Privacy Policy

PRIVACY POLICY AND PROTECTION OF PERSONAL DATA AND USE OF COOKIES

I. DETAILS OF PERSONAL DATA ADMINISTRATOR

PROSPERITY INVESTMENTS LTD, registered in the Commercial Register and the Register of Non-Profit Legal Entities at the Registration Agency, EIK 206711901, with headquarters and address of management in the Republic of Bulgaria, city Sofia, p.k. 1421, "Lozenets" district, str. "Zornitsa" No. 1, fl. 1, app. 2, registered with the Financial Supervision Commission (hereinafter for brevity referred to as "PROSPERITY INVESTMENTS" and/or "The Company") is a personal data controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC (below "Regulations") and the Personal Data Protection Act (below "ZZLD").

PROSPERITY INVESTMENTS owns and operates the following website: www.finitet.com in full compliance with the provisions of the Regulation and the LLDP.

As a personal data administrator, the Company controls and determines the purposes and means of personal data processing and is responsible for the storage and use of personal data on paper and electronic media.

Administrator contact details:

Three names: [please fill in]

Tel.: +359888011199

Email address: hello@finitet.com

II. PERSONAL DATA

Personal data according to The regulation represent any information related to an identified natural person or a natural person who can be identified on the basis of the relevant data.

III. GOALS

This Policy aims to inform you about the principles and the way in which PROSPERITY INVESTMENTS processes personal data, in its capacity as an administrator, the type of data they will collect and process, as well as the rights of the persons whose personal data is collected and processed. This Policy is, among other things, adopted and published in fulfilment of the obligations of PROSPERITY INVESTMENTS according to Art. 13 and Art. 14 of The regulation.If you have any questions or need additional information regarding your personal data, rights and privacy, please contact PROSPERITY INVESTMENTS of those specified in Section I contact details above.

IV. PROCESSING PRINCIPLES. LEGAL BASIS

PROSPERITY INVESTMENTS considers that the confidentiality and integrity of your personal information isa priority and undertakes to comply with the legal regulations for the protection of personal data. PROSPERITY INVESTMENTS does not sell personal data collected by the same to third parties, nor process or provide this data to third parties without legal basis for it, according to the Regulation and the PPE. PROSPERITY INVESTMENTS processes and provides personal data to third parties only if there is a proper legal basis for doing so, including express and freely given consent of the subject pursuant to the Regulation and/or on another basis for processing provided for in the Regulation and the GDPR.

IV.1 The activity you performed PROSPERITY INVESTMENTS is implemented in the field of credit, insurance and financial consulting for individuals, as well as mediation between individuals - clients of the Company and credit, financial and/or insurance institutions, including brokers/agents in this field. In connection with the above PROSPERITY INVESTMENTS processes and protects the personal data collected during the performance of its activity legally and expediently, according to the purposes for which the data is collected and/or collected.

IV.2 Types of personal data collected and processed

Regarding data collected and processed through the above-mentioned electronic site ofPROSPERITY INVESTMENTS

1. on the electronic site
2. by sending an electronic message to the contact email address specified on the webpage
3. by phone call

PROSPERITY INVESTMENTS collects and processes the following personal data of users:

names, email address, voice data of the customer/user who contacted the Company (in case the conversation is recorded), the information (inquiry, request or other), which the user himself provided in the link to text field PROSPERITY INVESTMENTS.

Regarding collected and processed customer data of PROSPERITY INVESTMENTS

PROSPERITY INVESTMENTS collects and processes the following personal data of customers:

• three names, gender, date of birth/TIN, data on the customer's identity card, phone number, email address;
• health data to the customer, when the customer wishes to conclude through us life insurance, medical insurance or other insurances requiring prior information about health status, provided with the express consent of the customer, or when the Company assists in making claims to insurers in the event of insured events related to health impairments.
• data on property status (if necessary for the insurance of the client's movable and/or immovable property), including for services in the fields of life insurance and in fulfilment of the Company's obligations under the Anti-Money Laundering Measures Act, in the process of performing a complex check of the client, we collect data from an identity card and a photo (from a copy of the civil law),data on related persons holding a senior government position, citizenship, country of permanent residence, professional activity, ultimate owners of a client legal entity; origin of funds;
• financial information - details of bank accounts, origin of funds
• any other information that a customer voluntarily provides to us

PROSPERITY INVESTMENTS collects and processes the following personal data of minors and/or minors of personal data subjects, with the express consent of a parent/guardian, in case the latter wishes to takeout the relevant insurance of the minor/minor: three names, date of birth / social security number, address, sex, and for the purposes of the same, the same volume of personal data of the parent/guardian of the minor is collected

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Regarding collected and processed data of counterparties, contractors, subcontractors and other contractual partners PROSPERITY INVESTMENT:

PROSPERITY INVESTMENTS collects and processes for the purposes and needs of carrying out its activity the following personal data from its counterparties, if they are natural persons: three names, date of birth/TIN, address, phone number, email address

Regarding collected and processed data of its employees and/or applicants for a job position PROSPERITY INVESTMENTS: 

PROSPERITY INVESTMENTS collects and processes for the purposes and needs of carrying out its activity the following personal data from its employees: three names, address, TIN/LNC, bank account details, information related to the person's professional and/or work experience, as well as any other information about his professional and/or work experience.

PROSPERITY INVESTMENTS may collect information about its customers, employees and/or contractors from publicly available public registers, which information may constitute personal data for the subject.

IV.3 By accepting this Policy and/or the General Terms and Conditions on the web page of PROSPERITY INVESTMENTS users of the electronic site, including all customers, employees, contractual partners of the latter (regardless of the method by which they contacted PROSPERITY INVESTMENTS and provided their personal data to PROSPERITY INVESTMENTS) consent to the provision of data, which/which way/s constitutes a binding contractual clause between the users of the electronic site/all other persons and/or group/s of persons mentioned above and PROSPERITY INVESTMENTS.

The processing of the above personal data is in fulfilment of the objectives of the corporate, economic, administrative and other operating processes in PROSPERITY INVESTMENTS, including, but not limited to, the services that the latter provides, such as credit and any type of financial consultation, mediation between the client and an insurance company/broker, as well as credit, financial, banking institutions and others, between PROSPERITY INVESTMENTS and the users of the electronic site, customers, employees and contractual partners.

When providing data to third parties, the same is done again in consideration of the above-mentioned purposes, and the legal basis for processing personal data according to the purposes, subjects and methods is based on Art. 6, item 1, letter "b" of The regulation.

The provision of personal data is necessary and mandatory for the provision of the Company's services to the end customer and is a contractual requirement, without which the services could not be provided or an insurance offer could be prepared, after which a policy should be signed by the customer, as well as the corresponding consultations in the financial and credit spheres should be received from a customer of PROSPERITY INVESTMENTS.

IV.4 It may be required by law, in a judicial / arbitration / enforcement / collateral process and/or at the request of a competent authority PROSPERITY INVESTMENTS to disclose personal data to third parties, as well as if this is necessary for the purposes of national security, law enforcement or other cases provided for by law.

IV.5 Personal data may also be disclosed if this disclosure is reasonably necessary to protect the legitimate interests of PROSPERITY INVESTMENTS. Legitimate interests of the Company are compliance with all regulatory requirements of PROSPERITY INVESTMENTS, including to carry out their activities in accordance with the applicable legislation, professional norms and rules, to respond to all requests of local or foreign regulatory, state or judicial authorities;

IV.6 PROSPERITY INVESTMENTS processes personal data in strict compliance with the principle of maintaining a minimum of processed personal data necessary for specific, justified and legitimate purposes (need-to-know principle).

IV.7 PROSPERITY INVESTMENTS processes personal data mainly for: (1) fulfilment of the goals of the corporate, economic, administrative and other operating processes c PROSPERITY INVESTMENTS; (2) the needs of the Company to be familiar with its client in order to be able to provide financial and/or credit counselling at the highest level, satisfying the wishes of its clients; (3) mediates between its clients and other insurance and/or credit brokers, being responsible for communication between the parties, in connection with selecting the best conditions for the client.

IV.8 PROSPERITY INVESTMENTS stores personal data for the period for which they are necessary to fulfill the purposes for which they were collected, including to comply with regulatory requirements, the tax system, labor law, insurance law, accounting standards.

V. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA

PROSPERITY INVESTMENTS collects and processes the personal data that is necessary to carry out its activities and fulfill its contractual obligations with partners, including, but not limited to, customers. In view of this PROSPERITY INVESTMENTS processes personal data for the following purposes:

1. user/customer registration on the website of PROSPERITY INVESTMENTS, including when contacting the user through the form for this on the electronic site maintained and managed by PROSPERITY INVESTMENTS and/or directly by email to the latter's email address and/or by phone call;
2. preparing responses and taking action on inquiries, claims, appeals, applications, etc. from website users / customers and/or potential/current contractual partners/counterparts.

With the consent of the user/customer, or where permitted by law, The company may use the personal data of the latter, namely e-mail address and names, for marketing purposes, including contacting the user/customer in order to provide information, news and offers in connection with the activity of PROSPERITY INVESTMENTS, including, but not limited to: providing messages in connection with obtaining customer discounts on services offered by PROSPERITY INVESTMENTS, as well as providing information to the client regarding discounts of partners and/or subcontractors The company. In addition to the indicated information, it is possible to send greetings for official and/or personal holidays to its customers in various mobile applications, to the e-mail address specified by the customer and/or to his phone number.

VI. CATEGORIES OF PERSONAL DATA PROCESSED

PROSPERITY INVESTMENTS collects the following categories of personal data from the relevant four groups of individuals detailed above in Section IV:

• names, email address of users/clients of the electronic site on PROSPERITY INVESTMENTS and/or by direct electronic message to the latter's e-mail address, upon request, inquiry and/or submission of information regarding the activity of PROSPERITY INVESTMENTS, including complaints, complaints and any kind of reviews related to the activity of PROSPERITY INVESTMENTS through the contact form on the electronic site and/or through an e-mail message; in the case of an established connection with PROSPERITY INVESTMENTS on the telephone it is possible to collect voice data if the conversation is recorded;
• three names, gender, date of birth/TIN, data on the customer's identity card, telephone number, email address, data on the customer's state of health, which may constitute sensitive personal data (if required for health insurance policy), property status data (if necessary to insure the client's movable and/or immovable property) and financial/banking information (if necessary for credit purposes) to customers;
• three names, date of birth / social security number, address, gender, and for the same purposes, the same volume of personal data of the parent/guardian of the minor/minor is collected, with the express consent of the person's parent or guardian;
• three names, date of birth/TIN, address, phone number, email address of the counterparty, contractual partner, contractor and/or subcontractor.
• Social security number/ID, bank account details, information related to the person's professional and/or work experience, as well as any other information about the professional and/or work experience of its employees and/or applicants for a job position in the Company.

When user/s and/or customer/s of the electronic page send inquiries to PROSPERITY INVESTMENTS bye-mail and/or by telephone call, it is assumed that the user/s and/or client/s have given their free, express and informed consent to the processing of the personal data voluntarily included by them in their inquiries to PROSPERITY INVESTMENTS, with the continuation of the telephone conversation and/or by including the information in the relevant electronic message.

When user/s and/or customer/s of the electronic page send inquiries to PROSPERITY INVESTMENTS through the contact form on the electronic page of the latter, he should freely indicate his agreement and acceptance of this policy, after having familiarized himself with the same, on the functional opportunity provided for this by ticking a checkbox.

VII. COOKIES

Cookies are small files of information that are sent by the web server and saved in the user's Internet browser (e.g. data on the language used, connection time, visited Internet pages) or in the hard disk, and are then returned from the Internet browser to the server each time that server is accessed when visiting the corresponding Internet site.

The website of PROSPERITY INVESTMENTS uses cookies to distinguish users from each other, provide users with better services and improve its site. The acceptance of this Policy in the part about cookies is done by the user clicking on the pop-up message on the site of PROSPERITY INVESTMENTS, as well as when the user continues to use the site of PROSPERITY INVESTMENTS. In the event that a user does not agree with this Policy, he/she is obliged to immediately stop using the site of PROSPERITY INVESTMENTS.

The website of PROSPERITY INVESTMENTS can use both cookies on PROSPERITY INVESTMENTS (First Party Cookies) and those of third parties for advertising purposes (Third Party Cookies). The website of PROSPERITY INVESTMENTS may at any given time use the following types of cookies on PROSPERITY INVESTMENTS (First Party Cookies) for the following purposes:

• Strictly Necessary Cookies
  Cookies fall into this category when they are absolutely necessary for the operation of the site, and through them support functions such as login and/or submitting orders/inquiries, etc.
• Analytics and Targeting Cookies
  For PROSPERITY INVESTMENTS it is important to understand how our site is used, such as how efficiently it is navigated and which of its features are used. Analytical and targeting cookies allow to PROSPERITY INVESTMENTS to collect information that helps improve the site and user satisfaction with it.
• Functionality Cookies
  Functional cookies enable PROSPERITY INVESTMENTS to provide additional features to your site, such as customization and remembering saved settings.

All of the above cookies can be persistent (remain on the computer or device for a certain period and are activated each time the site is visited) or session (those that are deleted immediately after closing the browser). Cookies on the site of PROSPERITY INVESTMENTS expire and are automatically deleted after [please specify a period].

By entering the site of PROSPERITY INVESTMENTS and before cookies are used on the user's computer or device, a pop-up message appears in the user's browser, through which the use of cookies can be allowed or denied. Allowing cookies allows the PROSPERITY INVESTMENTS to provide the best quality services through its site and improve user satisfaction. If the use of cookies is refused, certain functionalities of the site of PROSPERITY INVESTMENTS may become unavailable or unavailable.

Each user can set his Internet browser so that it does not store cookies, and can delete already stored one sat any time. Any user who wishes to take advantage of these functions should make the appropriate settings on his browser and/or contact the manufacturer of the Internet browser for assistance.

PROSPERITY INVESTMENTS is not responsible if the Internet browser used by the user does not have functions to control the use, refuse to store or delete already stored cookies. In the event that the user prohibits the storage of cookies or deletes already stored ones, then it is technically possible to disrupt the normal functioning of the website for the respective user.

VIII. SAFETY MEASURES

PROSPERITY INVESTMENTS takes sufficient technical and organisational measures to protect the personal data it processes against theft, misuse, unauthorised access, unauthorised disclosure, unauthorised destruction or any other unlawful processing or disposal of such data.

All representatives and employees of PROSPERITY INVESTMENTS, as well as all co-conspirators of PROSPERITY INVESTMENTS, are obliged to observe confidentiality and strictly apply the legislation in the field of personal data protection, according to the Regulation and the Personal Data Protection Act.

For cases in which PROSPERITY INVESTMENTS provides personal data to third parties, PROSPERITY INVESTMENTS implements mechanisms, including contractual ones, to ensure that this data is processed and protected in accordance with applicable legislation.

IX. STORAGE PERIOD

PROSPERITY INVESTMENTS observes the principle of data storage only for the period for which their storage is necessary and mandatory to fulfil the purpose for which they were collected, unless the law provides for storage for a longer period.

After expiry of the statutory periods for keeping documentation, in accordance with and in view of the applicable accounting, financial and tax legislation in the Republic of Bulgaria PROSPERITY INVESTMENTS deletes and deletes personal data related to:

• with inquiries made, questions asked, requests submitted, complaints and others through the contact form on the electronic site and/or by email
• in the performance of its administrative and operational activities;
• before/during and after a service provided, a consultation in the field of finance and/or regarding credit and/or advice regarding the same;
• with the implementation of mediation activities between a client and an insurance company/broker and/or others.

PROSPERITY INVESTMENTS deletes and deletes the personal data related to personnel selection/candidacy in the Company after a period of 6 /six/ months, if the person is not appointed in PROSPERITY INVESTMENTS or no bond and/or other contractual relationship has been established between the two parties for a period of 6 /six/ months. In the event that the applicant is approved and an employment relationship arises between him and the Company, PROSPERITY INVESTMENTS deletes and deletes the personal data immediately upon request and/or after the expiry of the statutory periods for keeping documentation, in accordance with and in view of the applicable accounting, financial and tax legislation in the Republic of Bulgaria.

X. RIGHTS RELATED TO PERSONAL DATA

Agreed The regulation And ЗЗЛД Data subjects have the following rights at all times:

1. right of access to their personal data processed by PROSPERITY INVESTMENTS;
2. right to request correction of inaccurate data, deletion (if there is a legal basis for this), limitation or blocking (if there is a legal basis for this) of the processing of their personal data processed by PROSPERITY INVESTMENTS;
3. right to data portability if the conditions for this are met according to the Regulation;
4. the right to object at any time to the processing of their personal data, when there are legal grounds for this;
5. the right to appeal to the Commission for the Protection of Personal Data (PCPD) if they believe that their rights in relation to the protection of their personal data have been violated.

PROSPERITY INVESTMENTS may refuse to fulfill requests for the exercise of rights, when there is areas on for this provided for in the Regulation and the LLDP, incl. when the requests are unreasonably repeated, require excessive effort and/or costs for the administrator, when they are clearly unfounded, and when they threaten or violate the privacy and rights of other users.

XI. ORDER FOR EXERCISE OF PERSONAL DATA SUBJECTS' RIGHTS

XI.1. Personal data subjects can exercise the rights under the Policy by submitting a request to exercise the relevant right.

XI.2. A request to exercise the rights of the subjects of personal data can be submitted in the following way:

• electronically to the following email address: hello@finitet.com.
• - on site at the administrative office of PROSPERITY INVESTMENTS;
• by mail - to the address of PROSPERITY INVESTMENTS – , town Sofia, p.k. 1421, Lozenets district, st. "Zornitsa" No. 1, fl. 1, app. 2.

XI.3. The request for exercising rights related to the protection of personal data should contain the following information:

• Identification of the person - name and social security number;
• Contacts for feedback – address, telephone, e-mail;
• Request – description of the request.

XI.4. PROSPERITY INVESTMENTS provides information on the actions taken in connection with a request to exercise the rights of subjects within one month of receiving the request.

XI.5. If necessary, this term can be extended by another two months, taking into account the complexity and number of requests from a certain person. PROSPERITY INVESTMENTS inform the person of any such extension within one month of receiving the request, indicating the reasons for the delay.

XI.6. PROSPERITY INVESTMENTS is not obliged to respond to a request in the event that it is unable to identify the data subject.

XI.7. PROSPERITY INVESTMENTS may request the provision of additional information necessary to confirm the identity of the data subject where there are reasonable concerns regarding the identity of the natural person making the request.

Where a request is made by electronic means, the information shall be provided by electronic means whenever possible, unless the data subject has requested otherwise.

XII. EFFECTIVENESS AND UPDATE

This Policy was adopted by Decision of the General Assembly of the Company and enters into force on__.__.2022

PROSPERITY INVESTMENTS may amend and update this Policy, any amendment/update being posted on the official and above-mentioned website of PROSPERITY INVESTMENTS, as at its discretion PROSPERITY INVESTMENTS may also take other actions to notify users/customers/employees of the amended or updated Policy