matching with other users of the Website according to their search criteria;
  • To optimize your search criteria by improving the matching algorithm on the Website;
  • For sending inquiries to the Administrator via the contact form;
  • In order to enable the contact between Users and to publicly disclose, with your consent, your data in your personal profile;
  • To participate in competitions, surveys, campaigns, and more;
  • To provide you with personalized content, such as more relevant search results;
  • In order to contact you via email so that you can activate your Profile and, with your consent, receive notifications and information about the Website and our products and services (current and future) about the products and services of our associates and partners regarding upcoming events and promotional campaigns, notifications about new messages, notifications of new comments, notifications for additions to the Friends list, birthday notifications, notifications about "Who viewed your profile", "Who has voted for your Profile", etc. If you do not wish to receive such messages from us or other affiliates, you should notify us when registering or alternatively at any time by going to the "Settings" section of your user profile.
  • To provide, maintain, protect and improve our Services, develop new ones, and protect the security of the Website and our users;
  • For other legitimate purposes in connection with the quality performance of all present and future services and resources on the Website.
Upon change in the purposes, we will inform you and ask for your explicit consent to process your personal data in accordance with the new purposes.

6. Who has access to your personal data?

Your personal data will not be transferred to third parties, unless:
  • you give us your explicit, informed and freely given consent;
  • the third parties in question provide us with support under a contract with the purpose of providing our products or services;
  • this is required by law or by virtue of a governmental act of a public body;
  • there is a justified need to protect the rights, property or security of the users of the Website or other defensible public interest;
  • this is necessary in connection with the sale of a business, our company or its assets that are subject to confidentiality.
Our employees and partners have access to your personal data for the purposes of maintaining the Website and Services, but they same are bound by the obligation of confidentiality regarding the data they have access to in connection with the implementation of this activity.

Our employees and partners are duly informed about the importance of their obligation of confidentiality and are responsible for the fulfillment of this obligation.

We may share your personal information with our trading partners (media, marketing agencies, and other business partners who have agreed to comply with this Policy) to enable them to provide you with information about their products and services as well as promotions and offers.

For any other purpose not expressly mentioned in this policy, we will request your explicit consent by identifying our partners as well as the purposes for data transfer and sharing.

You acknowledge and agree that by accessing our Services you give your explicit, informed and freely given consent to the public sharing of part of your personal data provided on registration or in the process of using the Services and the assignment of such data to Your personal ads and public Profile that will be visible to other users of the Website.

By virtue of a court decision or governmental act of a public authority, we may be required to disclose the identity of a User, especially in the case of investigating violations of third party rights or unauthorized acquisition of personal data.

7. Your rights

By virtue of the applicable law, you have the legally recognized right without indemnity, at any time, to object to the processing of your personal data by sending an explicit request or to the following email address: HERE

You also have the right to be informed before your personal data is first provided to third parties for direct marketing purposes or when used on behalf of third parties. You have the right to oppose this transfer or use without having to pay anything.

You have the right to access the personal data we hold about you in a structured, widely used and machine readable format by sending an explicit request or to the following email address: HERE

You have the right to request the transfer of your personal data to another administrator by sending an explicit request or to the following email address: HERE

In the event that some of the information we hold about you is incorrect or inaccurate, you have the right to correct it by modifying the information contained in your account by sending an explicit request or to the following email address: HERE

You have the right to contact us in order to request the complete deletion of your personal data by sending an explicit request or to the following email address: HERE

You also have the right to request а limitation in the processing of your personal data regarding individual actions of its collection, processing and sharing by sending an explicit request or to the following email address: HERE. You have the right to require third parties who have access to your data to be informed about the restrictions, deletion or prohibition of processing your data in order to remove from these third parties all links, copies or replicas of your personal data.

In addition, you have the right to file a complaint with the competent authority in Bulgaria - the Commission for Personal Data Protection (CPDP), address: Sofia 1592, № 2 "Prof. Tzvetan Lazarov" Blvd., or online here.

8. Where we store your personal data and for how long?

Your personal data which we collect is stored on servers located on the territory of the EU.

We store your personal data for the period you are registered as an active user on the Website or until termination of the Services and/or the Website.
In case you wish to delete your Profile on the Website, the personal data stored for you will be deleted upon receipt of a written request for this.
By exceptions, it is permissible by law to further preserve personal data only when it is necessary to exercise the right to freedom of expression and the right to information, to comply with a legal obligation, to carry out a task in the public interest or the performance of official functions assigned to us as an Administrator for reasons of public interest in public health, for the purposes of archiving in a public interest, for the purposes of scientific or historical research, or for statistical purposes, or for the establishment, exercise or protection of legal claims.

9. Technological and organizational security measures of processing. Risks.

Our goal is to guarantee the quality and integrity of the data provided to us by the users of the Website. To that end, the necessary technological and organizational measures have been taken to contribute to the protection, accuracy, timeliness and completeness of the data.
All the information you provide us is stored on secure servers. We apply the appropriate technological and organizational measures necessary to protect your personal data and the appropriate level of protection that ensures the confidentiality and integrity of data and prevents the destruction, loss, unauthorized modification or unauthorized disclosure of personal data.
Regardless of the measures taken to protect your data, you should be aware that data transmission over the Internet or other open network is never completely secure and there is a risk of third parties unauthorized access to your data or for them to use it.

10. Links to other sites

The website may contain links to other sites or apps, including those of our partners. Should you choose any of these links, you should be aware that each of them has its own privacy policy and that we are not responsible for them. Please refer to the privacy policy of other sites before providing personal data through the same.

11. Contact data

For further information or the exercise of your rights, please contact us at:
  • Address: city of Varna 9000, Primorski District, №84, “General Gurko” Str.;
  • phone number: +359 52 390 500 (9:00 to 17:30)
  • email:
  • Contact form: here.
This Policy is in force since 25.05.2018 and is in line with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).