1. Overview Caibo Digital EOOD (collectively “Caibo”, “Caibo ” and “us”) respect your privacy. Caibo offer services that enable platforms and merchants to run businesses, and to conduct online payment transactions. This Privacy Policy describes the types of Personal Data Caibo collect through our payments products and services (“Services”) and via our online presence, which include our main Caibo website at www.caibo.digital, (our “Site”). This policy also describes how Caibo use Personal Data, with whom Caibo share it, your rights, and how you can contact us about our privacy practices.

2. Information on Personal data Controller: CAIBO DIGITAL EOOD, UIC 206329734, headquarters and address of management Country: Bulgaria, District: Varna, Municipality: Varna Location: Varna, p.k. 9000 Mladost district Western Industrial Zone, Blvd. Ivsy Pool Office Building E-mail: office@caibo.digital

3. Information on DPO: dpo@caibo.digital

4. How Caibo Use Personal Data

a. Our products and services.

Purposes and legal grounds for processing Personal data: Caibo rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. Caibo use Personal Data to facilitate the business relationships Caibo have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. Caibo also use Personal Data to complete payment transactions and to provide payment-related services to our Users.

b. Marketing and events-related communications.

Caibo  may send you email marketing communications about Caibo  products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that Caibo  do so in accordance with the consent requirements that are imposed by applicable law. For example, when Caibo  collect your business contact details through our participation at trade shows or other events, Caibo  may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

c. Advertising.

When you visit Caibo Site, Caibo may use Personal Data collected from you and your device to target advertisements for Caibo services to you on our Site and other sites you visit (“interest-based advertising”), where allowed by applicable law. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our Services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you. Please see our Cookie Policy for more information. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.

We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site visitors.

5. Personal Data Caibo Collect

a. Personal Data that Caibo collect.

Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Site and Services will be apparent from the context in which you provide the data. In particular:

Account information When you register for a Caibo account Caibo collect your full name, email address, legal company name and password, company website, business type, company registration information, company bank account number, personal data of the company representative such as: name, address, e-mail, mobile phone, identity document information.

Emails or surveys When you respond to Caibo emails or surveys Caibo collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, Caibo will collect the phone number you use to call Caibo. If you contact us by phone as a Caibo User, Caibo may collect additional information in order to verify your identity.

Information on Caibo Users

If you are a Caibo User, you will provide your contact details, such as name, postal address, telephone number, and email address. As part of your business relationship with us, Caibo may also receive financial and personal information about you, such as your date of birth and government identifiers associated with you and your organization

Information on Caibo User’ Customer

If you are a Customer of a Caibo User, when you make payments or conduct transactions through a Caibo User’s website or application or device Caibo provide, Caibo will receive your transaction information. Depending on how the Caibo User implements our Services, Caibo may receive this information directly from you, or from the Caibo User or third parties. The information that Caibo collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and payment method. Different payment methods may require the collection of different categories of information. The Caibo  User will determine the payment methods that it enables you to use, and the payment method information that Caibo  collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you by the Caibo  User. When you make a transaction, Caibo may also receive your name, email, billing or shipping address and in some cases your transaction history to authenticate you.

Information required for carrying out fraud monitoring, prevention, detection, and financial compliance

When Caibo conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to our Users, Caibo  will receive Personal Data from you (and your device) and about you through our Service and from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may collect Personal Data about you and use technology to help us assess the risk associated with an attempted transaction by you with a Caibo User. You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

b. Information that Caibo collect automatically on our Site.

Our Site use cookies and other technologies to function effectively. These technologies record information about your use of our Site, including

Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Site you are visiting;

Usage data, such as time spent on the Site, pages visited, links clicked, language preferences, and the pages that led or referred you to our Site.

Caibo also collect information about your online activities on Caibo Site and connected devices over time and across third-party Caibo Site, devices, apps and other online features and services. Caibo use Google Analytics on our Site to help us analyze Your use of our Site and diagnose technical issues.

To learn more about the cookies that may be served through our Site and how You can control our use of cookies and third-party analytics, please see our Cookie Policy.

6. How Caibo Disclose Personal Data.

Caibo does not sell or rent Personal Data to marketers or unaffiliated third parties. Caibo share your Personal Data with trusted entities, as outlined below.

  1. Other Caibo entities Caibo share Personal Data with other Caibo entities in order to provide our Services and for internal administration purposes.
  2. Service providers. Caibo share Personal Data with a limited number of our service providers. Caibo have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. Caibo authorize such service providers to use or disclose the Personal Data only as necessary to perform services on our behalf or comply with legal requirements. Caibo require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union.
  3. Business partners. Caibo share Personal Data with third party business partners when this is necessary to provide our Services to our Users. Examples of third parties to whom Caibo may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when Caibo  provide payment processing services, and the professional services firms that Caibo  partner with.
  4. Our Users and third parties authorized by our Users. Caibo share Personal Data with Users as necessary to maintain a User account and provide the Services. Caibo share data with parties directly authorized by a User to receive Personal Data, such as when a User authorizes a third party application provider to access the User’s Caibo account.
  5. Compliance and harm prevention. Caibo  share Personal Data as Caibo  believe necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety and property of Caibo , you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.

7. Your Rights and Choices.

You have choices regarding our use and disclosure of your Personal Data:

  1. Opting out of receiving electronic communications from us. If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. Caibo will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, Caibo may still send you important administrative messages that are required to provide you with our Services.
  2. How you can see or change your account Personal Data. If You would like to review, correct, or update Personal Data that You have previously disclosed to us, You may do so by signing in to your Caibo account or by contacting us.
  3. Your data protection rights. You have the following rights with regard to the Personal Data Caibo control about you:
    • The right to request confirmation of whether Caibo processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
    • The right to request that Caibo rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
    • The right to request that Caibo erase your Personal Data in certain circumstances provided by law;
    • The right to request that Caibo restrict the use of your Personal Data in certain circumstances, such as while Caibo  considers another request that you have submitted (including a request that Caibo  make an update to your Personal Data); and
    • The right to request that Caibo export to another company, where technically feasible, your Personal Data that Caibo hold in order to provide Services to you.
    • Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time.
    • You also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.
    • You also have the right to know the categories of sources from which Caibo collected the personal information;
  4. The provision of personal data is a requirement necessary to enter into a contract.
  5. Process for exercising data protection rights. In order to exercise your data protection rights, you may contact Caibo as described in the Contact Us section below. Caibo will comply with your request to the extent required by applicable law. Caibo will not be able to respond to a request if Caibo no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country. For your protection, Caibo  may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that Caibo  have on file. If Caibo  no longer need to process Personal Data about you in order to provide our Services or our Site, Caibo  will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request. If you are a Customer of a Caibo  User, please direct your requests directly to the User. For example, if you are making, or have made, a purchase from a merchant using Caibo  as a payment processor, and you have a request that is related to the payment information that you provided as part of the purchase transaction, then you should address your request directly to the merchant.
  6. Right to lodge a complaint. Where you are dissatisfied with any aspect of our handling of your personal data you have a right to lodge a complaint with: Bulgarian Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592 Tel: +359 (0)2 91-53-518, E-mail: kzld@cpdp.bg, Web-site: cpdp.bg


7. Security and Retention.

Caibo makes reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. Caibo maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.

Caibo retain your Personal Data as long as Caibo are providing the Services to you. Caibo  retain Personal Data after Caibo  cease providing Services directly or indirectly to you, even if you close your Caibo  account or complete a transaction with a Caibo  User, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. Caibo  also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where Caibo  are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that Caibo  support. Where Caibo retain data, Caibo do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

8. International Data Transfers. Personal Data are stored and processed in Republic of Bulgaria. Caibo may transfer Personal Data that Caibo maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. Those countries may have data protection rules that are different from those of Republic of Bulgaria. However, Caibo will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. Caibo  have implemented intra-group data transfer agreements which you may view upon request. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, Caibo  use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA or UK, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU legal framework.

9. Updates To this Privacy Policy and Notifications.

Caibo may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when Caibo post the revised Privacy Policy on the Services. Caibo  may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through your Caibo Dashboard, email address and/or the physical address listed in your Caibo  account.

10. Contact Us if you have any questions or complaints about this Privacy Policy, please contact us electronically or send physical mail to: CAIBO DIGITAL EOOD Country: Bulgaria,  District: Varna, Municipality: Varna Location: Varna, p.k. 9000 Mladost district Western Industrial Zone, Blvd. Ivsy Pool Office Building E-mail: office@caibo.digital.