І. Data of the Administrator, Edelvays Invest LTD, with registered office and address of management: 15 Yosif Stoyanov Str., floor 3, app. 3, Varna 9000, Bulgaria, website www.slivnitsa50.com, processes personal data as a personal data controller in accordance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the Personal Data Protection Act. Edelvays Invest LTD defines the purposes for which the data is processed.

ІІ. Categories of Personal Ddata and categories of subjects whose Personal Data are processed by the controller

For the conclusion and performance of the Contract, Edelvays Invest LTD processes Personal Data about at least one of the following persons (each of these persons is hereinafter referred to as "the Person"):

1. Legal representative of the Contractor;
2. An authorized representative of the Contractor;
3. A contact person for the Contractor expressly designated as such in the Contract or by the Contractor;
4. An employee of the Contractor whose duties are related to or necessary for the performance of the Contract.
5. A person securing the performance of the Contract by appropriate legal means (pledge, mortgage, surety, promissory note).
6. Natural persons - Contractors.

In connection with the Contract Edelvays Invest LTD processes the following groups of Personal Data of the Person:

• • Personal Data relating to the Contractor and the Contractor's representatives (legal or contractual representatives - natural persons such as managers, employees, procurators, proxies, etc.) such as: full names of the representatives; position/function of the representative; personal identification number, signature; duration of the representative authority; contact details (business e-mail addresses, business telephone/fax number); information contained in actions and statements made by such persons (e.g. the execution of the Contract, amendments thereto, written instructions, requests, applications, etc.) on behalf of the Contractor to Edelvays Invest LTD, as well as any communications and information relating to actual acts performed by such persons as representatives of the Contractor to Edelvays Invest LTD in connection with the execution of the Contract;
• Full name and identity card details where the Contract is notarised for signature and/or contents;
• • Personal data relating to the Contractor's contact persons - names, position/function in the Contractor's organization (if applicable), contact details (business email addresses, business telephone/fax number, etc.), actions and statements made by such persons on behalf of the Contractor to Edelvays Invest LTD, as well as any communications and information relating to actual actions taken by such persons as representatives of the Contractor to Edelvays Invest LTD in connection with the performance of the Contract.

Failure to provide the minimum necessary data, such as names of natural persons - legal representatives or proxies of a party to the Contract or related contractual relations, or data of contact persons may lead to the impossibility of the proper conclusion or performance of the Contract and is therefore a mandatory prerequisite for the occurrence and subsequent performance of obligations under such contractual relations.

Given the different capacity of the Person in relation to the Contractor and its relationship to the Contract, Edelvays Invest LTD may process different parts of the said Personal Data of the Person for different purposes, depending on the Person’s capacity for the Contractor or the Contract (legal representative, authorized person, contact person).

Edelvays Invest LTD collects some of the above groups of Personal Data personally from the Person or receives them from the Contractor, while others Edelvays Invest LTD collects independently from publicly available records and sources of information.

ІІІ. Purposes of processing

Edelvays Invest LTD processes the Personal Data of the Person in connection with the Contract. The specific purposes for which Personal Data of the Person is processed include:

• Establishing proper representation of the Contractor under the Contract;
• Conclusion and execution of the Contract;
• Maintaining contact with the Contractor regarding the performance of the Contract
• Providing information to notaries in connection with the execution of the Contract by notarized or other qualified form;
• Performance of obligations under applicable tax and accounting laws and regulations;
• • Exercising and protecting the rights and legitimate interests of Edelvays Invest LTD, including through legal proceedings and assisting affected third parties in exercising and protecting their rights and legitimate interests; establishing, exercising or defending legal claims.

ІV. Grounds for processing Personal Data

Edelvays Invest LTD processes a Person's Personal Data on at least one of the following legal grounds:

• The processing is carried out on the basis of the Person's explicit written consent to the processing for specific purposes (Article 6(1)(a) of the Regulation);
• • The processing is necessary for compliance with legal obligations to which Edelvays Invest LTD is subject (Art. 6(1)(c) of the Regulation);
• The processing is necessary for the performance of a contract to which the Person is a party (Art. 6(1)(b) of the Regulation);
• • The processing is necessary for the purposes of the legitimate interests of Edelvays Invest LTD in relation to the Contract, but only where the interests or fundamental rights and freedoms of the Person do not override the interests of Edelvays Invest LTD (Art. 6(1)(e) of the Regulation);
• • The legitimate interests of Edelvays Invest LTD for which the company must process Personal Data of the Individual are mainly:
  • conclusion of a valid and binding Contract;
  • o the realisation of the interests and protection of the rights of Edelvays Invest LTD under the Contract.

V. Storage of Personal Data

Edelvays Invest LTD stores Personal Data about the Person in electronic form and on paper. In addition, Edelvays Invest LTD maintains databases of the Personal Data of the Person in various software applications that it uses for document management, bookkeeping, etc. Only those employees of Edelvays Invest LTD who need such access to achieve the purposes described above or for whom the law so requires shall have access to the Personal Data processed by Edelvays Invest LTD. Specifically, such persons are: a limited number of employees of the Accounting Department, a limited number of employees of the Commercial Department and the Legal Department.

VІ. Period of processing

Edelvays Invest LTD shall keep the Personal Data of the Person for as long as the Contract is in force and/or Edelvays Invest LTD has unsatisfied claims thereunder, as well as for the statutory period specified under the Accountancy Act (Article 12: 10 years) and as long as the Person represents a contact person or is a contact person under the Contract.

VІІ. Providing Personal Data to others

The Personal Data of the Person may be provided to the following categories of recipients of Personal Data:

• Accounting companies, lawyers, notaries in connection with the provision of legal, accounting and tax services, including the protection of the rights and legitimate interests of the company;
• Auditing companies performing independent financial audits in accordance with the requirements of the Independent Financial Audit Act and the Accounting Act;
• Competent state and municipal authorities, where necessary to fulfil a legal obligation;
• Banks and payment service providers (e.g. for the purposes of payments between the parties to the Contract).

Other controllers do not have access to the Personal Data of the Person unless they have this right by law. Edelvays Invest LTD does not provide Personal Data to third countries or international organizations.

VІІІ. Disclosure of Personal Data

Personal Data may be disclosed by Edelvays Invest LTD, provided that this is permitted by law, in connection with a corporate restructuring, sale, transfer of assets, merger, amalgamation or other form of reorganisation, or other change in the corporate or financial structure of Edelvays Invest LTD or its related entities.

Personal Data of the Person may also be disclosed in order to protect the vital interests of the Person, the legitimate interests of Edelvays Invest LTD (unless such interests of Edelvays Invest LTD are to be overridden by the rights and freedoms or interests of the Person as the subject of the Personal Data) or where it is necessary for Edelvays Invest LTD to comply with applicable law or to fulfil its obligations under the law or to respond to requests or questions from competent supervisory authorities.

The Personal Data of the Person may be disclosed upon request by the competent law enforcement authorities (court, prosecutor's office, etc.) for the purposes of pre-trial, judicial and enforcement proceedings, subject to the requirements of the applicable law and the Regulation.

ІХ. Protection of Personal Data

Edelvays Invest LTD provides and maintains appropriate technical and organizational measures to protect Personal Data of the Person against unauthorized access or unlawful use of Personal Data and/or against its accidental loss, alteration, disclosure, access and/or corruption or copying. These measures are intended to ensure the continued protection and privacy of Personal Data. Edelvays Invest LTD reassesses the measures regularly to achieve ongoing security of Personal Data.

Х. Rights of Personal Data Subjects

Under to the Act and the Regulation, the Person has the following rights in relation to the protection of their Personal Data:

• the right of access;
• the right to withdraw consent;
• the right to rectification;
• the right to erasure (right to be forgotten);
• the right to restrict processing;
• the right to data portability;
• the right to object;
• the right to complain to the Data Protection Commission.

The specific content of these rights is set out in paragraph XII. Rights of the Person.

The Person has the right at any time and on grounds relating to his or her particular situation to object to processing of Personal Data concerning him or her.

Exercise of the right referred to in paragraph 2 shall take place in the same form in which consent is given.

Exercise of the rights under paragraphs 1, 3, 4, 5, 6 and 7 shall be by written application of the Person addressed to Edelvays Invest LTD. The application shall contain at least the following information:

1. Name, address and other identifying data of the Person concerned;
2. A description of the request;
3. Preferred form for providing the relevant information - the Person may choose to have the information provided on paper or electronically to the correspondence/email address provided;
4. Signature, date of application and correspondence address.

Where a Person's claims are manifestly unfounded or excessive, in particular because of their repetitiveness, Edelvays Invest LTD may:

• charge a fee, taking into account the administrative costs of providing the information or communication or taking the action requested;
• refuse to act on the request;

ХІ. Contacts

For any questions regarding Edelvays Invest LTD's Privacy Policy, the Person may contact the following e-mail address: office@slivnitsa50.com.

In the event of a material change in the manner in which Edelvays Invest LTD processes a Person's Personal Data, and/or in the types of Personal Data it processes, and/or in any other aspect of the subject matter of the Policy, Edelvays Invest LTD will notify the Person of the relevant change in an appropriate and easily accessible manner.

RIGHTS OF THE PERSON