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Privacy Notice

vAeroLabs AD, hereinafter referred to as “vAeroLabs”, "Company", "we", "us" and "our", are committed to protecting your privacy and the privacy of your personal data.

This Privacy Notice (the “Notice”) describes the privacy practices that apply to our collection, use, protection and storage of personal information submitted with the Company using our contact form and/or other channels/means for communication, as well as what the rights of data subjects with regard to their personal information.

The processing of your personal information will be performed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 or General Data Protection Regulation (the “Regulation”, „GDPR”), the Bulgarian Personal Data Protection Act and all the applicable data protection legislation.

1. Name and Address of the Controller

The Controller of personal data is vAeroLabs AD, a joint-stock company registered in the Commercial register and register of NPLE with the Bulgarian Registry Agency under UIC 207520607, with its registered seat and business address at: 4 Racho Petkov Kazandzhiata Str., entr. A, fl. 2, Business Building Alfa, r.a. Sofia Park, Sofia 1766, Bulgaria, e-mail: legal@vaerolabs.com

2. Data subjects' categories

In the capacity of a Data controller we may process personal data of the following data subjects:

* For more information regarding the Job applicants' category please refer to Job Applicants Privacy Notice available here.

In a particular case, we may also process data of individuals outside the specified categories above - when acting as a data processor on behalf of a third party - data controller. In these cases, the volume of the processed data is limited to what is strictly necessary for the performance of the specific assignment, and the processing activities are performed in compliance with all applicable regulatory and technical safety requirements, as well as with the requirements of the specific controller.

3. Employees' personal data

We may process employees' personal data in the capacity of an employer under the applicable Bulgarian legislation.

The categories of personal data which might be subject to processing unexhaustively include names, unique identifier, address, ID document data, remuneration, education and professional experience data, marital status and family relations, contact information and health status data. The latter falls within the meaning of sensitive data processed only on the basis of valid special ground pursuant to art. 9 of the GDPR.

Please note that the provision of these data is voluntarily, but have in mind that in the event the Company is not being provided with them an employment contract might not be concluded and the Company might be unable to follow their legal obligations in the capacity of an employer.

We may process your personal data for the following purposes:

4. Clients' and Contractors' personal data

We may process your personal data in the capacity of a contracting party to concluded agreement.

The categories of personal data which might be subject to processing unexhaustively include names, unique identifier, address, professional experience (incl. job position), contact information (email and phone number). Usually all these data concern representatives/employees of our client and contractors with whom we communicate regarding the commercial activity carried out by the Company.

Please note that we do not process personal data of Clients and Contractors falling within the definition of a sensitive data.

The provision of the data listed above is voluntarily, but have in mind that in the event the Company is not being provided with them the respective contract might not be concluded and the Company might be unable to follow their legal obligations (including but not limited to administrative, accountancy, tax and other obligations of a public nature).

We may process your personal data for the following purposes:

We may process your personal data for specific marketing purposes in case you have provided us with your specific explicit consent (based on Art. 6, para 1, letter a) of the GDPR) on the matter and until you withdraw this consent.

5. Visitors' personal data

We may process personal data provided by a visitor to our website who has used our contact form.

The categories of personal data which might be subject to processing unexhaustively include names, contact information, the content of your message/ inquiry.

Please note that we do not process personal data of Visitors falling within the definition of a sensitive data.

The provision of the data listed above is voluntarily, but have in mind that in the event the Company is not being provided with them we might be unable to properly process your message/inquiry and therefore unable to prepare adequate reply.

We may process your personal data for the purposes of processing your message/inquiry and in order to prepare our reply to it.

We may process your personal data for specific marketing purposes in case you have provided us with your specific explicit consent on the matter (based on Art. 6, para 1, letter a) of the GDPR) and until you withdraw this consent.

Apart from the above listed information you may also decide to share other information which is not necessary for the purposes of the processing. As far as these data might not be relevant to the Company, we recommend that you do not include them in our communication and other documents you share with us. In case that despite our recommendations, you have provided us with such personal data, we believe that this has been done voluntarily, on your own initiative and with your consent, and we will store and process these data with due care and in compliance with all the requirements of the applicable legislation.

6. To whom personal data is shared or disclosed

Your personal data are processed by the Company for the purposes described in the applicable sections above. We may disclose the personal data listed to the extent that we consider such disclosure to be necessary for the fulfilment of these purposes to the following recipients, located within the EU:

We do not perform transfers of personal data within the meaning of the Regulation. If, however, in any of the cases described above, the sharing of personal data is performed outside the EEA, the Company will perform it only after ensuring that the applicable level of protection of personal data corresponds to the level of protection ensured within the EEA, in particular through the implementation of standard contractual clauses, approved by the European Commission or contractual clauses previously approved by the relevant supervisory authority.

7. Personal Data Retention Periods

We retain your personal data in accordance with the applicable law and with respect to the “storage limitation” principle. Please note that the Company has established sound and clear rules related to the data retention periods applicable to the different categories of personal data and these periods may vary depending on the nature of the data and the reason they might be necessary (for example (i) documents including information on remuneration and insurance income of employees are stored for 50 years; (ii) documents related to job applicants who are not hired are stored up to 6 months as of closure of the respective procedure; (iii) data included in tax invoices issued under contracts with customers, suppliers and other contractors are stored for 10 years as of the beginning of the accounting (calendar) year following the year in which the relevant invoices were issued, etc.). In addition to the above, we are readily available to provide additional detailed information as per specific retention period applicable to specific data carrier on the grounds of data subject's request.

Once your data are no longer necessary for the fulfillment of a specific purpose and/or the provided statutory retention period has expired, they shall be safely erased and/or destroyed. Further storage is permissible under existence of further legitimate interest (e.g. for execution of legal claim or in order to be presented in the course of court, administrative or other proceeding) or upon provided specific consent for their further processing.

8. You have the following rights in line with the processing of your personal data:

We do not employ automated decision-making nor profiling when processing your personal data.

9. Right to object to processing

In addition to the rights mentioned under the previous Section, under certain circumstances, such as if you question our legitimate interest to process your personal data or in case you have no further interest of our marketing activity and/or notification, you have the right to object, on grounds relating to your particular situation, to such processing. Your rights are derived directly from the provision of Article 21 as of the Regulation and we will assure their proper satisfaction in any case, except the Regulation provides otherwise.

10. Security of Processing

We guarantee the complete confidentiality of personal data. The personal you share with us will not be published anywhere unless the data subject has explicitly instructed us to do so or unless there is a legal requirement imposing the obligation to do so.

As a Controller of personal data, the Company has implemented technical and organizational measures to ensure personal data processed remains secure. However, absolute security cannot be guaranteed, but we maintain security and incident response plans in the event of a physical or technical incident to handle this in a timely manner and limit any negative effect of such incident.

11. How to contact us

If you have any questions or concerns regarding this Privacy Notice, you may write to us at: elitsa@vaerolabs.com

You may also refer to our Data protection officer appointed on a group level, available here: email: datenschutz@dlh.de

If you are not satisfied with the way we responded to your inquiry/request/complaint, you have the right to lodge a complaint with the Commission for Personal Data Protection. You can contact the supervisory authority at:

email: kzld@cpdp.bg, or address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592

12. Your responsibilities

As we undertake numerous obligations and implement a wide range of technical and organizational measures to ensure the confidentiality of your personal data, you are also required to provide us only with information which is honest, truthful, accurate and not misleading in any way and the sharing of which is not infringing on any rights of any third party.

13. Changes to this Notice

This Notice was last updated on 29.09.2025. We may change it from time to time to reflect changes in the law or our privacy practices. We will keep this notice updated and we will also keep prior versions of it in our archive for your review. You can request a copy of the Notice at any time by sending us an email to: elitsa@vaerolabs.com

Address: Business Center Alpha, Racho Petkov Kazandzhiyata № 4, ent. A, fl. 2 1766 Sofia