Privacy notice for LexUP

0. Introduction

BRENDPOL Ltd respects your privacy and is committed to protecting your personal data. This Privacy Notice explains how BRENDPOL Ltd (registered address: 36 Preslav Street, Office 7, Varna, Republic of Bulgaria, Unified Identification Code (UIC/EIK):: 201261446 (hereinafter ‘BRENDPOL’) collects and processes personal data when you use the LEXUP website, register for a personal account, use the LEXUP software service, contact us or receive marketing communications.

LEXUP is software that enables users to configure automated claim management for the protection of trade marks and other intellectual property rights, including monitoring potential infringements and automated preparation and sending of claims demanding cessation of infringement.

This Privacy Notice is provided in a layered format. It should be read together with our Terms of Use, Cookie Policy, consent forms, and any other notice provided when we collect or process personal data for a specific purpose.

1. Important information and who we are

Purpose of this Privacy Notice This Privacy Notice gives you information on how BRENDPOL collects and processes your personal data when you use our website https://www.lexup.pro and the personal account registration page https://cabinet.lexup.pro/registration, create an account, choose a tariff plan, pay for the right to use the computer software, configure monitoring, use the software service, request support, or subscribe to marketing communications.

Our services are not intended for children and we do not knowingly collect personal data relating to children. If we become aware that we have collected personal data from a child contrary to applicable law, we will delete such data without undue delay.

Controller
BRENDPOL Ltd (registered address: Republic of Bulgaria, Varna, 36 Preslav Street, Office 7, Unified Identification Code (UIC/EIK): 201261446) is the data controller responsible for your personal data. In this LEXUP Policy, ‘we’, ‘us’ or ‘our’ refers to BRENDPOL.

Contact regarding privacy matters
No Data Protection Officer has been appointed. If you have any questions regarding this Policy or wish to exercise your data protection rights, please contact us at: info@lexup.pro.

Full name: BRENDPOL Ltd
Website: https://www.lexup.pro
Personal account registration: https://cabinet.lexup.pro/registration
Email: info@lexup.pro
Postal address: 36 Preslav Street, Office 7, Varna, Republic of Bulgaria
Unified Identification Code (UIC/EIK): 201261446

Complaints
You have the right to make a complaint to the supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement. We would appreciate the opportunity to address your concerns first, so please contact us before approaching a supervisory authority.

Changes to this Privacy Notice and your responsibility to notify us of any changes
It is important that the personal data we hold about you is accurate and up to date. Please let us know if your personal data changes during the course of your relationship with us.

Third-party links
Our website and personal account may include links to third-party websites, services, plug-ins or applications, including payment service providers. We do not control third-party websites and are not responsible for their privacy notices. Please read the privacy notice of each third-party service you use.

2. The data we collect about you

Personal data means any information about an identified or identifiable natural person. It does not include anonymous data.

We may collect, use, store and transfer the following categories of personal data about you:
• Identity Data: full name.
• Contact Data: email address and telephone number.
• Account Data: information necessary to create, maintain and secure your user account, including your account identifier and authentication credentials, where applicable.
• Transaction Data: information about the tariff plan selected, payment status and payment-related confirmations received from payment service providers. BRENDPOL does not itself collect or store full payment card details. Payments are processed by third-party payment service providers, including Stripe and ЮKassa.
• Technical Data: IP address, cookie identifiers, browser and device information, time and date of access, session parameters and similar technical information collected through cookies, server logs and analytics tools.
• Usage Data: information about how you use our website, personal account and software service, including settings selected in the service where such information is necessary to provide and improve the service.
• Marketing and Communications Data: your preferences in receiving marketing communications from us and your communication preferences.

Aggregated data
We may use aggregated or anonymised data, such as statistical data about website usage or service features. Aggregated or anonymised data does not directly or indirectly identify you. Such data is not considered personal data under applicable data protection law unless it is combined with information that identifies or may identify you. If we combine aggregated data with personal data in a way that can identify you, we treat the combined data as personal data
.
Special categories of personal data
We do not collect special categories of personal data about you, such as health data, biometric data, religious or political beliefs, or information about criminal convictions and offences. You should not provide such data through the website or personal account unless we expressly request it for a specific lawful purpose.

3. How your personal data is collected

Direct interactions
You may give us Identity Data and Contact Data by filling in forms, registering for an account, accepting our Terms of Use and consent forms, choosing a tariff plan, contacting us by email or phone, requesting support, subscribing to marketing communications, or otherwise corresponding with us.

Automated technologies or interactions
As you interact with our website, personal account and software service, we may automatically collect Technical Data and Usage Data by using cookies, server logs and similar technologies. We use technical and analytical cookies, including Yandex Metrica, where permitted by your cookie choices and applicable law.

Third parties
We may receive limited Transaction Data and payment status confirmations from payment service providers such as Stripe and ЮKassa. We may also receive technical or analytical information from analytics providers, hosting providers or other service providers used to operate and secure the LEXUP service.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we use your personal data where it is necessary to perform a contract with you or take steps before entering into a contract, where it is necessary for our legitimate interests and your interests and rights do not override those interests, where we need to comply with a legal obligation, or where you have given consent, in particular for marketing communications and certain cookies.

Generally, we do not rely on consent as the legal basis for processing personal data necessary to provide the LEXUP service. We rely on consent for marketing communications and for non-essential cookies where required by law. You may withdraw consent at any time by contacting us at info@lexup.pro or by using the unsubscribe link in our marketing emails.

Purposes and legal bases

Purpose

Personal data

Legal basis

Legitimate interest

Registering and maintaining your user account

Identity, Contact, Account Data

Performance of contract or pre-contractual steps

Not applicable

Granting the right to use the computer programme (the LEXUP service), tariffs and account functionality

Identity, Contact, Account, Usage Data

Performance of contract

Not applicable

Processing payments and confirming payment status

Identity, Contact, Transaction Data

Performance of contract; legal obligation where accounting records are required

Not applicable

Technical support and client communications

Identity, Contact, Account, Usage Data

Performance of contract; legitimate interests

Responding to requests and supporting users

Service security, fraud prevention and system administration

Technical, Usage, Account Data

Legitimate interests

Maintaining secure and reliable operation of the service

Website analytics and improvement

Technical, Usage, Aggregated Data

Consent where required for analytics cookies; legitimate interests for aggregated analytics

Improving website and service quality

Marketing communications about new products, services and offers

Identity, Contact, Marketing and Communications Data

Consent

Not applicable

Compliance with legal obligations and protection of legal rights

Relevant data depending on the matter

Legal obligation; legitimate interests

Establishing, exercising or defending legal claims



4A. Marketing, cookies and change of purpose

Marketing
You will receive marketing communications from us only if you have opted in to receive such communications or where we are otherwise permitted by applicable law to contact you. We do not send unsolicited electronic marketing communications. Marketing communications may include information about new LEXUP products, additional services, legal updates, offers and events aimed at attracting and informing clients.

Opting out
You can ask us to stop sending marketing messages at any time by contacting us at info@lexup.pro or by using the unsubscribe link in our marketing emails. Opting out of marketing does not affect service communications necessary to provide the LEXUP service or administer your account.

Cookies
You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of the website or personal account may become inaccessible or may not function properly. For more information, please see the Cookies section below and our separate Cookie Policy.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that another use is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

5. Disclosures of your personal data

We may share your personal data with the following categories of recipients where necessary for the purposes described in this Privacy Notice:
• payment service providers, including Stripe and ЮKassa, for processing payments and confirming payment status;
• IT, hosting, system administration, CRM, email and technical service providers;
• analytics providers, including Yandex Metrica, where permitted by your cookie choices and applicable law;
• professional advisers, including lawyers, auditors, accountants and insurers;
• public authorities, courts, regulators or law enforcement bodies where required by law or necessary to protect our rights;
• third parties involved in any reorganisation, merger, transfer or sale of our business or assets.

We require third-party service providers to respect the security of personal data and to process it in accordance with applicable law. We do not allow our processors to use your personal data for their own purposes and permit them to process personal data only for specified purposes and in accordance with our instructions, unless they act as independent controllers under their own terms, such as certain payment providers.

6. International transfers

We primarily process personal data within the European Economic Area (EEA). Where it is necessary to transfer personal data outside the EEA, including where certain service providers or technical support resources are located outside the EEA, we ensure that such transfers are carried out only where an appropriate safeguard is in place in accordance with Chapter V of the GDPR, including an adequacy decision of the European Commission, the Standard Contractual Clauses adopted by the European Commission, or another lawful transfer mechanism.

7. Data security

We have implemented appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. In determining the appropriate level of security, we take into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing, as well as the risks of varying likelihood and severity to the rights and freedoms of natural persons.

We maintain procedures to deal with suspected personal data breaches and will notify affected individuals and competent regulators where we are legally required to do so.

8. Data retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including providing the LEXUP service, maintaining your user account, complying with applicable legal, accounting and tax obligations, resolving disputes and protecting or enforcing our legal rights.

The applicable retention period depends on the type of personal data, the purpose of processing and applicable legal requirements. When personal data is no longer required, it will be securely deleted or anonymised unless we are legally required or entitled to retain it for a longer period.

To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the risk of harm from unauthorised use or disclosure, the purposes of processing, whether those purposes can be achieved by other means, and applicable legal requirements.

As a working rule for the LEXUP project, account-related personal data may be retained for the term of the user account and for a reasonable period after account closure where needed for legal, accounting or dispute purposes. Marketing consent records may be retained for as long as necessary to demonstrate consent and manage opt-out requests.

In some circumstances, you may ask us to delete your data. In other circumstances, we may anonymise personal data so that it can no longer be associated with you and use it indefinitely for statistical or service improvement purposes.

9. Your legal rights

Under data protection laws, you may have the following rights in relation to your personal data:
• request access to your personal data;
• request correction of inaccurate or incomplete personal data;
• request erasure of your personal data;
• object to processing, including processing for direct marketing;
• request restriction of processing;
• request the transfer of your personal data to you or a third party;
• withdraw consent at any time where processing is based on consent;
• lodge a complaint with a supervisory authority.
These rights are not absolute and may be subject to limitations under applicable law.

How to exercise your rights
If you wish to exercise any of these rights, please contact us at info@lexup.pro. We may need to request information from you to confirm your identity and ensure that personal data is not disclosed to a person who has no right to receive it.

No fee usually required
You will not usually have to pay a fee to access your personal data or exercise your rights. We may charge a reasonable fee or refuse to act on a request if it is clearly unfounded, repetitive or excessive.

Time limit to respond
We aim to respond to legitimate requests within one month. If a request is complex or you have made several requests, it may take longer. In that case, we will inform you and keep you updated.

10. Cookies

A cookie is a small file placed on your browser or device. Cookies help websites function, remember preferences, understand usage and improve services.

BRENDPOL uses cookies for the following purposes:
• strictly necessary cookies: to enable the website and personal account to function, including login and security functions;
• preference or functional cookies: to remember choices where applicable;
• analytics cookies: to understand how users interact with the website and improve the website and service, including through Yandex Metrica.

We do not use cookies to collect payment card data.

Managing cookies
You can manage cookies through the cookie banner or consent management tool, where available, and through your browser settings. If you reject or disable cookies, parts of the website or personal account may not function properly. Analytics cookies will be used only where permitted by your choices and applicable law.

Separate Cookie Policy
This section provides a general overview. A separate Cookie Policy or cookie table should identify the specific cookies used, their provider, purpose, type and duration.

11. Glossary

Controller means the organisation that determines the purposes and means of processing personal data. For this Privacy Notice, the controller identified in Section 1 of this Privacy Notice.

Legitimate interest means our business interest in operating, securing, improving and developing the LEXUP service, provided that your interests and fundamental rights do not override that interest.

Performance of contract means processing personal data where it is necessary to provide the LEXUP service to you or take steps at your request before entering into a contract.

Consent means a freely given, specific, informed and unambiguous indication of your wishes by which you agree to the processing of personal data for a particular purpose.

Processor means a service provider that processes personal data on behalf of the controller and under its instructions acting solely on documented instructions of the Controller unless otherwise required by law.