Privacy Policy

Effective date: May 13, 2025

In this Privacy Policy, we describe the types of data, including personal data (collectively, “data”), that we collect from you when you use S.V.G. Software websites, products and services as described in this Privacy Policy (collectively, our “services”), how we use and disclose that data, and your options to access or update your data.

We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here. In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.

The data controllers are S.V.G. Software ltd., Boulevard “Tsarigradsko shose” 111,Sofia Bulgaria, and the associated companies of S.V.G. Software.

S.V.G. Software act as joint data controllers, who are jointly responsible for compliance with data protection legislation. S.V.G. Software ltd. is primarily responsible for exercising of the rights of data subjects and providing information about data processing.

What this policy contains

1. Definitions

2. Why We Collect Data and How We Use It

3. How long we store your personal information

4. Access to Data and Your Rights

5. Children

6. Transparency

7. Sharing

8. Security and Risks

9. Third-Party Links

10.Changes to our Privacy Policy

11. Further questions and how to make a complaint

Definitions

The following definitions are used throughout this Privacy Policy about S.V.G. Software as:

• Services: We are able to deliver our Services, personalize content, and make suggestions for you by using this information to understand how you use and interact with our Services and the people or things you’re connected to and interested in on and off our Services. We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits and troubleshooting activities.

• Products: Any software product owned or created by S.V.G. Software, EXCLUDING software that can be used by S.V.G. Software products but is not created by S.V.G. Software. This may include, but not be limited to, code that extends the functionality of a S.V.G. Software product (e.g., a “plugin”). Any such code is governed by its own terms and conditions and privacy policy.

• Website: Any website that is the property of S.V.G. Software ltd. (“S.V.G. Software”, “we”), including but not limited to everything hosted under the domains listed at https://www.svgsoftware.eu/.

Personal Data are any information which are related to an identified or identifiable natural person.

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies are small files stored on your device (computer or mobile device). Cookies serve useful and sometimes essential functions on the web. They can also be used to save for subsequent use information that the user previously entered into form fields, such as names, addresses, passwords, and payment card numbers.

Why We Collect Data and How We Use It

We collect several different types of information for various purposes to provide and improve our Service to you. In case where we make our services available free of charge, we finance our services through personalized advertising.

• What personal information we collect about you: We may collect data which are required to provide you with the software, support, and services, including checking for license validation and updates, provision of support, reporting of issues and bugs, and other processing connected with the use of S.V.G. Software, services, or information. We may use collected data in our development and testing of products and services. You explicitly fill in the data required for you to receive the software, support, or services, whether you purchase or use S.V.G. Software Products, use our support forums, and/or subscribe to receive marketing and/or technical information and content. We may use third-party service providers, acting as data processors, to assist us in providing S.V.G. Software Products to you or in our operations. For example, we may use third-party service providers to provide data storage and backup services. With your consent, your Personal data may also be transferred to third-party service providers, acting as separate data controllers, who provide products and services complementary to S.V.G. Software Products (further data processing performed by these service providers is governed by their privacy policies). The legal basis for this data processing is performance of contract between you and us.

• To protect us from piracy and unlawful use of our software or services. We may collect data which are required to protect us from any piracy, unlawful, or unauthorized use of our software or services, or which are necessary to ensure the security of our software or services, including both data provided by you (see above) and data collected in the course of use of S.V.G. Software Products. The legal basis for this data processing is S.V.G. Software’ legitimate interest in protection from piracy and unlawful use of S.V.G. Software and services.

• To promote and market our products and services. We may use feedback that you provide voluntarily on our products or services. As permitted by applicable law, we may use this in the form of quotes or in other ways in accordance with the S.V.G. Software Terms of Use. We also may use data that we collect and aggregate to assist us in determining appropriate marketing and advertising for our products and services. In doing so, we may share anonymous aggregated data with third parties to assist us with these efforts. With your consent or if permitted by applicable law, we may also use your contact details to send you commercial communications about our products and services. We also may use third-party service providers to assist us with our email marketing; in that case, the third-party service provider will have access to your email address, your name, and other information necessary to engage in the marketing. Such third-party service provider will act as a data processor and will not use your data for any other purpose. The legal basis for this data processing is our legitimate interest in promoting and marketing our products and services.

• How and why we share your personal information with others:

Third party advertising: We want to make sure that our advertising and marketing is relevant and interesting to you and our other customers. To achieve this, we use third-party advertising and technology companies to serve advertising and/or provide aggregated data to assist in serving advertising when you visit or use our apps. This includes third party technology companies which collect data about you in order to build a profile of your preferences based on your activities when you visit or use our apps. We also use these companies to automatically collect data from you when you use our apps in order to help us identify the advertising that are served to you and what you do after seeing those advertising. In addition, we share data with providers of analytics tools, such as Firebase, Google Analytics which we use to analyses your use of the apps. A list of the third party advertising and technology companies that we use is set out below.

DATA PROCESSING OPERATIONS:

» Admob (Google, Inc.)

» Firebase (Google, Inc.)

» Google Analytics (Google, Inc.)

» Unity Ads (Unity Technologies Finland Oy)

Where appropriate, we will prompt you to give us your consent to the collection and processing of your data as described above. This may happen within S.V.G. Software Products, on S.V.G. Software Website, or in another environment set up by S.V.G. Software, always in a clear and conspicuous manner. You can manage your data and opt-outs as described in the Transparency section below.

• Other third parties. We will share your personal information with the following third parties or categories of third parties:

1. Superhosting, who store all our data and may access personal data stored within that storage solution when providing support and maintenance purposes;

2. the OS providers of your device, or the providers of the platform from which you downloaded our app(s), in order to verify purchases you make and provide in-app purchase opportunities. This includes Google, Amazon and Apple; (c) Google, Inc. (trading as Firebase), who provide analytics of bugs and issues with our apps, so that we can fix, stabilize and improve our products;

3. We may share your personal information with our group companies where it is in our legitimate interests to do so:

(a) to enable them to provide customer support to you; or

(b) for internal administrative and management purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

4. We will also disclose your personal information to third parties:

(a) where it is in our legitimate interests to do so to run, grow and develop our business:

(b) if we or any of our group companies sell or buy any business or assets (or propose to do so), or we or any of our group companies are or may be acquired, we or our group companies may disclose your personal information to the prospective seller or buyer of such business or assets, and to their legal, financial and other professional advisers, and that personal information may be one of the transferred assets; and

(c) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

(d) in order to establish, exercise, enforce, or defend our terms of service or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

(e) to protect the rights, property, or safety of S.V.G. Software, our staff, our customers or other persons.

5. We may also disclose and use anonymised, aggregated reporting and statistics about users of our apps for the purpose of internal reporting or reporting to our group or other third parties. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

6. Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.

How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Any servers or services that contain personal data are located within the EU. For Software as a Service products, we provide the option for our customers to choose between hosting their instance in the EU or in other regions. At times, S.V.G. Software may process or transfer some of your personal data (such as name and email address) to our affiliate companies outside of the EU. Any such transfer will be made in accordance with the applicable laws on data protection and this Privacy Policy and will be based on a relevant adequacy decision of the European Commission, especially on standard data protection clauses.

Access to Data and Your Rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at office@svgsoftware.eu at any time. You have the following rights:

After the data removal, we may keep pseudonyms of your personal data solely for a record about the data removal. Generally, we retain your data as long as we need to in order to achieve the purpose for which it was collected. We may retain your information if it is required to comply with legal obligations and/or defense in case of violation of S.V.G. Software Terms of Use and/or Privacy Policies. We may also have copies of your information in application logs, weblogs, and/or backups made for security and support purposes if this is mentioned in a S.V.G. Software Terms of Use or consent text accepted before the personal data collection. These backups will not be accessible as separately delineated information. We may store data pertaining to a customer or user for as long as they are entitled to a license or usage of S.V.G. Software Products. Further, we may keep the data to protect ourselves from damage in case of litigation in accordance with the current legislation. Please note, however, that you must retain a copy of all data that you have placed on our servers in the case of any loss; further, if you cease using our software and/or services, we will not be responsible for retention of any of your data.

You may manage your Personal Data in your S.V.G. Software Account, including opting out of certain kinds of data collection. You are responsible for the correctness of the Personal Data you provide to us. We expect you to check the Personal Data you provide to us and if any inconsistency takes place, update your Personal Data or report the inconsistency to S.V.G. Software.

Moreover, as set out in locally applicable personal data protection law, you may have the right to: (i) request access to your personal data; (ii) request rectification of your personal data; (iii) request erasure of your personal data; (iv) request a restriction on the processing of your personal data; (v) request personal data portability; or (vi) object to the processing of your personal data.

• Right of access. You may have the right to obtain from us a confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to request access to your personal data. The information about personal data processing includes the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom your personal data have been or will be disclosed, etc. However, this is not an absolute right and the interests of other individuals may restrict your right of access. Further, you may have the right to obtain a copy of your personal data undergoing processing. For additional copies requested, we may charge a reasonable fee based on administrative costs.
• Right to rectification. You may have the right to obtain from us the rectification of inaccurate personal data. Depending on the purposes of the processing, you may have the right to have incomplete personal data made complete, in particular by providing a supplementary statement.
• Right to erasure (right to be forgotten). Under certain circumstances, you may have the right to require us to delete your personal data.
• Right to a restriction on processing. Under certain circumstances, you may have the right to require us to restrict the processing of your personal data. In this case, the respective personal data will be marked and may only be processed by us for certain purposes.
• Right to personal data portability. Under certain circumstances, you may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and to transmit these personal data to another entity.
• Right to object. Under certain circumstances, you may have the right to object, on grounds relating to their particular situation, at any time to the processing of your personal data by us and we can be required to no longer process your personal data.

These rights can be exercised via the email address office@svgsoftware.eu.

You may also contact S.V.G. Software to get up-to-date information about your personal data processing and any personal data recipients.

You may lodge a complaint related to the processing of your personal data with the competent data protection supervisory authority, i.e. in the Bulgarian Republic Commission for Personal Data Protection (CPDP), with its registered office Bulgaria, Sofia 1592, 2 Prof. Tsvetan Lazarov blvd. For more information, please visit https://www.cpdp.bg/en/.

Children

You must be aged 16 or over to purchase products or services from us. Our website and services are not directed at children younger than this and we do not knowingly collect any personal information from children younger than this.

If you are aged below the age of 16 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.

Our products and services are not designed for and are not offered to children under the age of 13. If we discover that a person under the age of 13 has submitted information directly to us, we will endeavor to delete the information from our systems.

Please contact us at office@svgsoftware.eu if you are aware that we may have inadvertently collected personal information from a child below the age of 16.

Transparency

To respect your privacy, before using your personal data, we will inform you about the categories of data we collect and the purposes we use them for. We will also inform you about the data management options that you may have. For this purpose, we use agreements, terms of use, and consent notices embedded in S.V.G. Software Products and Services, which are available here. Should you wish to access and manage your data, you can do so here, you can update and manage your data and also provide us with an opt-out of certain personal data collection.

Sharing

We may share your data with certain third parties which help us provide you with S.V.G. Software Products or services, or to run our business, for example to providers of data storage and backup services. We may also share your data with individual representatives of your company.

Your personal data may also be shared with other organizations or individuals if we have obtained your consent to do so.

We may also share your data with certain third parties if we are obliged to do so under applicable legislation (especially with tax authorities or with other government bodies exercising their statutory powers) or if such sharing is necessary to achieve the purposes defined above (especially with government bodies or with parties harmed as a result of violations of applicable laws).

Security and Risks

The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

For this reason, we are committed to protecting your personal information from loss, theft and misuse. We take reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organizational and technical measures. We use industry-standard practices such as encryption, firewalls and password protection systems to safeguard the confidentiality of any personal information that we might collect from you. For example, your email address will be encrypted, which will make it extra hard for someone to discover and use them without our authorization. We also strive to limit access to your data to employees performing a legitimate business function which requires them to access and use your data in order to supply you with our apps. We review our security procedures periodically to consider appropriate new technology and updated methods to ensure we continue to protect your data.

Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our apps or customer services function and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it. To secure your personal data, our products and services are designed with security and privacy in mind.

We encrypt your data in transfer and at rest where it is technically feasible. External web resources are protected by SSL encryption.

We review the processes of personal data usage before implementing them. This is done to minimize data usage and to make sure that you as the data owner is informed about the processing. When the reason for data storage expires, we remove your personal data from our servers or anonymize it for further usage. By the nature of the activity within which your data is collected, it may appear in datasets used for research. Before using the datasets for research or other purposes you are not informed of, we remove or anonymize your personal data in the datasets.

We use partners to host our services and websites and to process your data in accordance with this Privacy Policy. While choosing the partners, we ascertain their compliance with legal regulations and security standards to make sure your data are stored in a secure location with appropriate security measures in place.

Third-Party Links

S.V.G. Software Websites may contain links to other websites provided by third parties not under S.V.G. Software control. When following a link and providing information to a third-party website, please be aware that S.V.G. Software is not responsible for the data provided to that third party. This Privacy Policy only applies to S.V.G. Software Websites, so when you visit other websites, even when you click on a link posted on S.V.G. Software Websites, you should read their own privacy policies.

Changes to our Privacy Policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be made available to you via the privacy policy, accessible in our app. Please check back frequently to see any updates or changes to our privacy policy.

Further questions and how to make a complaint

If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact office@svgsoftware.eu. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of May 13, 2025.