Privacy Policy

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

The data controller in the sense of the GDPR as well as other applicable privacy laws is:
"Vidual" OOD, UIC 207571092 a limited liability company incorporated under the laws of Republic of Bulgaria, hereinafter referred to as referred Vidual, The Company or We.

Address:
239b Aleksandar Stamboliyski Blvd., floor 7, 1309 Sofia, Bulgaria.

Email:
privacy@seedo.co

2. HOW TO CONTACT US?

If you have any questions and / or requests related to your personal data that the Company processes, you can contact us at: 239b Aleksandar Stamboliyski Blvd., floor 7, 1309 Sofia, Bulgaria.

You can send us an email at:
privacy@seedo.co. Please note that to ensure safety and to abide by applicable privacy laws, we may need to verify your identity and geographic residency before fulfilling your request. We will comply with your request as soon as reasonably practicable within the statutory period for answering your request as per applicable privacy laws.

Vidual respects the privacy of your personal information. The protection of your personal information, as well as the security of all data processed by the Company, is an important issue for us. We process personally identifiable information collected while you use SeeDo® in accordance with applicable privacy laws.

3. SPECIAL NOTICE - IF YOU ARE UNDER 16 YEARS OLD.

SeeDo® is a social network that provides information society services. In line with the GDPR and other applicable laws we aim to offer direct registration and enable accounts for users that are above 16 years old.

SeeDo® is not aimed at children under 16 years old and we will not deliberately collect, use, provide or process in any other form any personal information of children under the age of 16. We therefore also ask you, if you are under 16 years old, please do not provide us with your personal information (for example, your name and email address). We reserve our rights to implement checks and mechanisms to ensure our users are above 16 years old as well as to delete accounts for children who are below this age threshold or another threshold that is applicable per law in a specific case.

4. IN WHAT CAPACITY AND HOW DO WE PROCESS YOUR PERSONAL DATA?

Vidual is a personal data controller as per the GDPR for all users that register and provide their personal information in SeeDo®. We determine what personal data is collected and how it is used making us the responsible entity for ensuring personal data protection.

Vidual declares that we have implemented all technical and organizational measures to protect the personal data of individual users of SeeDo® prescribed by applicable privacy laws.

5. WHAT IS THE NATURE OF THIS PRIVACY POLICY?

This Privacy Policy aims to provide you with comprehensive information in a clear and understandable language about what actions are taken with the personal data you provide to us, including:

• What personal data do we process?
• For what purposes do we process your personal data?
• For how long do we keep the personal data you provide?
• Whom do we share your personal information with?
• What are your rights regarding your personal data and how you can exercise them?
• How do we notify you of a change to our Privacy Policy?

6. WHAT CATEGORIES AND TYPES OF PERSONAL DATA DO WE PROCESS?

Any information and data by which an individual can be identified falls directly or indirectly under the definition of "personal data".

For example, indirect identification is your IP address. Direct identification is achieved when you provide a unique identifier such as passport number, driver's license number etc. Generally, SeeDo® does not process unique direct identifiers (unless the chosen display name or email matches your actual names).

"Special categories of personal data" means for example data revealing racial or ethnic origin, political views, religious or philosophical beliefs or membership of trade unions, as well as the processing of genetic data, biometric data for the sole purpose of identifying an individual, health data or data about the sexual life or sexual orientation of the individual. SeeDo® does not process special categories of personal data unless such are included in the user-generated content that is displayed publicly and is fully under the end user's control.

We collect personal data directly from you, for example when you create an account with us or contact us.

The personal data collected and processed by Vidual may include the following categories and types of data:

7. WHAT ARE OUR LEGAL BASIS FOR PROCESSING OF PERSONAL INFORMATION?

The processing of personal data includes the collection, storage, destruction, transfer, correction, updating, deletion, and all other activities carried out with your personal data.

We process personal data on the grounds of the performance of a contract (our Terms & Conditions) with the user (Article 6, paragraph 1, item "b" of the GDPR). We may also process personal data after obtaining clear, free, and unambiguous consent from you for the purposes of processing expressed through your voluntary registration or provision of optional personal data in SeeDo® (Article 6, paragraph 1, item "a" of the GDPR). The consent you provide can always be withdrawn by contacting us or using the options available in the application.

Some of our processing activities are based on legitimate interest (Article 6, paragraph 1, item "f" of the GDPR), but only after we have carefully assessed that such interests do not concern the fundamental rights and freedoms of the data subject.

Lastly, in a very limited number of cases we process your personal data for compliance with a legal obligation to which Vidual is subject (Article 6, paragraph 1, item "c" of the GDPR).

8. WHY ARE WE PROCESSING YOUR PERSONAL INFORMATION?

The personal data provided by you shall be used for the following purposes, including but not limited to:

• Authentication purposes and ensuring only registered users has access to their respective accounts in SeeDo®.
• Sale, support, development, and analytics of SeeDo®, including utilizing data to personalize user experiences and tailor content to make navigation more intuitive.
• Usage of aggregated data about your use of SeeDo® for the purpose of making all our products and services better.
• Marketing and advertising activities, including sending you marketing messages and for targeted advertisements based on information generated by a user's online activity, provided the legal requirements for digital marketing are met.
• Processing of personal data for compliance with regulatory and other legal requirements, including monitoring for and protecting against fraud, unauthorized transactions, claims, and other liabilities.
• Answering claims and requests sent by our customers/users and providing customer support, including managing support tickets and resolving issues.
• Creating new Products or Services that would meet your needs, based on feedback, surveys, research, and development purposes.
• Enhancing the security of our services, including risk management and quality control.
• Community building and managing social features, where applicable, for managing interactions, posts, comments, and community engagement within SeeDo®.
• Compliance and enforcement of legal obligations, terms and conditions of service, and policies.
• legal claims, including establishing, exercising, or defending against legal claims in court proceedings, administrative or out-of-court procedures.
• Communication and notifications about changes to our services, terms, conditions, and policies, or providing other important communications relevant to the use of our products.
• Affiliate and partner promotions, offering promotions, deals, or information in collaboration with affiliate or partner entities, with transparency and user consent where required.

Your personal data is not subject to automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR.

9. HOW DO WE PROCESS YOUR PERSONAL INFORMATION?

When you use SeeDo®, Vidual processes your personal information in the following ways:

• By completing your account registration.
• By processing information when you use SeeDo®.
• By contacting you if you want support or have other requests.

10. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

Depending on the legal ground on which we process your personal data, the storage period of personal data may be different.

Your personal data is stored as long as we have valid legal grounds for processing it. After this period has expired and in case there is no legal ground to continue storing your personal data, your information shall be fully anonymized or deleted.

11. DO WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?

Vidual respects your privacy and keeps your data secured. Subject to statutory requirements or business needs, Vidual may disclose your personal data to the following categories of recipients:

• Service providers: When we use service providers related to client management systems, technical maintenance and provision of internal IT systems, cloud storage and operational support to our activities, Vidual may disclose personal data to those service providers. Please be informed that such disclosure shall commence only in case there are legitimate grounds for doing so and only based on a written agreement ensuring that the receiver provides adequate levels of protection for the personal data.
• Advertisers, Businessess and Researchers: We may share data with advertisers who show ads on SeeDo®, businesses we hire to market SeeDo® for us, businesses we hire to do things like offer customer service or conduct surveys, researchers who use it to do things like innovate, advance technology, or improve people's safety.
• Advisors: We work with various advisors, including tax consultants, auditors and legal advisors, with whom we may share your Personal Data.
• legal: Information about our users, including Personal Data, will be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Vidual, our users, a third party, or the public.

Please note Vidual does not sell your information, and we never will.

12. DOES VIDUAL TRANSFER PERSONAL INFORMATION TO OTHER COUNTRIES?

In principle, Vidual is based in European Union and stores and processes personal data predominantly in the European Union ("EU").

Vidual may transfer personal information across borders only in case some of our service providers or cloud storage servers are located in a country outside of the EU.

If your personal information is transferred across borders by us or on our behalf, we use appropriate safeguards to protect your personal information in accordance with this Privacy Policy and applicable law. These safeguards include agreeing to standard contractual clauses or model contracts for transfers of personal information with our respective service providers located outside of the EU. When in place, these contracts require our service providers to protect personal information in accordance with applicable privacy laws.

13. WHAT ARE YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA?

Subject to European law (GDPR), you may have the following rights to your personal data processed by Vidual:

1. Right to be Informed regarding how your personal data is being processed covered by this Privacy Policy.
2. Right to access your personal data that Vidual processes and get a copy thereof.
3. In case of incompleteness or inaccuracy in the data that Vidual processes, your personal data will be corrected (right to rectification).
4. Request the erasure of your personal data when the conditions are met. Such cases are if the purpose for which the data is collected is achieved, you have withdrawn your consent when the processing is based on consent and there is no other legal basis for processing, your data is being processed unlawfully processed, and others.
5. In the cases specified by the law, you may require that the processing of your personal data is restricted.
6. In the cases specified by the law, you may object to the processing of your personal data.
7. Exercise your data portability rights and request that your data be provided in a structured, commonly used and machine-readable format.
8. Withdraw your consent when processing your personal data is based on consent.
   You can exercise any of the above rights by submitting a formal request to the following address: 239b Aleksandar Stamboliyski Blvd., floor 7, 1309 Sofia, Bulgaria, or email:
   privacy@seedo.co. To exercise your rights, it is mandatory to establish the identity of the claimant when submitting a request for exercising your rights.

You also have the right to file a complaint with the Bulgarian Commission for Protection of personal Data (https://www.cpdp.bg/en/index.php?p=home&aid=0), or the data protection authority where you live, work or where you think we have violated data protection laws, when the relevant prerequisites are in place.

14. ADDITIONAL INFORMATION FOR USERS WHO ARE RESIDENTS OF THE UNITED STATES OF AMERICA

Throughout this section for Residents of the United States, we use the following terms with the following meanings:

• Consumer (or you) means an individual acting in a personal or household context who uses the Services and, for California residents, individuals acting in a business-to-business context.
• U.S. Privacy Laws means the Colorado Privacy Act; Connecticut's Act Concerning Personal Data Privacy and Online Monitoring; Utah Consumer Privacy Act; Virginia Consumer Data Protection Act; and similar laws enacted from time to time in other U.S. states, each as amended, repealed, consolidated, or replaced from time to time.

CONTROLLER

The controller for the personal information collected in connection with use of our Products in the United States is "Vidual" OOD, UIC 207571092, a limited liability company incorporated under the laws of Republic of Bulgaria with registered address at: 239b Aleksandar Stamboliyski Blvd., floor 7, 1309 Sofia, Bulgaria. "Vidual" OOD is hereinafter referred to in this section as Vidual or We.

RESIDENTS OF CALIFORNIA.

This California Privacy Notice (California Privacy Notice) applies to Vidual's processing of personal information of residents of the U.S. State of California (California Consumers) as required by the California Consumer Privacy Act of 2018, as amended (CCPA). This "Residents of California" section contains our Notice at Collection under CCPA.

If you are a California Consumer, this California Privacy Notice is designed to help you understand the categories of personal information that we collect about you, where we get that personal information, why we process it, who we share it with, and the rights you have to know and control your personal information. If this California Privacy Notice and any provision in the rest of our Privacy Policy conflict, then this California Privacy Notice applies for the processing of personal information of California Consumers. This California Privacy Notice does not apply to Vidual's employees, contractors, contingent workers, job applicants, business partners and resellers residing and operating in the U.S. State of California.

In this "Residents of California" section, Business Purposes means providing our Products to California consumers; advertising and marketing; quality assurance; research and development; and other business purposes as may be defined in CCPA from time to time; and Service Providers means organizations that process personal information on behalf of Vidual and contractors and other organizations with which Vidual shares personal information pursuant to a contract for Business Purposes.

NOTICE AT COLLECTION

For CCPA purposes, Vidual generally acts as a "Business" with respect to your personal information, which means that Vidual determines how and why the personal information that Vidual collects from or about you is handled. (A "Business" is similar to a "controller" which is defined in the preamble to this Privacy Policy.)

This Notice at Collection of personal information describes our personal information collection practices when we are acting as the Business, including a list of the categories of personal information we collect, the purposes for which we collect personal information and the sources from which we collect personal information.

This Notice at Collection covers the twelve (12) months prior to the "Last Updated" date above. This Notice at Collection is updated at least once per year. If this Notice at Collection conflicts with the Privacy Policy, this Notice at Collection will govern as to California Consumers, unless expressly stated otherwise. If Vidual's processing materially changes between updates to this Notice at Collection, Vidual will provide a supplemental notice when or before the changes apply.

Although we already explain what personal information we collect and why above in this Privacy Policy, the CCPA requires that we make certain disclosures using the categories of personal information used in the definition of personal information in the CCPA.

In the preceding 12 months, Vidual has collected the following categories of personal information:

We do not collect precise geolocation information or other personal information that is "sensitive" under California law, Our use of this personal information is to provide you with a Product you have requested and is consistent with the permitted business purposes in California Civil Code § 1798.100 et seq. and implementing regulations. We will collect your consent for any other use.

Vidual does not collect:

• Government Issued Identification Numbers (e.g., social security, driver's license, state identification card or passport number)
• Non-public Education Records as defined in Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99), i.e., education records directly maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, schedules, identification codes, financial information or disciplinary records
• Communication Content (e.g., the contents of a California Consumer's mail, email and text messages, other than when Vidual is the intended recipient of the communication)
• Health Information (personal information collected and analyzed concerning a California Consumer's health, medical history, mental or physical health, diagnosis/condition and medical treatment)
• Sex Life / Sexual Orientation (personal information collected and analyzed concerning a California Consumer's sex life or sexual orientation)

We do not collect, share, process or sale any data of people below the age of 18.

Your California Consumer Privacy Rights

CCPA offers California Consumers the following key privacy rights:

• Right to Access Information: You have the right to request access to personal information collected about you and information regarding the source of that information, the purposes for which we collect it and the third parties and service providers with whom we share it.
• Categories: You may request any of the following for the period that is 12 months prior to the request date: (1) categories of personal information we have collected about you; (2) categories of sources from which we collected your personal information; (3) the business or commercial purposes for our collection, sale, sharing of your personal information; (4) the categories of third parties to whom we have disclosed your personal information; (5) a list of the categories of personal information disclosed for a business purpose, and, for each, the categories of recipients, or that no disclosure has occurred; and (6) a list of the categories of PI we have sold or shared about you, and, for each, the categories of recipients, or that no sale or sharing has occurred.
• Specific Pieces: You may request to confirm if we are processing your personal information and, if we are, to obtain a transportable copy, subject to applicable request limits, of your personal information that we have collected and are maintaining, subject to certain limitations.
• Right to Request Deletion: You have the right to request that we delete certain personal information that we have collected from you.
• Right to Correct: You have the right to correct inaccurate personal information about you. Note that correction requests are subject to certain limitations, and we may choose to delete rather than correct your personal information in some circumstances.
• Right to Opt-Out of Sale of Personal Information to Third Parties: Our disclosure of your personal information to third party advertising and analytics providers may constitute a sale under certain state laws and, in California, may also constitute "sharing" (which is a term used to address the sharing of information for advertising purposes).
• Right to Limit Sensitive Personal Information Processing: Vidual will ask for your consent if we process sensitive personal information for any purpose that is not exempt from consumer choice under the CCPA (e.g., to perform the services/provide the goods that you requested).
• Right Against Discrimination: We will not discriminate against you for exercising your rights under the CCPA. We will not deny you goods or services for exercising your rights; charge you a different price or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, because you exercised your rights; provide you a different level or quality of goods or services because you exercised your rights; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services as a result of exercising your rights.
• Automated Decision Making / Profiling: Vidual does not engage in processing that constitutes automated decision making or profiling under the CCPA. However, if in the future we opt to utilize automated decision making or profiling you have the right to opt-out of certain types of automated decision making or profiling processing.

To submit a request to exercise your California privacy rights, please:

• email us at: privacy@seedo.co

Please note:

• We may (and in some cases are required to) verify your identity before we can act on your request to exercise your California privacy rights. After we receive and process your request, we will contact you using the email address provided in your request with instructions on how to verify your identity, after which we will check our records for matching information.
• We may not honor part or all your request – for example, certain information we collect may be exempt from this California Privacy Notice, such as public information made available by a government entity or information covered by a different privacy law. In these situations, we will explain why we do not honor your request when we respond to you.

Notice of Financial Incentive

We may offer discounts or other benefits to California Consumers enrolled in certain rewards or promotional programs.

Vidual does not generally assign monetary or other value to consumers' personal information and our promotional activity changes continually. To the extent California law requires that a value be assigned to such programs, or the price or service differences they involve, Vidual values the personal information collected and used under each program as being equal to the value of the discounts or other financial incentives provided in each such program, based upon a practical and good-faith effort to assess on an aggregate basis for all collected information: (1) the type of personal information collected in each program (e.g., email address), (2) the use of such information by Vidual in connection with its marketing activities, (3) the range of discounts provided (which can depend on each consumer's purchases under such offers), (4) the number of individuals enrolled in respective programs, and (5) the products for which the benefits (such as price difference) can apply. These values can change over time. Note that this description is without waiver of any proprietary or business confidential information, including trade secrets, and it does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

A different California law permits California residents to request a notice disclosing the categories of Personal Information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. Currently, Vidual does not share Personal Information with third parties for their direct marketing purposes.

RESIDENTS OF OTHER U.S. STATES.

The U.S. Privacy Laws offer Consumers certain rights with respect to their personal information. Vidual will honor these rights for any U.S. resident. They include:

• Right to Access Information: You have the right to access and obtain a copy of your personal information.
• Right to Request Deletion: You have the right to request that we delete personal information provided by or obtained about you.
• Right to Correct: You have the right to correct inaccuracies in your personal information.
• Right to Opt-Out: Our disclosure of your personal information to third party advertising and analytics providers may constitute a sale under certain state laws. In addition, we use cookies to serve targeted ads. You have the right to opt-out of these activities by (a) enabling an opt-out preference signal or Global Privacy Control on your browser which is recognized by our U.S.-facing websites, (b) opting-out of cookies in our U.S.-facing websites' cookie preference center, or (c) for non-cookie personal information, submitting an opt-out request at privacy@seedo.co
  To protect Consumers, if we are unable to verify a privacy rights request, we are unable to honor the request. We will use personal information provided in a verified privacy rights request only to verify identity or agent authority to make the privacy rights request and to track and document responses unless Vidual also received the personal information for another purpose.

Agent Requests

You may use an authorized agent to make a privacy rights request for you. We may require that you directly confirm that you authorized the agent to submit requests on your behalf or request provision of evidence for the authorization. Please note that it may take additional time to verify and fulfill agent-submitted requests. Once confirmed, your authorized agent may exercise privacy rights on your behalf, subject to the requirements of applicable law.

Appeals

You may appeal Vidual's decision regarding a request by email at privacy@seedo.co. Please use the same email address that you used to submit the initial privacy rights request when you submit your Request to Appeal and please add "Request to Appeal" in the subject line of the email. If you do not use the same email address, Vidual cannot link your Request to Appeal to your initial privacy rights request.

Vidual's Responses

Some personal information that we maintain is insufficiently specific for us to be able to associate it with a verified Consumer (e.g., data tied only to a pseudonymous browser ID). We do not include that personal information in response to those requests. If we deny a request, in whole or in part, Vidual will explain the reasons in our response.

Vidual will make commercially reasonable efforts to identify personal information that we process to respond to a privacy rights request. In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest you receive the most recent or a summary of your personal information and give you the opportunity to elect whether you want the rest. We reserve the right to direct you to where you may access and copy responsive personal information yourself. We will typically do not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome. If we determine that the request warrants a fee or that we may refuse it, we will give you notice explaining why we made that decision. You will be provided with a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

Retention of your Personal Information

We retain personal information about a Consumer for as long as the Consumer's account is active and otherwise as long as necessary for the purposes described above. We also retain personal information as long as necessary to comply with legal obligations, resolve disputes and enforce our agreements. When determining the retention period, we consider various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you and mandatory retention periods under applicable law.