This Privacy and Personal Data Protection Policy (the “Policy”) governs the manner in which QHOME Ltd., UIC 205428843, having its registered office and management address at: 21 Shipka Street, Sofia, Bulgaria (the QHOME Ltd., the “Company”), processes personal data in connection with its business activities.
QHOME Ltd. provides and organizes services related to the valuation of real estate and other assets, including through partners and external valuers.
Given the nature of its business, the processes relating to inquiries, commissioning, approval, conclusion and performance of contracts, exchange of documents and delivery of valuation reports may be carried out entirely electronically.
The Company processes personal data in accordance with Regulation (EU) 2016/679 (the “GDPR”), the Bulgarian Personal Data Protection Act (the “PDPA”), and applicable Bulgarian and European legislation.
QHOME LTD processes personal data only for specific, explicitly defined and legitimate purposes.
For processing activities in respect of which it determines the purposes and means of processing, the Company acts as a data controller within the meaning of Article 4(7) of the GDPR.
Where a particular processing activity is carried out by another party, the roles and responsibilities of the parties shall be determined in accordance with their actual functions and the applicable legislation.
Depending on the particular service and relationship, the Company may process the following data:
The Company does not seek to collect special categories of personal data within the meaning of Article 9 of the GDPR. Where such data are contained in documents provided in connection with a particular service, they shall be processed only to the extent necessary and where an applicable legal basis exists.
The Company may process personal data relating to current and prospective clients and commissioning parties, representatives and authorized persons, owners and co-owners of real estate, holders of rights in rem, heirs, tenants and users, persons whose data are contained in documents provided for the purpose of carrying out a valuation, partners and external valuers, representatives of suppliers and other counterparties, as well as other persons who contact the Company or exercise their rights under the GDPR.
The Company may obtain personal data directly from the relevant individual, from the commissioning party or its representative, from partners and external valuers, from public registers and publicly available sources, from state and municipal authorities, from service providers, from documents and information provided in connection with a particular valuation, as well as automatically through the websites and information systems used by the Company.
Where personal data have not been obtained directly from the data subject, the Company shall provide the information required under Article 14 of the GDPR where applicable.
The Company processes personal data for the following purposes:
QHOME LTD works with partners and external valuers in different locations throughout Bulgaria. For the performance of a particular valuation assignment, the Company may provide the relevant valuer with documents and information containing personal data. Such disclosure shall be limited to the information necessary for the assignment.
The Company takes appropriate measures to ensure the confidentiality and security of the data provided. The role of a particular partner or valuer – whether as a data processor, independent data controller or joint controller – shall be determined in accordance with the actual functions, purposes and means of the processing. Where a partner acts as a processor, the relationship shall be governed in accordance with Article 28 of the GDPR.
The Company may disclose personal data to IT and cloud service providers, email and electronic signature service providers, accountants and auditors, lawyers and other professional consultants, payment and financial institutions, state and municipal authorities, courts and other competent authorities, as well as to other persons where such disclosure is necessary for the performance of a contract, compliance with a legal obligation or protection of a legitimate interest. Disclosure shall be limited to the extent necessary and shall take place where an applicable legal basis exists.
Due to the nature of its business, QHOME LTD may carry out entirely electronically the processes relating to the submission and processing of requests, exchange of documents, conclusion and signing of contracts, assignment of tasks to valuers, communication with clients and partners, and delivery of valuation reports.
The Company implements appropriate technical and organizational measures to protect personal data, including access controls, protection of communications, backups, management of user rights, information security measures and incident response procedures. Access to personal data is granted only to persons who require such access for the performance of their duties.
In the event of an identified or suspected personal data security breach, the Company shall take the necessary measures to limit the consequences, establish the causes and comply with its applicable obligations under the GDPR and the PDPA. Incidents and suspected breaches may be reported to gdpr@qhome.bg.
The Company retains personal data for the period necessary to fulfil the particular purpose, unless a longer period is required or necessary pursuant to a legal, professional or contractual obligation, or for the establishment, exercise or defence of legal claims.
Retention periods for individual categories of data shall be determined in accordance with applicable legislation and QHOME LTD’s internal rules. Upon expiry of the applicable retention period, the data shall be deleted, destroyed or anonymized, unless there is a legal basis for further retention.
Under the GDPR and the Bulgarian Personal Data Protection Act (PDPA), individuals have the right to information, the right of access to their personal data, the right to rectification, the right to erasure, the right to restriction of processing, the right to data portability where the legal requirements are met, and the right to object.
Where processing is based on consent, the individual has the right to withdraw that consent at any time, without affecting the lawfulness of processing carried out before its withdrawal.
In relation to direct marketing, individuals have the right to object at any time to the processing of their personal data for that purpose.
Requests to exercise rights under the GDPR may be submitted to gdpr@qhome.bg. The Company reserves the right to request additional information to verify the identity of the applicant where necessary for the protection of personal data. Requests shall be handled within the time limits provided for under the GDPR.
Every individual has the right to lodge a complaint with the competent supervisory authority if they believe that the processing of their personal data infringes the GDPR or applicable legislation.
The competent supervisory authority in the Republic of Bulgaria is the Commission for Personal Data Protection (CPDP), address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria, email: kzld@cpdp.bg. The current contact details and information on how to lodge a complaint are available on the official website of the CPDP.
Where possible, the Company uses service providers and systems under which personal data are processed within the European Economic Area. Where the transfer of personal data outside the EEA is necessary, the Company shall take the necessary measures in accordance with Chapter V of the GDPR, including the use of an adequacy decision, Standard Contractual Clauses or another legally permitted mechanism.
QHOME LTD does not use automated systems that independently make decisions concerning individuals and that may have legal or other significant effects on them. Where the Company uses such systems, it shall comply with the requirements of applicable law and ensure the rights and safeguards provided for affected individuals.
The website www.qhome.bg and the online systems of QHOME LTD may use cookies and similar technologies. Technically necessary cookies may be used for the functioning and security of the services. Where prior consent is required for the use of cookies, such consent shall be obtained through an appropriate mechanism. Information regarding the cookies used is provided in a separate Cookie Policy.
The Company applies the principle of accountability and maintains the necessary documentation relating to the processing of personal data. When introducing new technologies, systems or processes, it applies the principles of data protection by design and by default.
QHOME LTD may update this Policy in the event of changes in legislation, the practice of competent authorities, the Company’s activities, the technologies used or the manner in which personal data are processed. The current version of the Policy shall be published on the Company’s website at www.qhome.bg.
For all questions relating to the protection of personal data and this Policy, you may contact:
QHOME Ltd.
UIC 205428843
21 Shipka Street, Sofia, Bulgaria
gdpr@qhome.bg