Kitten Adoption Platform Purrs.bg
SCOPE
The purpose of this Privacy Policy is to provide information regarding the processing of personal data of individuals (“Users”), which is carried out through the kitten adoption website: www.purrs.bg/kittens and/or www.purrs.com/kittens (“Website”), part of www.purrs.bg and/or www.purrs.com and the application “Purrs Go”, available on Google Play and Apple App Store (“Application”) - collectively referred to hereinafter as “Platforms”, owned by PURS Foundation (“PURS”, “We”).
We assume that if you use the Platforms, Users have familiarized themselves with the content of this Privacy Policy. We reserve the right to periodically update and modify its content, the current version of which is always available on the Platforms.
DEFINITIONS
In this Privacy Policy, the following terms are used with the following meanings:
| Term | Meaning |
|---|---|
| Website | The kitten adoption website available at the following domain: www.purrs.bg/kittens and/or www.purrs.com/kittens; |
| Application | the application “Purrs Go”, available on Google Play and Apple App Store; |
| Platforms | the Website and the Application; |
| Data Subject | any natural person who is identified or identifiable, directly or indirectly, based on their personal data; |
| User | a data subject using the Website; |
| Personal Data | any information that is or could be related to a specific Data Subject. |
| Administrator | determines the purposes and means of processing personal data of Users of the Platforms, respectively of adopters. |
| Data Processor | PURS Foundation, in the explicitly specified cases. |
| Processing | collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, aligning or combining, restricting, erasing or destroying personal data; |
| Consent | any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes, by a statement or by a clear affirmative action, which signifies agreement to the processing of their personal data in general or only for specific operations; |
| Transfer | the disclosure of data to a third country or international organization outside the EU |
| Applicable Legislation | Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 and applicable Bulgarian legislation in the field of personal data protection, as well as all regulatory acts from which obligations for the storage or processing of personal data arise. |
INFORMATION ABOUT THE PERSONAL DATA ADMINISTRATOR
The personal data administrator is determined based on the processes in connection with which personal data is collected and used.
PURS Foundation
PURS is the administrator of the personal data provided and stored within the processing activities described in Section V, points 1 and 3 - 6 inclusive, as well as in cases where an advertisement is published on the Website by a natural person. The latter is applicable to the extent that We, to facilitate the communication process regarding the adoption of a kitten, have determined the scope and methods for obtaining personal data from Users, through a pre-defined questionnaire, the answers to which will be received from the individual publishing the advertisement. The data of PURS is as follows:
| Name | PURS Foundation |
|---|
| UIC | 206368267 || Headquarters | Sofia, Nadежda district, block 310 | | Address for conducting activities | Sofia, “Solunska” street 31, apt. 4 | | Email | biser@purrs.bg |
Organizations
The administrator of the personal data of Users who have submitted an adoption request is the Organization that published the respective advertisement on the website.
To facilitate the communication process regarding the adoption of a kitten, we provide Organizations the opportunity to configure a questionnaire from predefined options according to their preferences, which will determine what volume of personal information and data from Users they wish to receive for assessing their ability to care for an adopted kitten.
In this regard, each Organization determines the volume of personal data to be received and processed from the respective user through the questionnaire created by them, accompanying each advertisement.
In these cases, PÜRS acts as a personal data processor for the respective Organization, as we can store and technically support this communication.
Information regarding the processing of Users’ personal data is provided by the Organizations and is kept available and publicly accessible in the advertisements published by them on the website.
INFORMATION REGARDING THE SUPERVISORY AUTHORITY
| Commission for Personal Data Protection | |
|---|---|
| Address | Sofia, “Prof. Tsvetan Lazarov” Blvd. No. 2 |
| kzld@cpdp.bg | |
| Website | www.cpdp.bg |
CATEGORIES OF PERSONAL DATA. PURPOSES AND LEGAL BASES FOR PROCESSING
The type and volume of personal data processed are determined by the processes for which we collect and use them.
Account Registration
The content of the website is freely accessible for viewing by anyone.
1. Posting Advertisements by Users
User account registration is voluntary and free, and it is only necessary for posting an advertisement for the adoption of a kitten. Anyone wishing to register must be at least 16 years old.
In this regard, we collect data related to the physical identity of Users, specifically:
- Names;
- Email address;
- Phone number.
Refusal to provide the above personal data may result in the inability to provide certain functionalities of the website, thus fulfilling our contractual obligations regulated by the applicable general terms of the website.
2. Posting Advertisements by Organizations
Account registration by Organizations is voluntary and free, and it is only necessary for posting an advertisement for the adoption of a kitten. For this purpose, we collect from Organizations:
- Name;
- Email address;
- Phone number.
Applying for Advertisements
Users mentioned in point 2 below, in cases where they wish to take advantage of additional functionalities of the website, including the ability to establish immediate follow-up contact (chat) with the authors of published advertisements, can create and access their account on the Platforms for the purpose of tracking and preserving communication with a specific advertisement author through the hyperlinks provided to their email address.
Every User wishing to contact the individuals in point 1 above - authors of published advertisements, must provide their email address, to which they will receive a hyperlink (link) to a questionnaire, the responses to which will be received by the person who published the advertisement. In this regard, the data in point 1.1., as well as the information shared by filling out the questionnaire for assessing the ability to effectively care for the adopted kitten, will also be provided to the advertiser, including information regarding:
- The locality where the adopted kitten will be raised, in order to assess the possibility of transporting the kitten to its foster family.who and assessment for effective access to veterinary care for the adopted kitten in the specified locality;
- Occupation of the adopter, in view of assessing the possibility for effective care for the adopted kitten;
- Size of the household in which the adopted kitten will be raised and the presence of small children in the family: in view of assessing the possibility of the adopter and the foster family to provide effective care for the adopted kitten, as well as the risk of subsequent development of allergies or other problems that create uncertainty about the adopted kitten remaining with its adopters.
- Type of housing in which the adopted kitten will be raised, in view of assessing the possibility for effective care for the adopted kitten and the risks associated with the type of housing;
- Other information relevant for assessing the adopter’s ability to effectively raise the adopted kitten.
The information is provided voluntarily by the User and is intended solely for use by the person who published the ad mentioned in point 1 above, for the purpose of assessing by them the User’s ability to provide the necessary care for the kitten advertised for adoption.
Refusal to provide in whole or in part the above-mentioned personal data may lead to the inability, respectively the risk, that the application will not be fully and positively assessed by the person who published the respective ad.
Purrs Go
The application “Purrs Go” aims to help those publishing ads on the website to access and manage their ads and communication with Users more easily.
The information you enter and/or provide through the Application is available and accessible only by you and by the persons you wish to share it with, while the ads you publish and manage through the Application - with all or selected Users of the Platforms.
The Application uses the content of the website to provide the services and functionalities it offers. The main functionalities for managing ads, communication, and information, including the ability to establish immediate follow-up contact (chat), are also available through the website. If you choose to exchange information through the Application instead of and/or in addition to the website, this is done voluntarily by you.
Providing Feedback
PURRS processes personal data to respond to inquiries, complaints, and requests received through the Platforms.
If the inquiry or request concerns issues related to contractual relations with PURRS, the processing of this personal data is carried out on the basis of the performance of a contract or for taking steps at the request of a potential future user of the services before entering into a contract in accordance with the General Terms of the Platforms.
In other cases, PURRS processes:
- Names;
- Email address;
- The information contained in the content of the message/inquiry,
on the basis of the following legitimate interests:
- Providing clarifications and additional information and responses to questions regarding PURRS products/services, as well as supplementing the information provided through the website;
- Improving the quality of services and facilitating communication with Users by receiving feedback and evaluation about them.
Current Information and News
PURRS processes personal data to send to Users who have subscribed to this service notifications regarding current news related to the website.
In this regard, PURRS processes:
- Email address;
to provide you with current information and news on the basis of explicit consent given by the User to receive this communication. Users can withdraw their consent at any time, which does not affect the lawfulness of processing based on consent before its withdrawal.
Administering the Platforms
Administrative Messages
In connection with the useBy using the Platforms, we can send registered and/or users who have provided an email address notifications, alerts, updates, and messages of a technical and administrative nature.
Users will receive these messages at the email address provided during account registration, respectively during the application for an advertisement published on the website.
3. Cookies and Tools
We use cookies and tools to administer the Platforms, analyze their functionality and usage, as well as to tailor their content to the preferences of Users.
The scope of some of the cookies and tools used includes all visitors to the website, regardless of whether they are registered or not. More information about the specific cookies used on the website is available in the integrated cookie management tool, as well as in the available Cookie Policy.
AGREEMENT UNDER ART. 28 OF REGULATION (EU) 2016/679
In the cases under III, point 1, we may process personal data of Users on behalf of the Organizations that have published an advertisement for the adoption of a kitten on the website and configured specific questions for potential adopters within it, for which application the rules in this section apply.
In these cases, we act as a data processor concerning the respective Organization, as we, through the Platforms, can store and technically support the exchange of this information between Users and Organizations and to the extent that it constitutes personal data within the meaning of Article 4, paragraph 1 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 26, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (GDPR). In this regard, we:
- process the relevant personal data solely for the aforementioned purposes and only for the period necessary to fulfill them while complying with the documented instructions of the Organizations. We immediately inform the respective Organization when we believe that certain of its instructions violate applicable legislation.
- at the choice of the respective Organization upon termination of the relationship, will destroy or return to the Organization all personal data that we store and/or otherwise process on its behalf.
- assist the Organizations and take the appropriate technical and organizational measures for the successful exercise of the rights of data subjects concerning them.
- apply appropriate technical and organizational measures to protect the processed personal data in accordance with Article 32 of the GDPR to prevent unauthorized or unlawful processing and accidental loss, destruction, damage, alteration, or disclosure of the data, including ensuring that any person authorized to process data has undergone appropriate training regarding the protection and handling of personal data and that they have undertaken a confidentiality obligation.
- ensure that we will not transfer data to third parties outside the European Union/European Economic Area without the explicit prior approval of the respective Organization, unless required to do so by EU law or the law of a member state, in which case we will inform the Organizations of this legal requirement before the processing and/or transfer begins, unless the relevant law prohibits such notification for important reasons of public interest.
- may use subcontractors, which we will bind to data protection obligations identical to our own obligations under this section.
- if we learn of a personal data security breach, we will promptly notify the Organizations and provide all necessary information and assistance.
The Organizations are obliged to maintain available and publicly accessible the required in the advertisements published by them.Information in accordance with Articles 13 and 14 of the GDPR.
RETENTION PERIODS
We retain personal data only as long as necessary to achieve the purposes for which such personal data was collected and in accordance with applicable legislation, including but not limited to consumer protection, electronic communications and electronic commerce, tax and accounting legislation. The retention periods for different types of personal data depend on the purpose of their processing, such as:
| Category | Period |
|---|---|
| Account Registration and Job Application | until the account is deactivated. |
| Feedback | for the period necessary to administer and respond to the relevant communication, unless further retention is necessary for the establishment or exercise of legal claims or for the defense against legal claims; |
| Current News | until consent is withdrawn. |
| Platform Administration | in accordance with the Cookie Policy available on the website. |
EXCHANGE OF PERSONAL DATA
At PERS, we guarantee the confidentiality of processed personal data and compliance with all legal provisions regarding their exchange and disclosure. The exchange of personal data may occur only for legitimate reasons and in compliance with all provisions of applicable legislation regarding data exchange. We may disclose personal data to the following parties if this is lawful and/or necessary:
- individuals providing consulting services in various fields such as accounting, legal services, and others.
- central and local authorities and other public bodies for the prevention and detection of crimes, and regulatory authorities that have the power to request information from PERS;
- IT service providers, analytics tools, and cookies. For example, we use the Plausible Analytics tool for website analysis. More information can be found here.
RIGHTS REGARDING PERSONAL DATA
Throughout the period during which PERS, as the administrator, holds or processes personal data, Users have the following rights:
1. Right to Information
To be informed about the collection and use of their personal data, which is also the purpose of this Privacy Policy.
2. Right of Access
To request free information on whether personal data related to them is being processed, including but not limited to information regarding processing parties, categories of data, origin, purpose, legal basis, and retention period.
3. Right to Rectification
To request the rectification of incomplete, inaccurate, irrelevant, or outdated data.
4. Right to Deletion
To request their data to be deleted if:
- they have been processed unlawfully;
- they are no longer necessary for the purposes of their processing;
- consent has been withdrawn, if it served as the basis for processing and there is no other legal basis for processing;
- if, based on their specific situation, the User objects to the processing of their personal data carried out for the purposes of the legitimate interests of PERS and there are no legal grounds for processing that outweigh the interests of processing;
- if the statutory retention period for personal data under applicable legislation has expired;
- if there is an order for the deletion of personal data from a court or competent supervisory authority.
5. Right to Restriction
To request the restriction of personal data if:
- the User contests the accuracy of the personal data - for a period that allows PERS to verify the accuracy of such data;
- the processing is unlawful, but the User does not wish the personal data to be deleted;
- PERS no longer needs the personal data for the purposes of processing, but the User requires them for the establishment, exercise, or defense of legal claims;
- the User has objected to the processing of their personal data for direct marketing purposes;
- during verification.whether the legitimate interests of PÜRS take precedence over the interests of the User.
6. Right to Object
To object on grounds relating to their particular situation to the processing of personal data:
- carried out for the purposes of the legitimate interests of PÜRS.
- against processing for the purposes of direct marketing.
7. Right to Object to Automated Decision-Making, Including Profiling
To object to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
8. Right to Data Portability
To request that we provide them with the personal data we hold in a structured, commonly used, and machine-readable format, provided that such data is processed based on their consent or contract and the processing is carried out automatically.
9. Right to Withdraw Consent for Processing
To withdraw their consent when such consent has been given for the processing of personal data at any time, without incurring any fees, and the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
10. Right to Protection
To seek protection by:
- filing a complaint with the Commission for Personal Data Protection;
- initiating proceedings before the competent court.
REQUESTS
To receive more information regarding the protection of their personal data, Users can contact PÜRS at the following email: privacy@purrs.bg.
To exercise their rights, Users can send a signed request on paper by mail to the address: Sofia, “Solunska” St. 31, Apt. 4 or submit their request electronically, provided that the document is duly electronically signed in accordance with the Electronic Document and Electronic Trust Services Act.
We may contact and/or request additional information if necessary to verify the identity of the requester.