Demana Invest – Multifamily Commercial Retail

When you use the services of Demana Invest Ltd., you entrust us with your personal data. This privacy policy will help you understand what kind of data we collect, the reasons we collect it for and what we do with it. This is important and we hope you will take your time to read the following information carefully. In case you have any questions regarding confidentiality, please do not hesitate to contact us by sending email enquiry or call us at +359 878 767 000. What is personal data? According the General Data Protection Regulation (“GDPR"), personal data is defined as: “Any information relating to an identified or identifiable natural person (“Data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person". Why does Demana Invest Ltd. collect and store personal data? In order to provide you with our services, such as preliminary information and consultations regarding properties in Bulgaria, mediation in the course of purchase, sale or rent of a real estate property, assistance with the preparation of the required documents and notarization of the deal, as well as after-sale services, we need to collect your personal data. This data serves for the purpose of our correspondence with you prior to signing a contract, or for the purpose of us providing any information you require, identification prior to signing a mediation contract, in the course of preparing documents related to rental, purchase or sale contracts, marketing activities or advertisement. We guarantee that the information we collect and use is essential for one or more of the above said purposes and does not aim at damaging your privacy or the inviolability of your personal life. Before sending any communication of advertising or marketing nature to you Demana Invest Ltd. will ask for your explicit consent to receive such communication. What categories of personal data we collect and process? The categories of personal data, we process are as follows: your full name, phone number, email, date and place of birth, citizen identification number, permanent and present address, data from your ID document – number and date of issue, bank account details, income, IP address. The special categories of data we process are as follows: marital status and details regarding any existing marriage. Your personal data, as our clients, we receive online or offline, on the grounds of your voluntary consent, on the basis of a contract signed between you and us, or when required by law. The personal data we collect will be used solely for one or more of the following purposes: • In order to provide information you required; • Preliminary correspondence before signing a contract; • Signing a mediation contract; • Identification in the course of preparing documents for the signing of a contract; • Identification in the course of preparing documents for the purpose of signing a rental- or purchase/sale contract; • Marketing and/or advertising information; • Preparing personalized advertisements, remarketing and measurement of results The grounds on which we are entitled to process your personal data is: Your consent; implementation of a contract with you or our intent to enter into such contract; the processing is also required to comply with a legal requirement of ours or for the purpose of protecting your interests or third party interests, as well as to protect our own legitimate interests. The following organizations may receive your personal data (provided it is necessary): • The banking institution working with us on your transaction; • The lawyer we work with regarding your transaction; • The notary public we work with regarding your transaction; • The translator we work with regarding your transaction; • The insurance company we work with regarding your transaction; • The currency broker we work with regarding your transaction; • Our accounting company; • Eurostill Trade Ltd.and Metron S.A. for their offers that we advertise on our website; Social networks Your access to social networks such as Facebook, Google, YouTube, Twitter, and others, is through a separate registration and acceptance of the general terms and conditions of these sites. Demana Invest Ltd. is not responsible for the protection of your personal data when accepting these terms and conditions. Please take a closer look at the general terms and conditions of these sites. Consent: By agreeing to accept the present Confidentiality Notice, you are giving us your consent to process your personal data strictly for one or more of the above said purposes. Such consent is necessary in order for us to be able to process both types (regular and special) personal data, but the consent needs to be an explicit consent. At all times when we request consent for special (sensitive) personal data, we will explain the reasons for, and manners in which such information will be used. Transfer of personal data to a non-EU country or to an international organization Demana Invest Ltd. does not intend to transfer your personal data to third parties without informing you in advance and securing your relevant consent. If transferring data to a non-EU country we will make sure that the company has signed up to Privacy Shield. Data retention period: Demana Invest Ltd. will store your personal data in the following manner: as a paper copy and/or online in its information database for the following duration: • All documents, related to the preparation of signing a real estate transaction – 5 years • All documents, related to the notarization of the transaction before a notary – 10 years • All documents, data and information collected as required by the Law for Measures Against Money Laundering – 5 years • All remaining carriers, with the exception of the above said, including your own voluntary Consent for marketing purposes and/or advertising information – 5 years Your rights as Data subject are as follows: At all times while we collect or process your personal data, you, in your capacity of Data subject, have the following rights: • You may require a copy of your personal data from Demana Invest Ltd. and right to access your personal data at any time; • You are entitled to request from Demana Invest Ltd. to provide you with your personal data in a manner suitable for transfer to another personal data controller, or to ask us to do it for you without any hindrance from us; • You are entitled to request from Demana Invest Ltd. to correct, without any undue delay, any of your personal data that is inaccurate, as well as any data, that is no longer up-to-date; • You are entitled to request Demana Invest Ltd. to delete your personal data without undue delay in any of the following cases: – the personal data are no longer required for the purposes they were originally collected for; – when you have withdrawn your consent; – when you have objected against the processing, – when the processing is unlawful; – when the personal data must be deleted for the purpose of complying with a statutory requirements under the EU law or the law of a member-country, which is applicable to us in the capacity of personal data controller; – when the personal data have been collected in relation to the provision of information society services. • We are entitled to refuse to delete your personal data on one of the following grounds: – while exercising the right to free speech and right to information; – for the purpose of our compliance with a legal requirement or the performance of an assignment in public interest, – while exercising official powers which were granted to us by you for the purpose of the specific entering into a real estate transaction; – by reasons of public interest in the sphere of public health; – for the purpose of archiving in public interest, for statistical purposes, as long as a deletion would seriously impede or make impossible the achievement of the purposes of this processing; – or for the establishment, exercising or protection of legal claims. • You are entitled to request from Demana Invest Ltd. to restrict the processing of your personal data, and in such case the data will only be stored, but not processed. Our refusal to restrict such processing will only be provided in writing and we are under obligation to motivate such refusal with a lawful reason; • You are entitled to withdraw your consent for the processing of your personal data at any time with a specific request sent to Demana Invest Ltd.; • You are entitled to object against specific types of processing, such direct marketing (unwanted advertising messages); • You are entitled to object against the automated processing, including profiling; • You are entitled to not be subject of decision based solely on automated processing, including profiling; • In case we need to use your personal data for a new purpose not part of the present notification of confidential treatment of personal data, we will serve you a new confidentiality notice and when and where necessary, we will ask for your consent for such new processing. You are entitled to submit a complaint to the supervisory authority: You are entitled to submit a complaint directly to the supervisory authority, the supervisory authority for Demana Invest Ltd. being: Personal Data Protection Commission Address: city 1592 Sofia “Prof. № 2 Tsvetan Lazarov blvd. webpage: www.cpdp.bg In case you wish to submit a complaint regarding the processing of your personal data through Demana Invest Ltd., you can do so using the contact details of Demana Invest Ltd. or directly to Data Protection Officer using the contact details below. Policy for voluntary settlement of disputes: Our policy is to voluntarily resolve any disputes that may arise regarding the processing of your personal data and for that we would be happy if you contact firstly our Data Protection Officer, before submitting a direct complaint to the supervisory authority. Send us your request to info@demanainvest.com How we use your personal data? The present confidentiality notice describes in detail the purposes and reasons for the collection and processing of your personal data, including the use of “cookies". We will not sell your personal data to third parties, and we will not transfer them in order to acquire any benefit. If necessary, Demana Invest Ltd., can transfer your personal data to our subcontractors, which have signed an appropriate contract with us. All third parties that can receive your data have undertaken before us the obligation to protect your data in a safe, reliable manner and to use it only for the purpose of performing the obligations they undertook before us. When they no longer need your data to perform their obligations they will have detailed instructions regarding their destruction in compliance with the approved and effective procedures of Demana Invest Ltd.. When it is necessary to provide special personal data to a third party, we will only do so after obtaining your consent (unless the law requires otherwise). The recipients of your data can also be state bodies such as the National Revenue Agency, the National Insurance Institute, and such data is provided to them in compliance with specific and clear legal obligations. How we store and protect the personal data we collect? Demana Invest Ltd. will process (collect, store and use) the information you provided in a manner consistent with the General data Protection Regulation and the Personal Data Protection Act applicable in Bulgaria. We will always aim to maintain the information accurate and up-to-date. We will not store your information longer than necessary for the completion of the specific purposes it was collected for and of which you have been notified herein. Some of the information retention periods are subject to legal requirements for keeping documents and information for minimal periods of time, such as the Accounting Act or the Law for Measures against Money Laundering. We will undertake all possible technical and organization measures to ensure the protection of your data from unauthorized access, such as encryption, anonymization, masking and deletion after the expiry of the retention period. How can you find out what personal data we have about you and how we process them? At your request Demana Invest Ltd. will provide an answer regarding what personal data we store and the manner of their processing.Please, send your request at info@demanainvest.com At your request Demana Invest Ltd. will provide an answer regarding what information we hold about you, the manner of its storage and processing. In case we hold any personal data about you, you can request the following information: • Contact details of the organization which processes, or on behalf of which your personal data is being processed. • Contact details of the Data Protection Officer. • The purposes of the processing; • The legal grounds for such processing; • The respective categories of personal data, which are being processed; • The recipients or the categories of recipients to whom they have been or will be disclosed; • If the grounds for the processing are Demana Invest Ltd.’ or third parties’ legitimate interest, you can ask further information about such interest. • The planned retention period of the personal data; • Further details regarding your rights to request a correction or deletion of personal data or restriction of the processing of personal data, as well as to make an objection against such processing; • Information about your right to withdraw your consent at any time; • Details regarding your right to complain to a supervisory authority; • Information whether the provision of personal data is obligatory or a contractual requirement, or a requirement, necessary for the signing of a contract as well as whether you are under obligation to provide the personal data and the possible consequences of the inability to provide such data. • The source from which your personal data was collected, in the cases when they have not been collected directly from you. • All details and information on the existence of automated decisions, such as profiling and any relevant information about the respective logic applied by such operations, as well as the meaning and the expected consequences of such processing. How can you obtain access to the data of yours that we process? You need to send a request directly using the contact details of the Data Protection Officer. To certify your identity you will need to: indicate your full name and email address, as well as to confirm your email address by pressing the link that will be sent to the contact email you provided us with. Location: Country: Republic of Bulgaria Address: city Sofia-1407,office 4-5, № 81 James Boucher Blvd. Phone: +359 0878 767 000 email: info@demanainvest.com web: www.demanainvest.com Contact details of the Data Protection Officer: You can contact our Data Protection Officer at: Email: info@demanainvest.com Phone: +359 0878 767 000

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Cookies are small text files, created by the website visited, that contain data. They are stored on the visitor’s computer to give the user access to various functions. Both session cookies and non-session cookies are used on this website (the “Site”). A session cookie is temporarily stored in the computer memory while the visitor is browsing the website. This cookie is erased when the user closes their web browser or after a certain time has passed (meaning that the session expires). A non-session cookie remains on the visitor’s computer until it is deleted.

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Last changed 29.09.2018 The present GENERAL TERMS AND CONDITIONS govern the relations between Demana Invest LTD , hereinafter: “DEMANA INVEST” or „Agency“, from one side, and the Users of web-pages and services at the domain http://demanainvest.com (hereinafter: Users), on the other side. DEMANA INVEST is a company registered under the Commerce Act of the Republic of Bulgaria with UIC 204997578, with registered office and address of management: city Sofia-1407, district Lozenets,Offece 4-5, 81 James Boucher Blvd., email: info@demanainvest.com, phone number: +359 0878 767 000. Until 25.05.2018, the AGENCY, which is a registered personal data controller, according to Certificate № 123595/04.10.2013 issued by the Commission for Personal Data Protection, has been processing Users’ personal data according to the Personal Data Protection Act. As of 25.05.2018, the AGENCY is processing the personal data of Users, by applying all applicable standards for personal data protection as per Regulation (EU) 2016/679 of the European Parliament and of the Council from 27th of April 2016 regarding the protection of individuals in relation to the processing of personal data and in relation to the free movement of such data and the revocation of the Directive 95/46/ЕC. The AGENCY respects the privacy of the individuals and will make every effort to protect the personal data of individuals against unlawful processing through the application of technical and organizational measures for personal data protection, which measures fully conform to the current technological advancements and provide a level of protection corresponding to the processing-related risks, and the nature of the data, subject to protection. Further information on the types of personal data processed by the AGENCY, the purposes of the processing of personal data, personal data storage period, as well as any other information in compliance with the requirements of article 13 of Regulation (EU) 2016/679 is available at Privacy Policy of Demana Invest LTD, published on the internet page of the company and available at its offices. Please read carefully the following General Terms and Conditions before using the information and commercial services provided by the site of http://demanainvest.com. By visualizing http://demanainvest.com each User automatically undertakes to comply with the following terms as described further below. Should you have any questions please do not hesitate to contact us at +359 0878 767 000 or email info@demanainvest.com. The present terms contain information about the activities of DEMANA INVEST and the general terms for using the services, provided by DEMANA INVEST, by regulating the relations between us and each of our users. By visiting our site as well as by pressing any button on the said site it will be deemed that you are familiar with the General Terms and Conditions and you undertake to comply with them. The present General Terms and Conditions can be amended at any time by DEMANA INVEST in order to improve the quality of the provided services including by introducing new ones. In such case the amended General Terms and Conditions will be published on this web-site with new “Last change" date in the upper part and shall enter into force on the date of their publication. Such changes can also result from changes in the Bulgarian legislation. DEMANA INVEST reserves the right to change the General terms and conditions at any time and at its own discretion. The changes will be published on the official page of the site and shall come into force from the data of their publication. The users of the site services are to check the updates of the General Terms and Conditions and adjust their actions accordingly. The provisions of the acting Bulgarian legislation shall apply to all matters not regulated by the General Terms and Conditions and the Bulgarian courts of justice shall be competent for the resolution of any possible dispute. The parties hereby agree that in case any of the provisions of the present General Terms and Conditions becomes invalid this shall not result in the invalidity of the entire contract or any other parts thereof. Any clause that is found to be invalid shall be replaced by the imperative provisions of the law or the established practices. PROVIDED SERVICES art. 1. The services provided by DEMANA INVEST to the User represent information society services in the sense of the E-Commerce Act. art. 2 On its website DEMANA INVEST provides offers for sale or rent of real estate properties for the prices listed at the site https://www.bulgarianproperties.com. The offers have been provided by sellers, lessors, construction developers, investors, agencies and other parties in contract relations with Bulgarian Properties Ltd. art. 3 The information under art. 2 of the present General Terms and Conditions, that shall be provided to the User or to any other user, has the purpose of enabling DEMANA INVEST to assist the User in purchasing or letting a property. art. 4 All services provided by DEMANA INVEST and all relations between us and the respective client/s, shall be settled with a separate written contract which shall come into force when signed by the company, on one hand, and by the respective client/s, on the other side. For further information about the types and prices of the services we provide, please visit this page: INVESTMENTS of www.demanainvest.com art. 5 (1) The provision of real estate property offers by DEMANA INVEST on this website shall be deemed as an offer by the Agency to act as a consultant and to provide intermediation services for the purchase of purchase/sale of the respective property on offer, unless otherwise specified in the respective offer. art. 5 (2) Using the information according to art. 2 of the present General Terms and Conditions, the User undertakes to sign a protocol for views of properties made with the assistance of the Agency, as well as to sign intermediation contract with DEMANA INVEST for the purchase/letting of a property with the intermediation of the Agency. art. 6 (1) DEMANA INVEST has the right to send commercial messages to the User for the purpose of providing information and advertisements for its own goods and/or services or such offered by other business companies, to make enquiries on a range of matters, to perform polls and others, but only to Users who have expressly agreed to that. After the User has acquainted himself with Privacy Policy and has given his consent for the processing of the personal data, the User is entitled to receive commercial messages from DEMANA INVEST. art. 6 (2) The User shall be entitled to object against the sending of commercial messages by unsubscribing using the options provided or by sending an email to DEMANA INVEST. The User shall also expressly notify DEMANA INVEST in case he does not want any of the personal data he/she has provided to be subject to direct marketing. IDENTIFICATION art. 7. (1) DEMANA INVEST has legitimate interest to collect and process information about the Users on the grounds of their voluntary identification, provided in an informed manner. The information that can be used for identification of the person, can include the following personal data: name, surname, date of birth, address, phone number, email, IP address, as well as any other identification provided by the individual in the course of the identification, as well as data about the property sought by the individual – type, area, location, neighbourhood of the property, construction type. The information also includes any other data that entered, used or provided by the User in the course of using the Services provided by DEMANA INVEST. art. 7 (2) Any information provided by the User will be processed according to the Privacy Policy of DEMANA INVEST. art. 8 In the identification form, to be filled in by the User, DEMANA INVEST will indicate whether it is mandatory or not to provide certain data and the respective consequences of not providing such data. art. 9 (1) the User can identify himself/herself by filling in the respective identification e-form, accessible in real time (on-line) in Internet on the site of DEMANA INVEST and to express his approval of the present General Terms and Conditions and Privacy Policy. art. 9 (2) At the time of identification, the User makes an electronic statement in the sense of the Electronic Documents and Electronic Signature Act, thereby declaring that he/she is acquainted with the present General Terms and Conditions, accepts them and undertakes to comply with them. By its storage on the DEMANA INVEST server through common standard for transformation by technical means, enabling its reproduction, the electronic statement becomes an electronic document in the sense of the above said Act. DEMANA INVEST may store in the log-files on its server the IP address of the User, as well as any other information necessary for his/her identification and the reproduction of its electronic statement for acceptance of the General Terms and Conditions in case of a dispute. Тhe text of the present General Terms and Conditions can be accessed by internet from the site of DEMANA INVEST in a format allowing for its storage and reproduction. art. 9 (3) When filling in the identification form the User is obligated to present complete and true data about his/her identity (for individuals), the legal status (for legal entities) and any other data required by the e-form of DEMANA INVEST, as well as to update them within 7 (seven) days term of their change. The User declares that he agrees to provide the so-required personal data and guarantees that the data he/she has provided in the identification process is accurate, complete and true and that in case of change he/she will update it promptly. In case untrue data has been provided DEMANA INVEST shall be entitled, at its discretion, to suspend the provision of the services immediately and without advance notification. The above shall also be valid in case the provided services are being used in violation of the present general terms, the legislation of the Republic of Bulgaria or the generally accepted moral standards. art. 10 This site may contain links to other sites. These sites have been provided for your service and information and as such you can use them at your own responsibility. The contents of such sites is not related to DEMANA INVEST and we do not support this content, irrespective of whether we are partners with such sites’ owners or not. DEMANA INVEST rejects any responsibility for any damages or losses the Users may incur as a result of using such sites. DEMANA INVEST is not responsible for the contents of third-party sites, as well as for the existence of viruses or other harmful components of such sites. INTERMEDIATION AND SERVICES art. 11. (1) The Users use the interface of the DEMANA INVEST website in order to see the properties offered by DEMANA INVEST and to use the services offered by the company. art. 11 (2) The contract for the provision of a certain service is considered effective upon the signing of a written contract between DEMANA INVEST and the respective user. PRICES art. 12. (1) The prices of the properties offered by DEMANA INVEST, are those specified by the Users (sellers, lessors, construction contractors, investors, agencies or other parties working on the basis of contract relations with Demana Invest Ltd.), and DEMANA INVEST cannot be held responsible for any inaccurate and/or outdated prices announced by the User. art. 12 (2) The prices of the properties offered are in Euro and include VAT unless specifically stated that the price does not include VAT. art. 12 (3) DEMANA INVEST reserves the right to change at any time and without advance notification the prices of the published offers, however, such changes will not affect any contracts that have already been signed. RESPONSIBILITY art. 13. (1) DEMANA INVEST cannot be responsible for the truthfulness or up-to-date status of the published offers. DEMANA INVEST does not guarantee, and cannot be held responsible for anything resulting from using the site, or the reliability, accuracy or validity of the content, the description of properties and pictures, services or products, acquired as a result of the website’s use. art. 13 (2) You expressly agree that the use of this website is entirely at your responsibility and any damage caused to your equipment as a result of its use will also be at your expense. art. 13 (3) DEMANA INVEST rejects any responsibility regarding the content, marketing of products and services and their correspondence with specific purposes. You expressly agree that DEMANA INVEST will not owe any compensation for damages or losses (whether actual, subsequent, penal or others), damages or losses of any other kind whatsoever, resulting from the use of this website or the link to this site. DEMANA INVEST will not owe any compensation for any damage or error in the course of this site’s use, miss, interruption, defective operation, computer virus, theft or damages resulting from the use of information, opinions or other materials from this website. art. 13 (4) DEMANA INVEST does not guarantee that the functions contained in this website are free of errors, that the defects will be repaired or that the server providing the content, is free of viruses of other harmful components. art. 13 (5) You agree to safeguard, protect and hold DEMANA INVEST and their suppliers, employees, officers, partners, agents, licensees, harmless against losses, expenses, damages of any kind that may result from any breach of the terms and conditions for use of this website. You expressly agree that BULGARIAN PROPERTIES will not be responsible for any deformation, insulting or illegal behaviour by other users on the site or by third parties. art. 14 DEMANA INVEST is entitled to suspend the access to the website for certain mobile numbers, IP-addresses or e-mail addresses, which were used for systematic violations of the present General Terms and Conditions. INTELLECTUAL PROPERTY art. 15. (1) The intellectual property rights on any materials and resources on the DEMANA INVEST site, including, but not limited to, any published texts, pictures, photos, illustrations, graphics, computer programs, available databases, as well as any information that is uploaded to the site, are subject to protection under the Copyright and Similar Rights Act, belong to DEMANA INVEST or to the respective specified person who has granted DEMANA INVEST the right to use them, and cannot be used in violation of the acting legislation. art. 15 (2) The trademarks (both registered and non-registered), published on the website, are protected by the applicable laws. Nothing contained in the present General Terms and Conditions shall be interpreted as granting consent for the use of the DEMANA INVEST trademark. art. 15 (3) The User’s right of access does not include the right to use, copy or reproduce information, subject to intellectual property rights, unless the information is insignificant in terms of volume and is meant for personal use, provided that does not unjustifiably damage the legal interests of the authors or other holders of intellectual property rights and in case the copying or reproduction have a non-business purpose. art. 15 (4) Upon copying or reproduction of any information beyond the acceptable volume as defined in the preceding paragraph, or in case of any other violation of the intellectual property rights pertaining to the resources of DEMANA INVEST, DEMANA INVEST shall be entitled to seek compensation both for direct and indirect damages to full amount. art. 15 (5) in the course of using the access to services provided by DEMANA INVEST, the User undertakes to: to comply with the Bulgarian legislation, the present General Terms and Conditions, the Internet ethics, the rules of good manners; to not harm the reputation of anyone else and not to instigate violent change of the constitutional order, to a perpetration of a crime, towards violence against any person, or inciting conflict on racial, national, ethnic or religious basis, to not propagate fascist or any other anti-democratic ideology, to not violate third party material or non-material rights, including intellectual property rights; to immediately notify DEMANA INVEST of any case of performed or found violations; to not interfere with the proper functioning of the system, including, but not limited to, not impeding the identification procedure of another User, to not use access beyond the one granted, to not damage or impede the availability, reliability or quality of the granted access, as well as not to use it in a manner inducing anyone to reject using it; to not extract by technical means or in a technological manner any information resources or parts thereof, belonging to the databases on the DEMANA INVEST website and thereby to not create one’s own database in electronic or in any other format; to not impersonate another person or in any way to mislead other people in terms of his/her identity or being part to a certain group of people; to not engage in any malicious activities in the sense of the present General Terms and Conditions. art. 15 (6) Unless expressly agreed, the User cannot reproduce, change, delete, publish or proliferate in any manner the information resources published on the DEMANA INVEST website. art. 16 (1) DEMANA INVEST shall be entitled to deactivate or delete a username and password for access to the user profile of the User, in case the latter breaches any intellectual property right of DEMANA INVEST concerning any elements contained on its site, that are subject to intellectual property rights. art. 16 (2) All rights that were not expressly conferred shall be reserved for DEMANA INVEST. Should you have any questions regarding the present General Terms and Conditions regarding the use of the site please call us at +359 0878 767 000 or send us a notification at info@demanainvest.com.

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