Privacy Policy Marketplace

Data Privacy Policy

Who we are: and its data basis are owned and administered by "Truvity" Ltd, UIC 204818089, a
Bulgarian company, with its registered office in Sofia, 1303, Vazrazhdane district, Str. 117 "Hristo Botev"
(the Company).
The Company is a provider of highly value added data processing solutions and capabilities. Truvity’s aim
is to enable its customers to meet the AML and KYC requirements by providing them with an intuitive
business solution populated with information from publicly available sources.
This Policy is intended to inform you about:
 What is the personal data which Truvity processes;
 Data subject’s right and the information they should be aware of;
 Definitions and abbreviations.
1. Personal data - as defined in Article 4(1) of the GDPR. Truvity processes personal data from
publicly accessible registers – e.g. in Bulgaria these will be the Commercial Register, Bulstat Register,
Register of Persons Holding Senior Public Positions, etc. Truvity processes the data available in these
registers- names, position, address, contact details, data on property holdings, etc;
2. Controller - as defined in Article 4(7) of the GDPR. Truvity is the controller in the case at hand;
3. Product(s) - a database of information about individuals which, through the use of software
products, can be searched according to specified criteria. The Controller populates the database using
various public sources. The results of each search are provided in a compact and user-friendly;
4. Processing - as defined in Article 4(2) GDPR. Processing is any operation or set of operations
performed upon personal data or a set of personal data, whether or not by automatic means;
5. Data subject - any alive natural person whose personal data is processed by the Controller;
6. Publicly available sources - the sources of information available on the internet (including public
registers such as the Bulgarian Commercial Register, sanctions lists, websites, etc.); Truvity is working
only with public sources and these are the only sources where it collects the personal data from;
7. GDPR- Regulation (EU) 2016/679;
8. CPDP - Commission for Personal Data Protection;
Truvity’s processing

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What personal data does Truvity process?
 Names;
 ID;
 Age;
 Contact details (e.g. email, address and telephone);
 Location where the person is based and/or operates their business;
 Information on:
o the person's participation in the management body of a company, NGO or other legal
o details of any shareholding; and
o information on whether the person is the beneficial owner.
 Information whether the person or a member of his or her family is a prominent political figure;
 Information about related persons;
 Hyperlink and/or short excerpt of publications about the person in media and other websites;
 Other publicly available information about the subject
Where does Truvity obtains from the respective personal data?
Truvity collects the personal data only from public registers and publicly accessible sources such as the
Bulgarian Commercial Register, the Register of the Civil Status, the Register of Holders of Senior Public
Positions, etc.) or other sources that provide free access to information. Truvity is working only with
publicly available sources.
Who has access to the data?
The recipients of the personal data are the users of Truvity - for example, banks, insurers, etc. The use of
the Product is paid (on a subscription basis), and is done through a user profile created for each User.
Anyone who has paid the appropriate fee will be able to use Truvity and search the database accordingly.
Truvity can also provide access to customized data sets upon payment by the client.
Types of data processing
Truvity does the following processing: 
 collecting,
 synthesizing,
 storing 

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Truvity’s purposes
The purposes of the Data Controller in relation to data processing are to create, maintain and operate the
Product as part of the products and services offered by the Company in the course of its commercial
activities for profit and to meet consumer needs. In general, Trivuty is monetizing the publicly available
information, who can be accessed by anyone. Truvity is making this access easy and client friendly.
Truvity’s legal grounds
Truvity is processing the personal data on the grounds of its legitimate interest – Art. 6(1)(f) GDPR. Trivity
has performed a balancing test and justified its legitimate interest. The latter does not infringe the
legitimate interests and rights of data subjects.
Data processing via Truvity’s website
In addition to the Truvity's business objectives, the Truvity offers its products via its website - or via designated publicly available market places. The functioning of the website and its
use by users involves additional processing of personal data.
In case a website user aims to be a registered user on the website:
 The user should fill in the electronic form available on the Website, which collects the following
personal data: Names, Telephone, E-mail address, Company the user works for/represents,
additional relevant information sent by the user upon her choice;
The collection of this data is necessary in order to enter into contractual relations in connection with the
use of the Product and their performance. In case the client is purchasing data sets via a marketplace,
the respective market place is the one who is choosing what data to collect from the client.
Demo version of the Truvity’s product
In case a client requests a demo access, Truvity will request the following information: Names, E-mail
address, Phone number, Company the client works for/represents, additional information the client has
chosen to share
On the Truvity’s website there are plugins/buttons from the social networks Facebook, Twitter and
LinkedIn. When a user clicks on the icon, she agrees to communicate with the respective platform and to
transmit information (e.g. IP address) to the respective service provider.

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By activating such a plug-in, the respective social network receives information that the browser has
searched for the corresponding page on our website. This also applies if the user does not have an
account or is not currently logged in. The information (including the IP address) is transmitted directly
from the browser to the server of the respective social network and stored there.
Other information
This privacy policy and terms of use of the website apply only to the data collected online on the website.
They do not apply to information otherwise provided by data subjects or posted by them on pages to
which the Website links.
Truvity does not process special categories of personal data and personal data of children. Truvity shall
not be held liable for the voluntary provision of such data by subjects, including when completing the
communication forms on the Website.
Truvity will not transfer clients’ personal data to third parties outside the EU or to an international
organisation without first obtaining their consent.
Retention periods - the data that Truvity has collected through its website (form fillers and cookies) will be
retained for the period for which the client is in a contractual relationship with the Company or for the
period of validity of the relevant cookie.
The personal data that the Company processes for the purposes of its activities is stored for the period of
each update - usually a few days. When the Truvity database is updated using information from public
sources, the personal data is also updated. Clients who purchase data sets acknowledge and agree that
the data in the data sets is as it is. It is clients’ responsibility to update it or request Truvity to update it.
Truvity is not oblige to update the data set unless this has been agreed in advance with the client.
Data subject rights
As a data subject, you have the following rights. You can make requests, enquiries and complaints to us
at any time freely using the contact details above or the Ask a Question functionality on the Website.
 Access to your personal data
You have the right to request information from Truvity as to whether personal data relating to you is being
processed. If it is processed, you have the right to receive information about it, its processing, storage
and how it is collected.

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 Right to rectification and update of personal data
If your personal data is inaccurate, outdated or incomplete, you have the right to update or correct it by
making a request to us.
 Right to be forgotten
In certain circumstances, such as if your personal data has been unlawfully processed or you have
withdrawn your consent (if the processing of your personal data is based on consent) and there is no
other basis for continuing to process it, you have the right to require us to delete your personal data.
 Right to restriction of the use of personal data
In certain circumstances, such as storing more than the minimum necessary of your personal data, you
may request a restriction of the processing of your personal data.
 Right to data portability
If your personal data is processed by automated means with your consent or for the performance of our
contractual relationship, you have the right to request that we provide your personal data in a machine-
readable format for transfer to another data controller.
 Right to file a claim
Being a data subject you have the right to lodge a complaint regarding the processing of your personal
data with the CPDP. You can send such a complaint through the Company or directly to the CPDP using
the following contact details:
1592, Prof. No. 2 Tsvetan Lazarov Str., Sofia
E-mail: [email protected]
You can contact with Truvity at. Sofia, 1303, Vazrazhdane district, Blvd. "Hristo Botev" № 117

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