Privacy Policy

INTRODUCTION

AppGreat Ltd. is committed to protecting your privacy. This privacy policy explains how AppGreat Ltd. referred below as(“AppGreat Ltd.”, “we”, “us” or “our”) use your personal data (or personally identifiable information) when you visit our website (www.appgr8.com).It also advises you of your rights as a data subject and how those rights may be exercised. We will ensure that any information that we collect or that you submit to us through the website will be used only for the purposes set out in this policy.

Our website is not intended for children, and we do not knowingly collect data relating to children.

We keep our privacy practices under review and may amend this policy from time to time. This version is dated March 2022.

ABOUT US

AppGreat Ltd. provides data, technology and media services for technology , software and betting industries. This privacy policy is issued on behalf of AppGreat Ltd. When we mention “AppGreat Ltd”, “we”, “us” or “our” in this policy, we are referring to the company in the AppGreat Ltd. that is relevant for processing your personal data.

AppGreat Ltd. is the data controller responsible for this website and for processing personal data collected via the website. It is a company registered with VAT BG205794997 with a main seat at Sofia, Bulgaria ,Okolovrasten road 251. We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy, including any requests to exercise your legal rights, then please contact the DPO using the contact details given at the end of this policy.

PERSONAL DATA WE COLLECT

Broadly speaking, your personal data is any information about you from which you may be directly or indirectly identified. The personal data we collect about you via our website will depend on the nature of your interaction(s) with us. However, we will only collect personal data that is reasonably necessary to fulfill the purpose for which it’s being collected (for example, to respond to your enquiry or to allow you to apply for a job with us). 

If you are …	We might collect …
A subscriber to our marketing list	·   Contact details, including full name, company name, email address and telephone number.·   Information that enables us to provide you with relevant content. This might include your job title, business region and marketing preferences.
An enquirer via our “contact us” form	·   Contact details, including full name, company name, email address, telephone number and location.·   Details of enquiry.
A job applicant	·   Contact details, including full name, gender, email address and telephone number.·   Professional background information, including CV/resume, cover letter and employment history.·   Details related to the role on offer, including salary expectations, availability to start/notice period, distance from work location, authority to work and visa/sponsorship requirements.

There are certain types of personal data (referred to as “special category data”) that are afforded a higher level of protection under applicable data protection law because they are more sensitive. Special category data include personal data relating to a person’s racial or ethnic origin, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sex life or sexual orientation. We do not request any special category data via our website.

COOKIES AND AUTOMATED TECHNOLOGIES

Our website uses cookies to distinguish you from other users.

You may set your browser to refuse all or some browser cookies, or to alert you when websites access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. We use cookies on our website to give you the most relevant experience by remembering your preferences and repeat visits. By clicking “Accept All”, you consent to the use of ALL the cookies. However, you may visit “Cookie Settings” to provide a controlled consent.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect your personal data in the following ways:

Directly from you

We may collect personal data from you via our website where you choose to provide it to us in the following scenarios:

• where you make a general request or enquiry using the “contact us” form on our website
• where you use the “request a demo” feature on our website to request a demonstration of one of our products or services
• where you subscribe to our marketing list
• where you subscribe for tailored email alerts on the Investor Relations section of our website
• where you request a copy of our e-book for digital publishers
• where you apply for a role via our website

Automated technologies

• As you interact with our website, we automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. 

Publicly available sources

After you have submitted personal data to us via our website, we may sometimes use publicly available sources in order to obtain further information about you. For example, if you subscribe to receive marketing from us, then we may review your profile on LinkedIn in order to understand your business area better so that we can ensure we send you content that is relevant to you. If you apply for a job with us, then we may use LinkedIn to obtain further detail on your professional background and experience.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data where this is permitted by law. We have set out below an explanation of the way in which we use your personal data and which of the lawful bases we rely on to do so.

Purposes for using personal data	Personal data processed	Lawful basis for processing
To provide you with marketing, including AppGreat Ltd. updates, news and product information	Contact details and marketing preferences	Consent (you may withdraw your consent at any time by using the unsubscribe link provided on the page of our website where you subscribed, by following the instructions for unsubscribing in our marketing emails or by contacting us using the details in the “Contact and DPO” section below)
To send you a copy of our e-book on digital publishing upon request	Contact details	Necessary for our legitimate interests (to provide you with the requested product so that we may develop and grow our business)
To respond to an enquiry made by you	Contact details and details of enquiry	Necessary for our legitimate interests (to answer your enquiry so that we may develop and grow our business)
To monitor link tracking in our marketing communications in order to help us provide more engaging and relevant content	Statistics on link clicks including email open rate and clicks in our email communications	Necessary for our legitimate interests (to enable us to monitor and improve the quality and relevance of our marketing communications)
To apply for a job with us	Contact details, gender, LinkedIn profile, professional/educational background information and details related to the role on offer (including salary expectations, motivation for the role, authorisation to work, distance from work and availability to work).	Necessary for our legitimate interests (to enable us to hire the people we need to develop and grow our business) – for further detail on how we process applicant personal data.
If you apply for a job with us, you may voluntarily submit personal data for the purposes of our monitoring of our equality and diversity composition	Gender, race, ethnic origin	Consent (you may withdraw your consent at any time by contacting us using the details in the “Contact and DPO” section below)

We will only use your personal data for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will contact you and explain the legal basis which allows us to do so.

HOW WE SHARE YOUR PERSONAL INFORMATION

We will not sell your personal data to other parties. However, we may share your personal data with the following third parties either because they process personal data on our behalf or because we are required to do so by law:

• Organizations that provide services to us. We work with a number of trusted third parties to provide our website and associated services. In particular:
  • Our Talent Acquisition Team uses a number of third party suppliers to deliver our recruitment platform and associated services .
  • Our professional advisers. We share personal data with our professional advisers only where it is required in order for them to provide their advice.
• Potential buyers. In the event of a prospective sale of all parts of our business, we may provide access to personal data to a potential buyer, provided that we inform the buyer that your personal data may only be used for the purposes outlined in this privacy policy.
• Governments or our regulators. We may share personal data with governmental bodies or regulators where required to do so by law.
• Police, law enforcement and security services: We may share personal data with enforcement bodies to help them with any investigation, prevention of crime or matter of national security.

In each case, we will only share your personal data where it is necessary to do so. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

DATA SECURITY

We respect your personal data and have put in place appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way or altered or disclosed. In addition, we restrict access to your personal data to those employees, agents and contractors who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

RETENTION OF YOUR INFORMATION

We will retain your personal information only for the time necessary to fulfill the purposes for which it was collected or as required by any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation in respect of our relationship with you.

We will store the following categories of your personal information for the time periods indicated:

Category of personal data	Storage time period
Contact details and email history for enquiries	Two years after last contact
Contact details and preferences for marketing purposes	Until you unsubscribe
Job applications and candidate contact details	If the candidate is successful, seven years after the date on which employment ceases.If a candidate is unsuccessful, four months after the date on which the candidate is advised that their application will not be progressed unless it is considered that it would be worthwhile retaining the candidate details for potential future opportunities beyond that period, in which case the candidate will be asked if they consent to a further retention period.

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the rights to:

• request access to your personal data;
• request rectification of any mistakes in your personal data;
• request erasure of your personal data;
• object to our processing of your personal data;
• request restriction of processing of your personal data;
• request transfer of your personal data (data portability);
• withdraw your consent to our use of your personal data (only where we rely on consent as the lawful basis for processing).

We may need to ask for information from you to help us confirm your identity and ensure your right to exercise your data privacy rights before we are able to act on your request. We reserve the right to refuse to comply with a request if it is unfounded, repetitive or excessive. Otherwise, we aim to respond to all complete and legitimate requests within one month. Occasionally, it could take us longer to respond if we require further information from you, the subject matter is particularly complex, or you have made a number of requests. In this case, we will notify you and keep you updated.  

Further information on each of your legal rights and how to exercise them is set out below. It should be noted that the rights are not absolute but are subject to certain limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

• Right of access: You have the right to ask us for a copy of the personal data we hold about you at any time.
• Right of rectification: If the personal data we hold about you is not accurate or is incomplete, you have the right to have the data rectified, updated or completed.
• Right of erasure: In certain circumstances, you have the right to request that personal information we hold about you is erased – for example, if the information is no longer necessary for the purposes for which it was collected or processed, or if our processing of the information was based on your consent and there is no other legal basis on which we may process the information.
• Right to object: In certain circumstances, you have the right to object to our processing of your personal data – for example, you may object to the use of your personal data for direct marketing purposes, or you may object to processing based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.
• Right to restrict processing: In certain circumstances, you have the right to restrict our use of your personal information – for example, where you have challenged the accuracy of the information during the period where we are verifying its accuracy.
• Right to data portability: In certain circumstances, you have the right to receive the personal data that we hold about you in a structured, commonly used and machine-readable format. This right only applies in relation to personal data that you have provided to us and which is processed by us using automated means. Where the right applies, you may ask us to send the data directly to you or to a third party. However, we are not able to guarantee technical compatibility of the data we provide with a third party’s systems.

COMPLAINTS

If you are unhappy about our use of your personal information, you may contact us using the details in the “Contact and DPO” section below. We will investigate your complaint and notify you in writing of the outcome as soon as possible and in any event within 30 days of receiving the complaint.

CONTACT AND DPO

If you have any enquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights you can contact us, we will ask you to verify your identity.

Telephone:     

+359 876 700 834

Email: 

privacy@appgr8.com

Post:

Data Protection Officer

5^th Floor

Okolovrasten road 251

Ring Tower

Sofia

Bulgaria