Last Updated on 24/05/2018
“Services” - means all products, services, content, features, technologies or functions, and all related websites, applications, and services offered by us.
“Platform” – means websites, mobile apps, mobile sites, or other online properties through which we offer our services.
“Personal Data” – means all data that contain identifying information (name, address, telephone number, email, etc.).
“Personal Data Administrator” - means a person or company that determines the purposes or means of processing the personal data.
1.Who we are?
The main administrator of your personal data for the purposes of our international services is Web Novel Bulgaria Ltd., UIC 203807976., a limited liability company based in Bulgaria. The corresponding contact details are given in section 13.
2.What data do we collect about you?
2.1.1 Data provided through direct interactions.
Registration and other user profile information
When you sign up to use our Services we can collect the following information about you:
• If you sign up using your Google Account: your name, surname and email;
• If you sign up using your Facebook profile: we collect your name and surname, as they are visible on your Facebook account. If you have granted Facebook permission through the application privacy option (which appears just before you sign up on our Platform), we can collect information about your gender, years, email address, depending on the permissions you have provided; and
• If you sign up using your phone number: we collect information about your phone number.
Depending on the choice you make when entering our Services or during the process of participating in our Services, you may choose to provide some of the following additional personal information:
• Your name
• Your email address
• Your phone number
2.1.2. Information we collect automatically when you use our Services
When you access our Platform or use our Services we automatically collect the following information about you:
• We collect specific device information such as operating system, version, unique identifiers. For example, the name of the mobile network you are using. We connect unique identifiers to your account.
User data and entry data
• Technical details, including the IP address of your device, time zone, and operating system. We will also keep your login information on the Platform (registration date, last password change date, last login date), type and version of your browser.
Data generated by users when viewing webpages
• We collect information about your activity on our Platform that includes the sites from which you access our Platform, the date and time of each visit you made, searches, ads, or banners you clicked, your interaction with such ads, or ads on the time of your visit, and the order in which you visit the content of our Platform.
Cookies and similar technologies
• We use "cookies" to manage user sessions, store the selection of your preferred language preferences, and provide you with relevant ads. Cookies are small text files transferred from a web server to your device's hard disk. Cookies can be used to collect the date and time of website visits, web browsing history, your preferences, and your username. You can set your browser to deny all or some cookies, or to alert you when the websites you visit set or have access to cookies. Please note that if you disable cookies, some of our services / Platform may become inaccessible or may not function properly. For more information about the cookies we use, please see our Cookies Policy and related technologies.
2.1.3. Data from third parties or from publicly available sources
We receive your personal data from various third parties [and public sources] as outlined below:
i. Specific technical data and information on the use of the Services by analytics vendors such as Google Analytics, Facebook, Google, and others;
ii. Data collected by reading cookies, data from advertising networks such as Programmatic Advertising and other;
iii. Publicly available, specialized information from search providers such as public online catalogs and directories;
iv. Data from social networking accounts when accessing our services in the Platform through these accounts.
2.1.4. We do not collect personal data that:
• reveal racial or ethnic origin;
• reveal political, religious or philosophical beliefs;
• reveal membership of political parties or organizations, associations with religious, philosophical, political or trade union goals;
• relating to health, sexual life or the human genome
3. Do we collect information from children?
Our Services are not intended for children under the age of 16 and do not consciously collect personal data from persons under 16 years of age. If we know that a person under the age of 16 has provided us with personal data we will delete it immediately.
4. Why do we process your personal information?
We will use your information and personal data only when the law permits us. We will most often use your personal data in the following circumstances:
• When we have to fulfill the contract that we have concluded or is about to conclude with you.
• When it is necessary to protect your legitimate interests to improve our services and provide you with a safe and secure Platform.
• When we are obliged to comply with a legal or regulatory obligation
Under certain circumstances, we may process your personal data based on your consent. If we do, we will notify you of the purpose and the category of personal data that will be processed at the time you request your consent. Here is a description of how we use your personal information [and which are the legal grounds we invoke to do it. We also identify what our legitimate interests are].
4.1 To provide user access and provision of Services through our Platform.
• If you use your mobile number or email address to access, we use your name, surname, mobile number and / or email address to identify you as a user and provide access to our Platform.
• If you use your Facebook account to access, we use your name and surname from your Facebook account and the email address you used on Facebook to identify you as a user of our Platform and give you access to it.
• The registration data is used by us to provide our Services in accordance with the Terms of Service.
• We use your email address and mobile number (via SMS) to make proposals and recommendations for our Services that you may be interested in.
We process the above information for accurate performance of our agreement with you and based on our legal interest in marketing activities to offer you services that may be of your own interest.
4.2. To improve your user experience in the Platform.
A) We use data generated by users when viewing web pages to:
• we offer compliant content, such as giving you more relevant search results when you use our Services.
• determine how much time you spend in a Platform, and how you manage the Platform to understand your interests and improve our Services based on this data. For example, we may offer you content to visit based on the content you clicked on.
• monitor and report on the performance of our business partners' campaigns and on internal business analyzes.
B) We use your location data for the following purposes:
• to compile anonymous and aggregated information on the characteristics and behavior of Platform users, including for business analysis purposes, segmentation and disclosure of anonymous profiles.
• to improve the performance of our Services, and customize the content we target to you. For example, using your location data, we show you a list of ads that are close to you to improve your buying experience.
• to evaluate and monitor your access to third-party ad banners that are visible on the Platform.
C) Using the login information on the Platform you provide, including an email address and a phone number, we reflect the various devices (such as desktops, mobile devices, tablets) that you use to access the Platform. This allows us to connect your platform activity across different devices and helps us provide you with seamless user experience no matter what device you use to access.
We process the above information based on our legitimate interest to improve your experience in the Platform and fully implement our joint venture.
4.3. To provide you with a safe and secure Platform.
A) We use your mobile number, access form data, and unique device identifiers to administer and protect the Platform (including troubleshooting, data analysis, testing, fraud prevention, system support, support, reporting, and data reception).
B) We analyze your communications through our chat feature to prevent fraud and to promote safety by blocking spam or offensive messages that may have been sent to you by any other user.
We process the above information for the full and accurate execution of our joint venture, to improve our Services and our legitimate interest in preventing fraud.
6. Your rights
In certain circumstances, you have the rights under the applicable privacy laws and in relation to your personal data.
If you wish to exercise any of the following rights, please select your profile settings / privacy settings or contact us via the contact form:
Right to request access to your personal data (commonly referred to as "data subject request"). This allows you to obtain a copy of your personal information that we store and to verify that it is legally processed.
Right to ask for a correction of the personal data we have about you. This allows you to correct any incomplete or inaccurate data we have about you. However, we may need to check the accuracy of the new data you provide us with.
Right to request limitation of the processing of your personal data. This allows you to contact us with a request to suspend the processing of your personal data in the following hypotheses: a) if you want to prove the accuracy of the data; b) when you believe that the use of our data is illegal; c) when you require us to store the data, even if you no longer need it, as you need to identify yourself in order to exercise or prove your claims; or d) when you oppose the use of your data, but we need to verify if we have legitimate reasons to use it.
Right to request the deletion of your personal data. This right allows you to contact us with a request to delete or remove your personal information when there is no good reason to continue processing it. In addition, you have the right to request to delete or remove your personal data when you have successfully exercised your right to object to processing (see below) when you have doubts that we may have processed your information not in accordance with the law or when required to erase your personal information to comply with legal requirements. Please note that for certain purposes we may be legally obliged to store your personal data (see Section 10).
Right to object to the processing of your personal data when it is based on a legitimate interest (or that of a third party) and has reason for your specific interests, which makes you oppose the processing of your personal data on this basis, that processing violates your fundamental rights and freedoms. You have the right to object when processing your personal data for the purposes of direct marketing. In certain cases, we can prove that we have compelling legitimate reasons to process the information about you that waives your right of objection.
Right to request transfer of your personal data to you or a third party. We will provide you or the third party that you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right applies only to automated information for which you have originally consented to use or which we have used to conclude a contract with you.
You have the right to withdraw your consent to the processing of your personal data at any time. This is without prejudice to the lawfulness of the processing we have already done on the basis of your prior consent.
No fee is usually required: You have no obligation to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your application is clearly unfounded, repetitive or excessive. We may refuse to fulfill your request under these circumstances.
Response Time: We will do our best to respond to any legitimate request within one month of filing. It may take us more than a month if your request is particularly complicated or you have made several requests. In this case, we will notify you and keep you up-to-date. In addition, you have the right to file a complaint at any time with the Privacy Commission as set out in section 13. Before submitting a complaint to the Privacy Commission, we would like to get to know your reasons for complaints and claims and do our best to resolve them. Please contact our Privacy Department using the contact form.
7. Communications and marketing
We will contact you via email, SMS, or notice in relation to our Services / Platform to verify your registration to inform you in case your ad has become active / expired, as well as other announcements about connection to our Services. Since it is imperative to provide you with such messages, you may not be able to opt-out of receiving them.
You may want us to stop sending marketing communication at any time by clicking the opt-out link in the email or the SMS we send to you, or by changing the communication settings in your account. If you have a problem with changing the settings, please contact us via the contact form.
You may receive marketing communications from us if:
• you have requested such information from us;
• you use the Platform or Services;
• you provided your data when you participated in a contest organized by the Platform; or
• you are registered for promotion.
8. Who do we share your data with?
We may share your personal data with the countries listed below for the purposes listed above in Section 4.
Company affiliates: We may share your personal information with other affiliates / sites within the Group within and outside the EEA and assist us in providing business operations such as product enhancements, customer support, and a discovery mechanism fraud. Any sharing of personal data within the Group outside the European Economic Area (EEA) will always be subject to the safeguards described in Section 9 or to a data transfer agreement that clearly defines the obligations of the parties and provides for appropriate technical and organizational measures to protect your data.
Employees and consultants of BULFELD Ltd. UIC: 175266642, who own the website www.paradise-center.com, blog www.blog.paradise-center.com and the Paradise Center mobile applications, will have access to your personal data for the purpose of managing the website, blog and mobile apps, as well as the marketing initiatives they have organized to inform you about campaigns, games and / or promotions that they think may be of interest to you or to communicate with you for a different purpose, as evidenced by the circumstances, or for which they will informing you in case of the collection of a personal data from you but they are bound by an obligation of confidentiality regarding the data accessed by them as part of the relevant underlying marketing operations.
Employees, consultants and partners of Web Novel Bulgaria Ltd. are duly informed of the importance of complying with the confidentiality obligation and are responsible for complying with this obligation.
Third-party service providers:
We conduct inspections of our third-party service providers and require them to respect the security of your personal data and to treat them in accordance with legal requirements. We do not allow third-party service providers to use your personal data for their own purposes and only allow them to process your personal data for specific purposes only and in accordance with our instructions.
Ad Servers and Analysts:
In order to improve our Services, we will occasionally share the non-identifiable information with analytics providers that help us analyze how users use the Platform / Services. We share our information with them in a non-identifiable form for monitoring and reporting on the performance of our business partners' campaigns and business analysis. For more details on our advertisers and analytics vendors, please see our Cookies Policy and related technologies.
Law enforcement, regulators, and others:
We may disclose your personal data to law enforcement, governmental or public authorities and others like third parties to comply with all legal or regulatory requirements. We may disclose your personal data when such disclosure is necessary for the creation, exercise or protection of legal claims, whether in court proceedings or in an administrative or extrajudicial procedure. In these cases, we are not obliged to inform users about the disclosure of their personal data to public authorities.
We can sell, transfer or merge parts of our business or our assets. We are likely to acquire or merge with other companies. If these changes occur in our activity, new owners may use your personal information in the same way as described in this privacy statement.
9. International transfers
Every time we transfer your personal data outside of the EEA, we ensure that a similar level of protection is provided, ensuring that at least one of the following safeguards is applied:
• We transfer your personal data only to countries that are accepted by the European Commission to ensure an adequate level of protection of personal data.
• When we use the services of certain service providers, we can conclude with them specific contracts approved by the European Commission that provide personal data with the same protection they have in Europe.
• When using service providers based in the US, we may transfer data to them if they are part of an EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between Europe and the United States.
10. Where do we store your data and for how long?
The data we collect about you will be stored and processed in and outside the EEA on secure servers in order to provide users with the best user experience. For example: to quickly create websites or mobile apps.
We will only retain your personal data for as long as necessary to meet the purposes for which we have collected it, including for purposes of compliance with statutory, accounting or reporting requirements.
To determine the appropriate period of privacy, we take into account the amount, nature and sensitivity of your personal information, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can to achieve these goals by other means and the applicable legal requirements.
If you have any questions regarding the period of storage of your personal data, please contact us via the contact form.
11. Technical and organizational security measures for processing
All the information we receive about you is stored on secure servers and we have implemented technical and organizational measures that are appropriate and necessary to protect your personal data. Web Novel Bulgaria Ltd., UIC 203807976 continuously assesses the security of its network and the suitability of its internal information security program, which is designed to: a) help protect your data from accidental or unlawful loss, access or disclosure; b) Identify reasonably foreseeable security risks for Web Novel Bulgaria Ltd., c) minimize security risks, including risk assessment and regular testing. We also ensure that all payment data is encrypted using SSL technology.
12. Links to third-party sites
For additional information or to exercise your rights, please check your profile / privacy settings or contact our Privacy Department using our contact form. You may also contact the Personal Data Administrator for your Services at: Web Novel Bulgaria Ltd., UIC 203807976, with its registered office and address: Sofia, Lagera, Smolyanska №56 Str., floor 6 ap. 22.
The main supervisory body is:
“Berliner Beauftragte für Datenschutz und Informationsfreiheit”
Friedrichstr. 219, Besuchereingang: Puttkamerstr. 16 – 18 (5. Etage), 10969 Berlin, Germany
Phone: 030 13889-0; Fax: 030 2155050; Email: email@example.com
For local data protection issues, your local supervisor is:
Personal Data Protection Commission
Address: Sofia, 1592, Tsvetan Lazarov Blvd.
Tel. +359 2 915 3580 Fax +359 2 915 3525
Latest version: 23/05/2018
1.What are cookies?
For more information about cookies, visit www.allaboutcookies.org.
Cookies perform multiple features, including making navigation easier and storing your preferences in order to provide more personalized content and enhance overall user experience.
• To manage your preferences and improve certain Platform features. This includes collecting information about the date and time of your visit, your search history, and your language preferences.
• To support our security measures and detect abuses.
• To analyze the ways in which our Platform is accessed, and how it is used. We use this information to support, manage and improve our services.
• To provide you with customized ads. Cookies help us manage ads and measure their performance.
3.What types of cookies and other technologies do we use?
Our Platform uses the following categories of cookies and technologies:
• Permanent Cookies - These cookies are stored on your device's browser and are in use when you visit the Platform. These cookies serve to store user settings and preferences to improve their subsequent visits. For example, these cookies ensure that users do not have to re-enter their profiles. In addition, they store the language preferences of users on a subsequent visit.
• Session Cookies - These are temporary cookies that are stored in your browser's cookie archive until they leave the Platform. The information we receive using these cookies helps us analyze web traffic that allows us to detect and eliminate problems and to provide better navigation.
• Ad Cookies - These cookies ensure that personalized ads are delivered and help measure ad campaign performance by analyzing your interaction with your ads. For example, they help us determine the number of clicks on an ad from users who have visited the advertiser's website.
In addition, our Platform uses web directories that are small graphics (also known as "pixel pointers" or "clear GIFs"). They are used together with cookies to identify users and their behavior.
4.Do we use third-party cookies or extensions on our Platform?
Below is a list of third parties that have received our consent to store cookies or other technologies on your device.
Ad networks: The following ad networks may use targeting cookies and ad cookies to provide ads that might be of interest to you and measure the performance of similar ads on our Platform:
Third-party extensions: Our Platform also uses third-party extensions in the form of a share button on Facebook, Twitter, and Whatsapp. With the help of the sharing button, you can share our ads on third-party platforms, provided you are logged in to those third-party accounts. These could link your interaction with our Platform and your accounts with them. You should learn about these third party privacy policies before clicking the share button.
5.How can you delete, disable, or block cookies?
Your browser typically provides you with information on how to delete, block, or opt out of cookies. More information about more commonly used browsers can be found at the following links:
• Google Chrome
• Internet Explorer
• Mozilla Firefox
You can opt out of third-party cookies from Google Analytics through its ad settings or through https://adssettings.google.com.
You can opt out of targeting interest-based targeting cookies from advertisers using one of the following websites provided by Digital Advertising Alliance:
In addition, you can change the settings of your mobile device when it comes to seeing ad content based on your interests.
Warning: In case you block the cookies used by our Platform, you may not have access to all or part of our services, such as saving custom settings as access information.
For further information or to exercise your rights, you can contact us at any time by email firstname.lastname@example.org or email@example.com.