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Personal Data Protection Policy

Personal Data Protection Policy

Personal Data Protection Policy

No. 1/02.2026

/for users of the platform https://sportclub.bg/bg

owned by

“SPORTS SOFTWARE” Ltd., UIC 207779428

I. INTRODUCTION

This document aims to inform users of https://sportclub.bg/bg about our policy on the storage and protection of personal data of Users, Visitors and persons using the Platform, and how we safeguard the Personal Data we access in connection with the use of our services.

“SPORTS SOFTWARE” Ltd. processes personal data of Users and Visitors in strict compliance with Regulation (EU) 2016/679 of the European Parliament (General Data Protection Regulation, “GDPR”), the Bulgarian Personal Data Protection Act and other applicable legislation, as well as this personal data protection policy.

Definitions:

“Personal data” means any information relating to an identified or identifiable natural person or legal entity;

“Processing” means any operation or set of operations performed on personal data or on sets of personal data by automated or other means;

“Controller” means a natural or legal person which, alone or jointly with others, determines the purposes and means of processing personal data; under this policy these are the sports clubs that enter and manage data relating to their athletes and competitors through the software;

“Processor” means a natural or legal person that processes personal data on behalf of and on the instructions of the controller; under this policy this is “SPORTS SOFTWARE” Ltd.;

“Recipient” means a natural or legal person, public authority, agency or other body to which personal data are disclosed, whether or not a third party;

“User” means a natural person who uses the Platform as a service user and has completed the relevant registration;

“Visitor” means a natural person who is a service user and has completed the relevant registration on the Platform;

“Data subject” means a user or visitor of the Platform;

“Platform” means the website https://sportclub.bg and its subdomains and related Internet addresses for accessing the service, and other subsites;

“epay.bg” means the electronic payments system at www.epay.bg.

Scope:

This document applies to the relationship between “SPORTS SOFTWARE” Ltd., on the one hand, and users and visitors of the Platform, on the other. The policy aims to inform data subjects of their rights in accordance with Article 12 et seq. of Regulation (EU) 2016/679.

Processing of personal data between “SPORTS SOFTWARE” Ltd. and sports clubs that are also personal data controllers is governed by a data processing agreement concluded in accordance with Article 28 of Regulation (EU) 2016/679.

Information about “SPORTS SOFTWARE” Ltd.:

As a processor of personal data, “SPORTS SOFTWARE” Ltd., UIC 207779428, with registered office and management address: Sofia, “Mladost” district, residential complex Mladost 2, block 235, entrance 1, floor 10, apt. 37, processes personal data on behalf of and on the instructions of the personal data controllers — sports clubs using the Platform.

With respect to personal data processed in connection with visits to the Platform, submission of enquiries via the contact form, as well as for the purposes of administration, maintenance and security of the Platform, “SPORTS SOFTWARE” Ltd. acts as personal data controller.

Contact details of the data protection officer:

The data protection officer of “SPORTS SOFTWARE” Ltd. is Martin Enev, address: Sofia, email: sales@sportclub.bg

Categories of personal data:

“SPORTS SOFTWARE” Ltd. collects the following categories of personal data directly from data subjects:

Upon registration of Users:

When a data subject registers and creates their own user profile, they voluntarily provide the following categories of personal data: telephone number, name, email address, username, password, date of birth, IP address. The cookie policy of “SPORTS SOFTWARE” Ltd. clarifies what additional information may be processed.

The data subject registers and creates a user profile with different possible roles — coach, athlete, parent, etc. When the User registers as a sports club, amateur group or coach, each provides the following data: Coach — provides the Controller with the following categories of personal data: name, date of birth, address, telephone number, email address, username, password, photograph. When the User registers as an athlete, they provide the Controller with the following categories of personal data: name, telephone number, email address, username, password; this is also the scope of information provided by parents. The natural person registering an amateur group provides the Controller with the following categories of personal data: name, date of birth, address, telephone number, email address, username, password, photograph.

“SPORTS SOFTWARE” Ltd. has integrated epay.bg as a payment instrument for transfers to a User registered as Coach, Sports Group or Sports Club. Completing the registration form requires information on: bank account number, bank account holder, copy of ID card and proof of use of the bank account. These personal data are not processed by the Company. They are received from epay.bg via an encrypted connection, and “SPORTS SOFTWARE” Ltd. has no control over and does not access such personal data in any way. The Company does not store the bank card number or its three-digit security code of the User. These data are transmitted to and stored by epay.bg. For more information on the grounds and purposes of processing by epay.bg, please visit their official website. epay.bg processes personal data as an independent controller in accordance with its own privacy policy and applicable law.

Visitors to the Platform:

Visitors may browse the Platform and use its functionalities according to the access granted to them after creating a user profile.

“SPORTS SOFTWARE” Ltd. does not actively and deliberately collect personal data from Visitors such as names and email addresses. Technical data may be processed, including IP addresses, log files and device data, where necessary for the functioning, security and prevention of misuse of the Platform.

When submitting an enquiry:

When a data subject sends an enquiry to the Controller through the contact form, they provide name, email address and a comment relating to their enquiry.

Marketing purposes:

The Controller does not process personal data for marketing purposes.

Where personal data have been provided by the data subject to the Controller without a legal basis under Article 6(1) of Regulation (EU) 2016/679 or in breach of the principles in Article 5 of the same Regulation, within one month of becoming aware the Company shall return them, and where this is impossible or would require disproportionate effort, delete or destroy them. Deletion and destruction shall be documented.

Processing of personal data relating to minors

The Platform may be used by minor athletes, including persons under the age of 18. In such cases personal data of minors are processed only after consent has been provided by a parent or legal guardian, while registration and profile management are carried out by a parent, legal guardian or the respective sports club within its contractual relationship with the Company.

“SPORTS SOFTWARE” Ltd. does not deliberately process children’s personal data beyond what is provided by personal data controllers (sports clubs).

Data subjects whose personal data are processed:

The Controller processes personal data of the following categories of data subjects:

  • Users of the Platform;
  • Visitors to the Platform;
  • Business partners.

Purposes and legal basis for processing:

“SPORTS SOFTWARE” Ltd. processes personal data for the following purposes:

  • for entering into and performing a contract to which the data subject is party;
  • for compliance with a legal obligation applicable to the Controller;
  • for the protection of legitimate interests of the Controller, including administrative activities such as legal and information services and consumption analysis, information security and others.

“SPORTS SOFTWARE” Ltd. processes personal data of data subjects on the following lawful bases:

  • processing is necessary for the performance of a contract to which the data subject is party, or to take steps at the request of the data subject prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation applicable to the Controller. Such an obligation may arise from an explicit request from law enforcement authorities such as the Ministry of Interior, State Agency for National Security, prosecution services and others;
  • the data subject has given consent to processing for one or more specific purposes;

The Company may share personal data of data subjects with the following categories of recipients:

  • state bodies and authorities with enforcement powers where the Controller is legally obliged to disclose personal data;
  • business partners that assist the Controller as processors for maintaining information security and providing services related to the Platform, courier providers, law firms, accounting firms and others;
  • employees of the Controller who process personal data in accordance with their assigned official and/or employment duties under job descriptions and employment contracts.

“SPORTS SOFTWARE” Ltd. does not disclose your personal data to other companies or individuals outside the legal bases described in detail in this procedure without exception. An exception may be made only if explicit consent has been given for one or more specific purposes under Article 6(1)(a) GDPR; if disclosure is necessary under Article 6(1)(e) GDPR for the establishment, exercise or defence of legal claims and there is no reason to assume that you have an overriding legitimate interest in non-disclosure; if there is a legal obligation to disclose under Article 6(1)(c) GDPR and this is permitted by law and necessary for the performance of contractual obligations under Article 6(1)(b) GDPR.

Retention periods for personal data

“SPORTS SOFTWARE” Ltd. stores personal data in accordance with the principle of “storage limitation”. In particular, for the purposes above the Company will retain:

  • personal data of counterparties for periods in accordance with the general limitation period;
  • personal data contained in accounting records for periods laid down in the Accounting Act, Tax and Social Insurance Procedure Code and other legislation;
  • personal data in the user profile until the User deletes them or requests the Controller to delete them;
  • where the basis for storage ceases to exist.

Rights of data subjects

Data subjects whose personal data are processed by the Controller have the following rights:

  • right of access to personal data, including obtaining a copy;
  • right to request rectification of their data;
  • right to request erasure of their data (“right to be forgotten”);
  • right to request restriction of processing;
  • right to object to processing;
  • right to lodge a complaint with the Commission for Personal Data Protection (CPDP) where they consider that processing infringes applicable law.

These rights may be exercised by sending an application in electronic form to the email of the data protection officer, signed with a qualified electronic signature under the Electronic Document and Electronic Certification Services Act, or by submitting the same in writing at the Company’s office.

Updating and amendment of this privacy policy

This Privacy Policy is current for users of the Platform. It was created in 05.2018 as the first text document. No subsequent amendments have been made.

Changes to the Privacy Policy may be required due to new Platform functionality or any changes to data registers or legal or administrative requirements. The current privacy policy can be found at https://sportclub.bg/en/privacy, and each amended document will be numbered with a serial number, slash and date of publication on the website.

This personal data protection policy applies to data processed by:

“SPORTS SOFTWARE” Ltd., UIC 207779428, represented by Martin Emilov Enev
Address: Sofia, “Mladost” district, residential complex Mladost 2, block 235, entrance 1, floor 10, apt. 37
Tel.: +359 884 721 701
e-mail: sales@sportclub.bg

Contact the data protection officer of “SPORTS SOFTWARE” Ltd.:

Attorney Borislava Aleksandrova
DPO@legaladvisor.bg