Privacy Policy

Introduction

Welcome to the Open Sofia Foundation (OSF) privacy notice concerning the Open Sofia online platform (called « the Platform » in the rest of the document).

The Open Sofia Foundation respects your privacy and is committed to protecting your personal data in compliance with the 2018 GDPR (General Data Protection Regulation).

This privacy notice informs how your personal data is used when visiting the Platform (regardless of where you visit from). It also explains your privacy rights and how to manage them.  You will learn how the Open Sofia Foundation collects and processes your personal information, including any data you provide when registering as a user and interacting with service providers.

Please note that the Platform is not intended for children. The Open Sofia Foundation does not knowingly collect data relating to children.

This privacy notice should be read in conjunction with the general rules established by the GDPR.

I) Using the Platform without creating a user profile

Most of the Platform’s content is available to view without creating a user profile. 

Google Analytics

When browsing the Platform you should be aware that: 

  • The Platform uses Google Analytics for statistical and analytical purposes.
  • An IP is anonymized and the Platform accepts Do Not Track (DNT) requests, as well as opt-out from tracking.
  • The Information collected is: 
    • links followed
    • page scrolling depth 
    • actions related to submission forms

You have the possibility to opt-out of Google Analytics by clicking on the following link:

Opt-out of Google Analytics

You can also avoid Google Analytics by using the Do Not Track feature of your browser.

Embedded content

Articles on the Platform may include embedded content (e.g., videos, images, articles, etc.) from other websites or social networks. 

Embedded content behaves in exactly the same way as if the visitor was using the website or social network of origin. These websites may use cookies, collect data about you, embed third-party tracking, or monitor your interaction with the embedded content.   It may include tracking your interaction with the embedded content through your logged-in account of that website (for instance, if you are logged in to YouTube and watching a video embedded in the Platform).

The Platform uses a Facebook Feed plugin to display the Open Sofia Foundation feed from Facebook. As a result, the Platform sends requests to Facebook’s servers in order to display images and videos. These requests make your IP address visible to Facebook, who may use it in accordance with their data privacy policy. The Platform does not collect any data from Facebook feeds.

Facebook’s privacy policy applies to any Facebook data that appears on the Platform.

If a user believes a breach of privacy has occurred in a Facebook feed, the user should refer to Facebook and follow Facebook’s procedures for corrective action.

Use of Contact Forms

The Contact us form is required to contact the Open Sofia Foundation. This form integrates a CAPTCHA feature to avoid spam.

The CAPTCHA feature communicates with Google to validate the user under the Google Privacy policy and Google CAPTCHA

When using CAPTCHA features, the user hash from an IP address is stored in a database.

Please note that a «user hash» is an anonymized string created from your IP or email address.

The CAPTCHA feature also ensures that humans, not robots, are utilizing the platform. For instance, directly messaging employers and real estate agents, or registering for an event. 

The reCAPTCHA plugin collects: 

  • the date of action
  • the language your browser is set to
  • any plugins you have installed in your browser
  • javascript objects on the page you’re navigating
  • all cookies placed on your device by Google over the last 6 months
  • number of  mouse clicks made on that page (or touches if on a touch device)
  • the CSS information for that page

If you contact the Platform team via the contact form, the following information is collected to allow for exchanges:

  • your email address
  • name 
  • the content of the message

When contacting us through the contact us page, you may opt to save your name, email address, and website in cookies. This is for your convenience and eliminates the need for you to fill out your details again when sending a message or leaving a review. These cookies last for a maximum of one year.

To find out more about what data has been collected by the Platform, please use the following link: contact us.

II) Using the Platform as a registered user

User Profile

To access some features (full information on jobs, real estate, exchanges with other users, etc.), you must create a user profile. 

The Platform collects your user profile data only with your consent. You grant consent either by creating a user profile from your email address or from your social login from Facebook or Linkedin.

In addition to information collected by default, as indicated in the previous section, the Platform collects information necessary to use the advanced features of the Platform.

When creating your profile through email, compulsory user information includes:

  • first name
  • last name
  • valid email address
  • social profile avatar
  • unique identifier

If you are using your social profile to register, the Platform collects the link to your profile through the OneAll plugin to establish communication with your social profile. In this respect, the Platform follows the OneAll privacy policy.

When you log in, we establish cookies to save your login information and screen display choices. 

  • If you do not logout, login cookies last for two days and screen options cookies last for a year. 
  • If you select “Remember Me,” your login remaioutputns for two weeks. 
  • If you log out of your account, the login cookies are removed.

This data is used to create your user profile for use of all the features of the Platform. Want to delete your account and data? Click the following button, you will lose access to your account immediately and your data will be erased within 48 hours.

Jobs, real estate, and events sections

Based on the actions of your user profile, the Platform may also request the following information:

  • profession – necessary to use the jobs section
  • services reserved – necessary to use the events section
  • forms used – necessary to exchange messages in the job, real estate, and events sections

Non-compulsory user information:

  • address
  • localization

Please note, the Platform collects and stores messages exchanged with other users or service providers (jobs, real estate, promotions, etc.).

Further information automatically collected during the use of the Platform

When uploaded images to the Platform, you should avoid images with embedded location data (EXIF GPS). Users of the Platform can download and extract any location data from images on the website.

Should you wish to review an ad or evaluate a service provider in the jobs, real estate, or events, the Platform collects and stores:

  • contents of the evaluation or review
  • time and place of review
  • IP of origin

Please note, the Platform uses cookies to track the origin of reviews to avoid spam, as well as prevent abusive behaviors. Reviews are monitored by OSF and abusive messages will be removed.

In order to avoid abusive behavior, specific archiving rules apply to reviews and evaluations of services. The information is stored for 12 months after the deletion of your profile.

JOBS SECTION: The CV and information provided in the form (“applicant information”) is stored by the Platform and sent to an employer under the employer’s privacy policy and GDPR compliance. All exchanges with a company or person posting a job offer are stored for a period of 12 months, even after the deletion of your user profile. This will only be used in cases of a legal conflict between you and the employer concerning the specific job offer. 

REAL ESTATE: The property owner/agent will receive an email copy of your message and information provided in the Open Sofia form. All exchanges between you and the property owner/agent will be stored for 12 months, even after the deletion of your user profile. This will only be used in cases of a legal conflict between you and the other party in the specific commercial deal.

Access to your personal data

If you have a user profile on the Platform, you can request a file of the personal information we hold about you, including any data you have provided. You can also request that we erase your personal data. This does not include data we are obliged to keep for administrative, legal, or security purposes.

You may contact us to delete your account and your personal data collected by the Platform will be deleted after 7 days. However, personal data collected within the last month for article reviews, jobs, and real estate ads will be kept for 2 months to avoid willful abusive behavior.

III) Using the Platform as a service provider

As a person promoting products or services on the Platform, you enter into a commercial/contractual relationship with the Open Sofia Foundation. 

Thus, the information included on the Platform about your services, events, or products is not subject to privacy rules of the 2018 GDPR. This includes information such as name, email, or telephone number necessary for users to contact you. 

To publish ads or information about your products or services, please use the following page to learn more about a partnership with the Open Sofia Foundation.

All information given by a service provider is stored for one year after the advertisement’s expiration date. If an ad is found to contain deliberately false information, or to be a scam, the information collected may be provided to judicial authorities or the police in the context of a civil or criminal investigation.

IV) Competent courts

Should any conflict arise between the Open Sofia Foundation and a user, content provider, or service provider, the applicable law is Bulgarian law, regardless of the location of the user, content provider, or service provider.

The competent courts will be the Bulgarian courts located in Sofia, Bulgaria.

Last update: 28 March 2020 

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Cookie Policy

Introduction

The Open Sofia Platform may use cookies when you visit our website opensofia.org to help customize the Platform and improve your experience. 

We reserve the right to make changes to this Cookie Policy at any time and for any reason. We will alert you about any changes by updating the “Last Update” date of this Cookie Policy. Any changes or modifications will be effective immediately upon posting the updated Cookie Policy on the Platform, and you waive the right to receive specific notice of each such change or modification. 

You are encouraged to periodically review this Cookie Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Cookie Policy by your continued use of the Platform after the date such revised Cookie Policy is posted. 

Use of cookies

A “cookie” is a string of information which assigns you a unique identifier that we store on your computer. Your browser then provides that unique identifier to use each time you submit a query to the Platform. We use cookies on the Platform to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into the Platform, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how the Platform is being used and improve your user experience. 

Types of cookies

The following types of cookies may be used when you visit the Platform:

Advertising Cookies

Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to the Platform, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you. 

Analytics Cookies

Analytics cookies monitor how users reached the Platform, and how they interact with and move around once on the Platform. These cookies let us know what features on the Platform are working the best and what features on the Platform can be improved. 

Security Cookies

Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.

Site Management Cookies

Site management cookies are used to maintain your identity or session on the Platform so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

 

Control of cookies

Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Platform. 

For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies.

In addition, you may opt-out of the “Non Necessary” cookies through the Cookie Settings in our page.

Privacy Policy

For more information about how we use information collected by cookies and other tracking technologies, please refer to our Privacy Policy. This Cookie Policy is part of and is incorporated into our Privacy Policy. By using the Platform, you agree to be bound by this Cookie Policy and our Privacy Policy.

Contact us

If you have questions or comments about this Cookie Policy, please contact us.

Last update: 29 March 2020