Privacy Policy of ImgSearch

The purpose of this Privacy Policy of ImgSearch (the "Policy") is to notify our visitors and users of what data about them we process when they access and use the ImgSearch Platform (ImgSearch/ the Platform), for what purposes and on what grounds we process the data, as well as what data protection rights they have. This Policy is an information document under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC ("the Regulation").

I. Data Controller

Art. 1. The Controller of personal data under this Policy is ImgSearch Ltd, a company registered with the Bulgarian Commercial Register at the Registry Agency, with unified identification code 208143664, with seat and registered office: 88 Bulgaria blvd, entr. 3 – offices, fl. 2, office 6, Sofia 1680, Bulgaria, referred to below as “We” or "Controller".

Contact information:

You can contact the Controller at the physical address indicated above, as well as through the following email address: contact@imgsearch.com

II. To whom does this Policy apply?

The Policy applies to all visitors and users of ImgSearch (“You”) and aims to inform You about the processing of your personal data in connection with your access and use of the Platform.

"Personal Data" within the meaning of this Policy and European legislation means any information relating to an identified or identifiable natural person ("Data Subject").

III. What data do we collect and for what purposes?

If you access ImgSearch, the following Personal Data will be collected about You:

Technical Data:

Information about the IP address and basic details of the device through which you access ImgSearch - what browser and which version of it You use, operating system, screen resolution, plug-ins You use. This information is automatically collected by the Platform in order for You to access and use it and to display ImgSearch correctly on your device.
We may collect the above Personal Data, as well as data about your behavior in the Platform, in order to detect and resolve technical problems with the Platform, as well as to ensure the security of the Platform and protect it from denial-of-service (DDoS) attacks and other malicious actions;
With your consent, additional data may be collected about Your use of the Platform, such as which pages of the Platform You visited, how You were redirected to the Platform.
In addition, we process information that You have provided consent or that You have withdrawn your consent – this information is stored in the form of log files in our systems solely for the purpose of proving that we have fulfilled our legal obligations.

Account Data:

If You create an Account on Our Platform, we will process the following Personal Data about You:

Data for creation of Account: name, email address, chosen password.
Sign up and login with Google: You may use Your credentials to log in to your account with Google and we will receive information from Google to identify You and create an Account in our Platform /log You in Your Account. In this case we receive from Google information about Your names and email address. We do not receive Your password for Your Google Account or any other information contained in Your Google Account and/or processed by Google about You.
Other Personal Data in Your account: account picture (if provided by You or if We receive it from Gravatar or any similar third-party), information about Your chosen Plan/Package and Your purchase history, information about Your downloads history.

Payments Data:

We use a Merchant of Record (MoR) who is a licensed payment service provider and handles the payments made by Our clients to Us. To make a payment, You need to provide to Our MoR Paddle (Paddle Payments Ltd., The Academy 42 Pearse Street Dublin, D02 YX88 Ireland) with payment method details: card number, expiration date, CVV/CVC code. This data is processed by Paddle and is not provided to Us in any way. We receive only information about the payment itself: the amount of the payment, date of the payment, names of payee. The processing of Your Personal Data by Paddle is subject to their privacy policies available at: paddle.com/legal/privacy.

Communications Data:

We may use Your email to contact You with important information about Your Account, including information about Your registration, updates of Our legal documents, important information about the Services, guidelines how to use the Services, and any information we are obliged to provide to You under the applicable legislation.

If You contact Us with questions, complaints, inquiries, etc., we will process information about Your name, contact means You used, content of the communication, data and time of receipt, result of the processing of Your communication and subsequent actions undertaken by Us.

Personal Data gathered upon Your Consent:

With Your consent we may gather other categories of Personal Data which will be described in the respective consent document. For example, You may subscribe to receive a news bulletin for ImgSearch.

IV. What data do we collect and for what purposes?

On grounds of a contract concluded between You and Us under Our Terms of Use

Providing You with access to the Platform, Your Account and all functionalities,
Providing Our Services to You in accordance with the Terms of Use,
Providing You with the opportunity to make payments in order to use paid Packages and Plans.

For these purposes, it may be necessary to process all of the categories of Personal Data mentioned above.

On grounds of legitimate interest

ensuring the normal functioning and use of the Platform by You and other users,
protecting Our rights and legitimate interests, including in court proceedings, and assisting in protecting the rights and legitimate interests of other users of the Platform and/or affected third parties, including employees, representatives, suppliers and partners of Ours,
communicating with you, receiving and processing complaints, requests and other correspondence,
introducing improvements in the functioning of the Platform and detecting and resolving technical or functional problems,
detecting and preventing malicious actions and ensuring the secure functioning of the Platform.

For these purposes, it may be necessary to process all of the categories of Personal Data mentioned above.

On grounds of legal obligations

The purposes related to compliance with legal obligations include the fulfilment of legal obligations, such as:

tax and accounting obligations,
responding to requests and inquiries from users (e.g. requests regarding personal data protection),
executing orders of competent authorities.

For these purposes, it may be necessary to process some, or all of the categories mentioned above.

On the basis of explicit consent

Your data may be processed on the basis of your explicit consent, and the processing in this case is specific and to the extent described in the respective consent document.

Who do we share Personal Data with?

Your personal data may be provided to third parties only in the following cases:

where this is required for fulfilment of legal obligations - if duly requested by a competent state, municipal or judicial authority, for fulfilment of tax and accounting obligations to the respective authorities, etc.
when it is necessary for ensuring the functioning of the Platform and the general operations of the Controller (e.g. payment providers, accountants);
when necessary for the protection of Our rights and legitimate interests and/or the rights and legitimate interests of third parties – to lawyers, notaries, bailiffs, etc.
when we have obtained your explicit consent to do so.

Your Personal Data collected in connection with accessing and using the Platform may be shared with third parties who process Personal Data as processors on our behalf for the purposes and means determined by Us. In these cases, we take all necessary measures to settle our relations with these persons in a way that ensures the security of Your Personal Data.

We use cloud services from Akamai (Akamai Technologies, Inc., 145 Broadway Cambridge, MA 02142, USA). Akamai acts as a processor of Personal Data on our behalf. Akamai participates in the EU – US Data Privacy Framework Program, for which the European Commission issued an adequacy decision available at: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en. The transfer of Personal Data under this Policy to Akamai is based on this adequacy decision in accordance with Art. 45 of the Regulation.

We use the services of ActiveCampaign, LLC (1 N Dearborn St FL 5 Chicago, IL 60602) to send emails concerning Our Services, i.e. regarding registration, updates of Our legal documents, important information about the Services. ActiveCampaign, LLC acts as a processor of Personal Data on our behalf. For these purposes we share with ActiveCampaign Your name and email address. ActiveCampaign participates in the EU – US Data Privacy Framework Program, for which the European Commission issued an adequacy decision available at: https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en. The transfer of Personal Data under this Policy to ActiveCampaign is based on this adequacy decision in accordance with Art. 45 of the Regulation.

We may use Google services (Google Ireland Limited at Gordon House, Barrow Street, Dublin 4, Ireland) for the purpose of analysing the use of the Platform, with Google acting as a processor on our behalf. The use of Personal Data for this purpose will be based on your consent. We also use Google services to provide You with easier way to sign up or log in to Our Platform by logging in Your Google Account. If You use this option, Google will receive information that You used Your Google account to log in to Our Platform.

In addition to the above, we share search enquiries from ImgSearch with OpenAI for the purposes of AI model training, however, they are not linked to Your Account and Your Personal Data, i.e. You cannot be identified in any way by these enquiries.

V. For how long do we retain Your Personal Data?

Personal data collected under this Policy is stored for the following periods:

Device data: for a period of up to 1 (one) year.
Data collected in connection with the security of the Platform: for a period of up to 1 (one) year.
IP addresses and system logs - for a period of up to 1 (one) year.
Data contained in Your Account – for as long You maintain Your Account and for 5 (five) years after its deletion. Your download history and any preferences you've set on our Platform will be deleted together with Your Account, but we will retain information about Your name, email and purchase history for the purposes of defense of legal rights and interests in case of future disputes.
Data about payments - for the purposes of accounting registers and financial statements, including documents for tax control, audit and subsequent financial inspections – 10 (ten) years as of January 1 of the reporting period following the reporting period to which the respective documents relate; in other cases – for 5 (five) years. Please note that even if You delete Your Account with Us, we have a legal obligation and legitimate interest to retain this information.
Correspondence, requests, complaints and others - in order to resolve complaints, inquiries, requests or other communication addressed to Us, We store and process the information about the communication, as well as the result of the processing. Given the limitation periods under Bulgarian law, for the purpose of resolving disputes this information is stored for a period of up to 5 (five) years.
Cookies - data from the cookies and other similar technologies will be stored as described in the Cookie Policy below.
Data collected on the basis of consent will be retained for the periods stated in the consent document or until You withdraw Your consent.

Personal Data may be retained longer in case of ongoing legal proceedings - for the duration of the proceedings and 5 (five) years after their termination.

VI. What rights do you have in relation to your Personal Data?

1. Right to information

This Policy aims to inform you in detail about the processing of your Personal Data when accessing and using the Platform.

2. Right of access

You have the right to receive confirmation of whether your Personal Data is being processed, access to Your Personal Data and to information about their processing and your rights in this regard.

3. Right to rectification

You have the right to rectify your Personal Data in case it is incomplete or inaccurate.

4. Right to erasure

You have the right to request the deletion of Personal Data if the grounds for this provided for in the Regulation are present.

5. Right to restriction of data processing

You have the right to request restriction of the processing of your Personal Data, if there are grounds for this provided for in the Regulation.

6. Right to notify third parties

Where applicable, you have the right to ask Us to notify third parties to whom we have disclosed your Personal Data in respect of any rectification, deletion or restriction of the processing of Your Personal Data, unless this is impossible or requires a disproportionate effort on Our part.

7. Right to data portability

You have the right to receive Your Personal Data in a structured, widely used and machine-readable format, as well as to provide this data to another controller at your discretion.

The right to data portability applies where the following two conditions are met simultaneously:

(a) the processing is based on consent; and

(b) the processing is carried out by automated means.

If technically feasible, you have the right to receive a direct transmission of Personal Data from us to another controller.

8. Right not to be subject to a decision based solely on automated processing

Your personal data under this Policy will not be used for decisions based solely on automated processing, including profiling, that have legal effects on You or similarly affect You to a significant extent.

9. Right to withdraw consent

You have the right to withdraw Your consent to the processing of your Personal Data at any time. Such withdrawal shall not affect the lawfulness of the processing until the withdrawal.

10. Right to object

You have the right to object to the processing in respect of Personal Data processed on the basis of legitimate interest.

11. Right to lodge a complaint

You have the right to lodge a complaint with a supervisory authority if You believe that the processing of Your Personal Data violates the applicable legislation on personal data protection. The supervisory authority in the Republic of Bulgaria is the Commission for Personal Data Protection, address: 2 Prof. Tsvetan Lazarov blvd., Sofia 1592, Bulgaria, email address: kzld@cpdp.bg, website: www.cpdp.bg

You can exercise all your rights by contacting us on the contacts specified in this Policy.

Cookie Policy

Cookies are small files of information that are stored on your device when you visit a website. Cookies are used by most websites and do not harm operating systems. The information stored in cookies may relate to your preferences, your device and your use of the Platform. You may refuse to consent to the use of certain types of cookies.

Cookies can be categorized in different ways:

Mandatory, which we use on the basis of our legitimate interest in providing the Platform, and without which the Platform cannot function properly, and optional, for which we require Your consent.
Mandatory, functional, analytical, marketing, etc. based on their functions.
Session and persistent, depending on whether they are automatically deleted at the end of Your session on the Platform, or stored to be used during your next visits. You can see in the table below for how long the persistent cookies used by our Platform are stored.
First-party and third-party– first-party cookies are the cookies used by our Platform that only we can read. We may use third-party services for which separate cookies, called third-party cookies, are used. We provide information about all third-party cookies we use.

Your browser may be set to reject all cookies. You can choose which cookies to allow or disable by visiting the appropriate settings on your browser:

Microsoft Edge cookie settings: https://support.microsoft.com/en-us/windows/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d

Chrome cookie settings: https://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform%3DDesktop

Safari web https://support.apple.com/en-is/guide/safari/sfri11471/16.0/mac/11.0 cookie settings

Please note that blocking some types of cookies may prevent the Platform from working properly.

Essential cookies (no consent required, necessary for the proper functioning of ImgSearch)

These cookies are mandatory for the normal functioning of the Platform. You can set your browser to block these cookies, but it may lead to problems when using the Platform or certain functionalities.

Name	Function	Duration
XSRF-TOKEN	Protects against cross-site request forgery (CSRF) attacks.	Session
laravel_session	Stores session data for authenticated users.	Session
cookie_consent	Stores user consent preferences for cookies.	?
remember_token	Enables "Remember Me" functionality for users.	3 months
paddlejs_checkout_*	Cookie of Our Merchant of Record for managing payment sessions and user preferences.	Session
paddle_cart_*	Paddle cookie for storing shopping cart information during a session.	Session
paddle_affiliate	Tracks the affiliate ID to attribute sales to the correct affiliate.	?
paddle_affiliate_override	Stores temporary affiliate overrides if multiple referrals are received.	?

Optional cookies (consent required)

Analytical

Analytical cookies are optional and serve for useful analyses of the use of the Platform. You can refuse the use of analytics cookies.

Name	Function	Duration
_gat_gtag_UA_*	Google Tag Manager cookie for tracking website activity.	1 minute
_ga	Google Analytics cookie for tracking user behavior on the Platform.	2 years
_gid	Google Analytics cookie for tracking user behavior on the Platform.	24 hours

Advertisement cookies are used for advertising, including serving and rendering ads, personalizing ads (depending on Your ad settings), limiting the number of times an ad is shown, muting ads You have chosen to stop seeing, and measuring the effectiveness of ads.

Name	Function	Duration
_fbp	Meta (Facebook) cookie for tracking and ad delivery.	3 months
_gac_*	Google Ads cookie for tracking conversions and ad performance.	3 months
_gcl_au	Google Ads cookie for storing and tracking conversions.	3 months

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