Privacy Policy

This Privacy Policy is accepted on 01.03.2024

It governs the relationship between MeUp Ltd., a company registered according to the laws of the Republic of Bulgaria, UIC 207531549 and registered address at Bulgaria, 4600 Velingrad, 4 Slivnitsa Str., hereinafter referred to as “MeUp”, “we”, “us”, “the Platform”, “the Site”, “the Company”, or the “Administrator” on the one hand, and the Users (either Publishers or Advertisers) of Internet pages and services located on the Site https://meup.com/, hereinafter referred to as “User”, “Data subject” or “you” as the case might be.

I.1. During the course of the activity, the Site collects, processes and uses the data of the Users, Advertisers, and Publishers, with personal data included.

I.2. Personal data will be collected in compliance with Regulation 2016/679 of the European Parliament and of the EU 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 repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter: “GDPR”).

I.3. User data may be collected by the Site as a result of the Users’ voluntary provision, among others, during account registration or through cookies.

I.4. Apart from personal data, the following are also collected:

• the User’s IP address;
• type of software used by the User
• and/or information on the source from which the User was redirected to the Site.

I.5. The User will be instructed on how the data will be processed upon his/her personal data provision.

I.6. Data collected by the Site will be used for statistical purposes and administration of the Site.

I.7. All content in the Service is protected by law, including copyright or trademark protection rights, and may not be used in any way without the prior written consent of the Administrator.

I.8. The Administrator reserves the right to introduce alterations to this Privacy Policy in order to keep it up to date. Users will be notified by e-mail about any changes to this Privacy Policy.

II.1. The administrator of your personal data is MeUp Ltd., a company registered according to the laws of the Republic of Bulgaria, UIC 207531549 and registered address at Bulgaria, 4600 Velingrad, 4 Slivnitsa Str.

II.2. The Administrator obtains the personal data of Users, natural persons or natural persons, representing Users who are legal entities, and other persons visiting the Site directly from the data subjects after their explicit consent.

II.3. Personal data is obtained by automated means of the Platform or by other channels of communication used and agreed upon by the Administrator and the User. As part of the operation of the Site, the processing of personal data will include:

• name and surname,
• email address,
• company name (in case of company accounts),
• phone number,
• residence address, UIC (reg. number) or PIC (Personal ID No.) number.

II.4. The processing of the User’s data will be performed for the purpose of:

• the correct placement/execution of the order and providing the services of the Site as per the T&C;
• fulfilment of legal obligations,
• contacting the User to properly execute the Orders;
• processing payments and settlements of the services offered on the Site;
• contacting the User to conduct the complaint procedure;
• direct marketing, after obtaining the User’s consent;
• providing newsletter services, and for statistics and analysis;
• other legitimate interests pursued by the Administrator according to Art. 6, para. C f) of GDPR.

II.3. The newsletter service referred to above shall be activated through a form available on the Site. The User may also consent to receiving commercial information related to the direct marketing of services or goods, i.e. newsletters, addressed to a designated recipient by electronic communication means, in particular by electronic mail using the data obtained by the Service Provider as part of registration or use of the Site, in accordance with the declarations made upon registration.

II.3. If necessary, the User’s personal data may be transferred to entities providing services to the Administrator within the scope of hosting, legal services, accounting, marketing, payment operators, and cooperating entities that need the data in order to carry out a particular order.

III.1. The User has the following rights:

1. the right to confirm the processing of his/her personal data and to access his/her personal data; the right to object to the processing of personal data;
2. the right to request the restriction of the processing of personal data;
3. the right to rectify his/her personal data;
4. the right to erase his/her personal data;
5. the right to receive a copy of his/her personal data;
6. the right to transfer his/her personal data;
7. the right to file a complaint before the supervisory authority.

III.2. The User has the right to obtain a confirmation from the Administrator as to whether the personal data relating to him/her is being processed and, if it is, he/she is entitled to access the data and the following information:

1. the purpose of the processing;
2. information on the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular, the recipients in third countries or international organizations;
3. categories of personal data concerned;
4. information about the right to request the following actions from the Administrator: rectification, erasure, and restriction of the processing of personal data concerning the data subject, as well as the right to object to such processing;
5. if feasible, the intended period of storage of the personal data and, if this is not possible, the criteria for determining that period;
6. information on the right to lodge a complaint with a supervisory authority;
7. information on automated decision-making, including profiling as referred to in Article 22(1) and (4) of GDPR, and relevant information on the rules for decision-making, as well as on the significance and foreseeable consequences of such processing for the data subject – at present the Administrator does not undertake and does not plan to undertake such actions.

III.3. The User has the right to object at any time to the processing of his/her personal data for the purposes of direct marketing carried out by the Administrator, including profiling, to the extent of which the processing is related to such direct marketing.

III.4. The Data Subject has the right to request the Administrator to restrict processing in the following cases:

1. The User questions the correctness of the personal data – for a period that allows the Administrator to check the correctness of the data;
2. the processing is unlawful and the User objects to the deletion of personal data, requesting instead that its use be restricted;
3. the Administrator no longer needs the personal data for processing purposes, but the data is needed by the User to establish, assert or defend a claim;
4. the User has raised an objection under Article 21(1) GDPR to the processing – for as long as it is determined whether the legitimate grounds on the part of the Administrator override the grounds of the data subject’s objection.

III.5. The user has the right to request the Administrator to promptly rectify the inaccurate personal data concerning him or her. Taking into account the purposes of processing, the data subject has the right to request the completion of incomplete personal data, also by submitting an additional statement.

III.6. The User has the right to request the Administrator to delete his/her personal data immediately, and the Administrator is obliged to delete the personal data without undue delay if one of the following circumstances occurs:

1. personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
2. the data subject has withdrawn the consent on which the processing is based and there is no other legal basis for the processing;
3. the data subject objects under Article 21(1) GDPR to the processing and there are no overriding legitimate grounds for the processing, or the data subject objects under Article 21(2) GDPR to the processing;
4. personal data were processed unlawfully;
5. personal data must be deleted in order to comply with legal obligations under European Union law or the law of a Member State to which the Administrator is subject;
6. personal data has been collected in connection with the offering of information society services as referred to in Article 8(1) of GDPR.

III.7. he Administrator reserves the right to refuse to delete personal data if their retention is necessary for the realization of claims or if it is required by applicable law.

III.8. The data subject has the right to receive his/her personal data which he or she has provided to the Administrator, and has the right to transfer such personal data to another Administrator without hindrance from the Administrator, if:

• the processing is based on consent pursuant to Article 6(1)(a) of GDPR or on the contract pursuant to Article 6(1)(b) of GDPR; and
• processing is carried out by automated means.

III.9. The User has the right to request the transfer of his/her personal data to another Administrator, insofar as this is technically possible.

III.10. The User has the right to lodge a complaint to the supervisory authority – Commission for Personal Data Protection, Bulgaria, 1784 Sofia, 2 Tsvetan Lazarov Bvd. More information is available at: https://cpdp.bg/.

III.11. In order to exercise any of the rights referred to above, the User may send a request to the Administrator in writing to Bulgaria, 4600 Velingrad, 4 Slivnitsa Str. or via e-mail to [email protected].

III.12. If the processing of data is based on consent, the User also has the right to withdraw his/her consent to the processing of personal data at any time. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

IV.1. Cookies are used as part of the activities of the Site, and they are stored in end Users’ devices.

IV.2. The use of cookies is understood as storing and accessing them by the Administrator.

IV.3. Cookies are computer data, in particular text files, which are stored on the User’s end devices and are intended for the use of websites. Cookies usually contain the name of the Site they come from, the time of storing them on the terminal equipment, the content (e.g. action identifiers), and a unique number.

IV.4. The Site uses cookies in order to:

• adapt the content of the Site to the User preferences and optimize the use of the Site. In particular, these files allow for the recognition of the User’s device and appropriate display of the Site, adjusting it to his/her needs and preferences;
• compile statistics and analysis relating to the use of the Site.

IV.5. The Site uses two basic types of cookies, i.e.

• “session cookies” (session storage) – i.e. temporary files that are stored on the User’s terminal equipment until the session expires (e.g. by leaving the Site, deleting them by the User, or switching off the software).
• “persistent” (local storage) – i.e. cookies that are stored on the terminal equipment of the User for the time specified in the parameters of cookies or until they are deleted by the User.

IV.6. The use of cookies does not cause any configuration changes in the User’s end device and in the software installed on that device.

IV.7. The default settings of Internet browsers usually allow the storage of cookies on the terminal equipment of Site users. However, these settings can be changed by the User.

IV.8. The User has the possibility to determine the conditions for the use of cookies through the settings of the software (web browser) installed on his/her end device. The change may involve partial or complete restriction of the possibility of storing cookies on the User’s terminal device. Such change may also affect the performance of the Site and the proper execution of some of its functionalities.

IV.9. Detailed information on how the browser’s cookie settings can be changed and deleted can be found on the official Site of the specific browser.

V.1. The User’s personal data will be processed for the period of as the case might be:

1. using the services of the Site;
2. until the consent for processing given by the User is revoked (if the processing is carried out solely on the basis of the consent)
3. for the time of holding the account by the User;
4. Period, required by law.

V.2. In the case of an existing or potential legal dispute between the User and the Administrator, as well as in the case of the existence of a legitimate obligation of the Administrator, the Administrator may continue to store the personal data which are essential for the Administrator to protect and/or exercise their rights or perform their obligations. The processing of personal data for statistical purposes will be carried out for a period of 2 years after its collection.

VI.1. The Administrator may use different tools such as Google Analytics, Google Ads, Google Cloud, Facebook Ads, Facebook Pixel, Hotjar, where the enumeration is not explicit, in order to provide its Services. The tools might be used for analyzing Site statistics and Users behaviour when visiting the SIte, hosting and server services, creation and precise targeting of paid campaigns located on Facebook, Instagram, Messenger, and Audience Network, etc.

VI.2. The Administrator, to the best of its abilities and knowledge, ensures that its third-party service providers have an appropriate level of data protection and are in compliance with the respective EU or other legislation in this regard.

VI.3. In addition, the Administrator may use the services of companies that handle online payments, quick transfers, credit and debit cards. The privacy policies of these entities are made available when using these tools as well as on their respective websites.

VII.1. The Administrator shall not be responsible for the privacy policy of Sites to which the User will be transferred via links on the Site.

VII.2. The Privacy Policy does not apply to services and companies whose contact details are provided on the Site.

VII.3. Any announcements, advertisements, or other similar content placed on the Site by its Users are solely informative and do not constitute an offer within the meaning of the Civil Code and cannot constitute the basis for any claims against the Administrator.

VII.4. The Administrator shall make every effort to protect the privacy of the Users. The Administrator applies all precautions required by law to ensure that all data, including personal data provided by the Users, is protected against loss, destruction, disclosure, access by unauthorized persons, and misuse. Also, due to relevant actions, the Users can contribute to increasing the security of their data, including personal data on the Internet (e.g. by frequent changes of user passwords, by use of combinations of letters and numbers in their passwords).