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  3. “Upravlenie na vhoda” Privacy Policy

“Upravlenie na vhoda” Privacy Policy

Last edited: 13 November 2026

Draft. This document is a draft and is not yet in force. Missing details still have to be added and it needs a legal review.

Contents

  1. Roles under the GDPR
  2. Data controller
  3. What data is processed
  4. Where and for how long
  5. Your rights
  6. Changes to this document

1. Roles under the GDPR

For data about owners and residents, the controller is the organisation that manages the building (the building manager or management company). The platform processes this data on its behalf as a processor.

For the account data of managers, the controller is the platform's publisher.

2. Data controller

The data controller is missing: publisher's legal name, missing: registered address, missing: company number, if applicable. Contact for questions and requests about personal data: missing: public contact email.

missing: Data protection officer — state whether one is appointed and how to reach them.

3. What data is processed

Owners' names and units, optionally phone and email, charges, payments, issue reports and documents. Personal identification numbers (EGN) are not collected.

Cookies: only those needed for the session. No analytics or ads.

4. Where and for how long

Data is planned to be stored in the EU; there is no cloud or production environment yet. missing: Hosting provider and region once the production environment is set up. Financial records are kept as required by the Bulgarian Accountancy Act. missing: Retention for the audit log and other data after legal review.

On a deletion request, an owner's personal data is deleted or anonymised, while financial records remain with an anonymised payer where the law requires it.

5. Your rights

Under the General Data Protection Regulation (GDPR) you have the right of access, rectification, erasure, restriction of processing, data portability and objection, and you may withdraw consent at any time without affecting processing carried out before the withdrawal.

Send requests to missing: public contact email. We reply within one month.

You may lodge a complaint with the Bulgarian Commission for Personal Data Protection (CPDP) or with the supervisory authority in the country where you live.

6. Changes to this document

If we make material changes we will update the last-edited date and, where needed, tell you in the app. missing: Describe how users of each app are notified.

Details still to be confirmed

  • Legal name, registered address and company number of the publisher/controller (or a decision on whether the publisher is an individual — no personal name is published until this is decided).
  • Public email for contact and personal data requests.
  • Whether a data protection officer is appointed.
  • Legal review of the text before publishing.
  • Retention periods (financial records, audit log, accounts).
  • List of sub-processors (hosting, email, payments).
  • Data processing agreement template for managers.
  • Hosting provider and region of the production environment (not set up yet).

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