Privacy & Personal Data Protection Policy

PRIVACY POLICY FOR PROTECTION OF PERSONAL DATA OF THE USERS OF “INSPECTA PREMIUM” PLATFORM

Content

1. ABOUT THIS POLICY2

2. WHAT DATA WE COLLECT2

3. HOW WE COLLECT DATA AND WHY3

3.1. Data you provide to us3

3.2. Data related to the way you use the INSPECTA PREMIUM platform4

3.3. With your explicit consent4

3.4. Why do we process your data – for what purposes:4

4. YOUR RIGHTS5

A. Right to access your personal data6

B. Right to rectification of personal data6

C. Right to erasure of personal data6

D. Right to restriction of processing of personal data7

E. Right to withdraw consent7

F. Right to portability7

G. Right to object7

H. Right to lodge a complaint with a supervisory authority for personal data protection8

I. Rights in relation to automated decision-making and profiling8

5. HOW LONG DO WE KEEP PERSONAL DATA8

6. HOW WE PROTECT THE DATA9

6.1. Controlling the visibility of data in the platform:9

6.2. Technical measures:9

7. CATEGORIES OF PERSONS TO WHOM WE DISCLOSE DATA9

7.1 Personal data processors9

7.2. Banks and payment institutions10

7.3. Competent authorities10

8. THIRD PARTY WEBSITES10

9. TRANSFER OF PERSONAL DATA10

10. HOW TO CONTACT US10

11. CHANGES TO THIS POLICY11

1. ABOUT THIS POLICY

The mission of the “INSPECTA PREMIUM” platform is to connect, in the most objective way possible using various technological solutions, professionals working in the shipping and shipbuilding industries offering their services (labor) with entities seeking to hire providers of such services (labor). The platform offers tools for structured matching of offered and sought services, for contract conclusion between service seekers and providers, as well as management of the negotiation process to ensure transparent and traceable cooperation between participants on the platform.

In carrying out this mission, a certain amount of personal information (data) from the users is collected and processed, and we at "INSPECTA GLOBAL NETWORK" Ltd. have the responsibility to collect and process this data with care for its protection and in accordance with applicable legislation.

This document informs you about our practices regarding the collection, processing, use, and sharing of personal data that we collect and process in connection with the provision of services through the “INSPECTA PREMIUM” platform. It also describes your protection rights, including, for example, the right to object to certain processing activities we perform.

This privacy policy applies to the online platform “INSPECTA PREMIUM”, owned by "INSPECTA GLOBAL NETWORK" Ltd., registered in the Commercial Register and the register of non-profit legal entities under UIC: 201755107, with headquarters and management address: Sofia, postcode 1729, Mladost district, Mladost 1A residential complex, Alexander Malinov Blvd. No. 23, floor 2, office flat 97, and correspondence details: phone: +30 698 189 8344, email: admin@inspectaglobalnetwork.com, and VAT number: BG201755107 (hereinafter referred to as “the Organiser” or “us”, “we”), as well as regarding online forms and communication channels in social media managed by the Organiser and where a link to this policy is provided, unless a separate privacy policy different from this one is available on the respective form or social media channel.

2. WHAT DATA WE COLLECT

We process different types of personal data depending on the features of the platform you use. Such data includes your identification data, information about how you use the services and functionalities of the platform, information about connecting with other users of the platform—companies or professionals with whom you communicate through the platform's features, data about your location, as well as information about completed payments, issued invoices, current obligations to the platform, the terms of contracts between platform users, and more.

We process the following categories of personal data:

3. HOW WE COLLECT DATA AND WHY

We collect personal data in various ways. In most cases, we receive information directly from you at the time of, and in relation to, the conclusion and performance of our contract with you for the provision of services through the “INSPECTA PREMIUM” platform. Certain data is generated automatically when you use the platform's features.

3.1. Data you provide to us

3.1.1 Upon initial registration for use of the “INSPECTA PREMIUM” platform

To create a profile on the platform, you need to provide us with a certain set of data, so we can be sure that you are a real person, on the one hand, and on the other, so that we can fulfil our contractual obligation to objectively link the platform users. Without providing this necessary information, we would not be able to offer the services through the “INSPECTA PREMIUM” platform, and we collect it so we can fulfil our commitment to you as users of “INSPECTA PREMIUM”.

The minimum required information includes basic data and professional data.

NOTICE! Without providing this information, you cannot use the services of the Platform.

3.1.2 When you use the Platform's function for communication with other Platform users

We process information about the date and time of interviews and conversations (chat), as well as preserve communication to assist resolving disputes both between you and other users and between you and us. This data is generated automatically by the Platform and cannot be edited or reviewed in real time by us.

3.1.3 When you use the Platform's function for concluding contracts between you and another user

We collect, process, and store information regarding which individuals have concluded the contract and under what conditions. In this regard, we process identification data, banking information of professional individuals (if a bank account is specified in the contract), data about the amount of remuneration, type of work, place of rendering the services, duration of work, as well as the main rights and obligations agreed between you.

NOTICE! We are not a party to this contract. The data is processed in order to provide the service of contract conclusion through the Platform's functions. The party hiring becomes the administrator of the personal data of the party providing the services at the moment the hiring process starts—conducting interviews, concluding contracts, and subsequent administration.3.1.4. when you use the Timesheets tool

The Timesheets tool is used to track time spent on a project for which you are paid on a time-based basis. In this case, we collect data about what you have done, or you have received and the length of your remuneration for that project. This data is provided by you using the Platform’s features and is necessary to calculate the amount of our remuneration.

3.2. Data related to the way you use the INSPECTA PREMIUM platform

As developers of the INSPECTA PREMIUM platform, it is important for us to know how it works and how we can improve it, we process certain data related to your behavior as users of the platform such as the number of positions you have applied for or candidates you have interviewed, the number of active projects you participate in, how often you have used various functionalities, on what device the Platform is used, are there any and what are the problems when using the Platform, etc.

3.3. With your explicit consent

In certain situations, in order to receive information/offers for products and services based on your behavior when using the platform, your consent is required if the processing has not met the criteria for legitimate interest. For example, as a user of the Platform, you can choose an additional service for providing assistance with your travel to and from the place of performance of the service under a contract with another user of the platform. When you choose this option, we provide the opportunity to contact you with the third party providing these additional services you have requested.

3.4. Why do we process your data – for what purposes:

3.4.1 to fulfill our contractual obligation to you

a) to provide the service of connecting users providing services with users seeking services.

b) to provide the opportunity to conclude a contract between users of the Platform.

c) to provide the service of tracking the implementation of the project for which a contract has been concluded, including through the time reporting tool (Timesheets).

d) to provide support in the form of evidence of actions performed through the Platform when there is a dispute between you and another user in connection to the contract between you.

3.4.2. to realize our legitimate interest

a) to calculate the remuneration due to us by you, according to the selected plan.

b) in the event of a dispute between you and us regarding the use of the Platform.

c) in the event of a dispute between you and another user of the Platform, in order to guarantee the trust, security and integrity of the Platform by providing a “secure connection environment” for users.

d) in order to avoid abuse and fraud, including avoiding circumvention of the Platform as a connection environment, avoiding unlawful actions and fraud, as well as protecting the integrity of the platform and your rights.

e) to process your feedback and contribution to customer surveys, competitions, offers or questionnaires sent by us for the purpose of studying user satisfaction.

f) preparation and storage of statistical information and reports in a summarized form in order to develop and improve the functions of the “INSPECTA PREMIUM” platform.

NOTICE! When we process your data to achieve our legitimate interests as set out above, we have previously and carefully assessed our legitimate interests against your rights and freedoms in order to ensure a balance between them and, at the same time, we have implemented appropriate safeguards to ensure that balance is maintained.

4. YOUR RIGHTS

Under the General Data Protection Regulation and other applicable EU legislation, you have and may exercise rights over your personal data. For example, you have the right to request a copy of your personal data from us, to request that you rectify, erase or restrict its processing, or to request that we transfer some of that information to other organisations. These rights may be restricted in certain situations, for example if fulfilling your request would reveal personal data about another person or where we can demonstrate that we have a legal requirement to process your personal data.

We will only act on a request to exercise a right under this section if we are able to identify you.

We will provide you with information about the action taken in relation to your request to exercise rights under this section without undue delay and in any event within one (1) month of receipt of the request. If necessary, this period may be extended by a further two (2) months, taking into account the complexity and number of requests. We will inform you of any such extension within one (1) month of receipt of the request, stating the reasons for the delay.

If we refuse to comply with a request, we will inform you of your rights.

If we do not take action on your request, we will inform you without delay and at the latest within one (1) month of receipt of the request of the reasons for not taking action, as well as of the possibility of filing a complaint with the Personal Data Protection Commission and seeking judicial protection.

In the event that we have reasonable concerns regarding the identity of the person making a request under this section, we may request the provision of additional information necessary to confirm the person's identity.

The actions we take in and in connection with the exercise of your rights are completely free of charge. Where your request is clearly unfounded or excessive (for example, due to its repetition), we have the right, at our discretion: (a) to refuse to comply with the request; or (b) to charge a reasonable fee, determined on the basis of the administrative costs necessary to provide the requested information or to take the requested action.

To exercise any of these rights, to obtain other information or if you require further information about your rights or the use of your personal data, you should use the communication functions available on the Platform.

Your rights include:

A. Right to access your personal data

You have the right to access your personal data and information, of the type that we have included in this Privacy Policy with respect to the data in question. You may request information from us whether and for what purposes we process your personal data.

In order for your access request to be processed, you must provide the following information:

Your full name;

In what form the requested information should be provided;

How the requested information should be received;

You will receive a response to your request for access to personal data at your email address registered on the platform.

B. Right to rectification of personal data

If you inform us that your personal data is no longer accurate or incomplete, we will correct or update it. If we have shared your personal data with other parties, where possible, we will notify them of the correction or update.

C. Right to erasure of personal data

We will erase your personal data in certain circumstances, such as:

a) you withdraw your consent to the processing of the personal data (if the processing is based on your consent);

b) you exercise your right to object to the processing of your personal data (if we rely on our legitimate interest for the processing);

c) the personal data are no longer necessary for the purpose(s) for which they were collected;

d) the personal data must be erased for compliance with a legal obligation under EU or Member State law to which we are subject;

We may refuse to comply with your request to erase your personal data where the processing is necessary: ​​

a) for compliance with a legal obligation to which we are subject;

b) for archiving purposes in the public interest, scientific or historical research purposes; or

c) for the establishment, exercise or defence of legal claims.

We will inform you of the relevant exceptions that we apply when responding to any request for erasure that you make.

D. Right to restriction of processing of personal data

We will restrict the processing of your personal data in certain circumstances, such as:

a) if you contest the accuracy of your personal data for the period necessary for us to verify the accuracy of the data;

b) unlawful processing has been established, but you only wish to restrict the processing of your data instead of having them deleted;

c) you wish your personal data to be stored even though we no longer need them for the purposes of the processing, as you will use them for the establishment, exercise or defence of your legal claims;

d) if you object to the processing of your personal data for the period of verification of its validity.

Where processing is restricted, we, with the exception of storage, process such personal data only on the basis of your consent or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person, or for reasons of important public interest.

E. Right to withdraw consent

If at any time you have provided consent to the processing of your personal data in the circumstances or for the purposes described in this policy and you no longer wish your personal data to be processed in this way, you may withdraw your consent by sending your request in writing via the communication functions available on the Platform. The request should contain sufficient data for your undeniable identification, as well as contact details - address and/or email.

F. Right to portability

You may request that we provide you with your personal data (which you have provided to us or which we have collected through your activity on our platform) in a structured, commonly used and machine-readable format in order to send it to another controller. Your right to portability applies to personal data for which the following conditions apply:

a) the processing of the data is based on your explicit consent or on a contractual obligation; and

b) the processing is carried out by automated means.

G. Right to object

You may object to us at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us or for which we have indicated that we are processing for our legitimate interest.

Where the objection is to the processing of your personal data for direct marketing purposes, including profiling for this purpose, we will cease processing them for that purpose.

Where the objection is to the processing of your personal data for other purposes, we will respond to you within a reasonable period, but not longer than one month, whether we find the same justified and accordingly whether we will cease processing the relevant personal data for these purposes.

H. Right to lodge a complaint with a supervisory authority for personal data protection

You have the right to lodge complaints or reports with the Commission for Personal Data Protection (CPDP) if you believe that we are violating the legislation on personal data protection. Instructions for lodging complaints are published on the CPDP website: https://www.cpdp.bg

You can also file complaints with other supervisory authorities within the European Union, as provided for in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC).

I. Rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing or profiling which has a legal or similar significant effect on you. We do not carry out this type of processing of your data

5. HOW LONG DO WE KEEP PERSONAL DATA

We retain your personal data for as long as is necessary to achieve the purposes set out in this Privacy Policy or to comply with legal requirements.

When determining the appropriate retention period, we take into account the purpose for which we process your personal data, the volume, type and nature of the personal data, local legal requirements, the risk of harm to the data protection rights of the individual and whether the purpose of processing personal data can be established by an alternative method.

The personal data you have provided to us will be retained for the duration of your relationship with us and, to the extent permitted, after the end of that relationship for as long as is necessary to fulfill the purposes set out in this policy. This includes, for example, the length of time necessary to satisfy legal, regulatory, accounting and reporting requirements and to process personal information about you for the purpose of establishing, exercising or defending legal claims.

Personal data processed for the purpose of concluding and performing the contract for the provision of the Platform's services are stored for the term of the contract and until the final settlement of all financial relations between the parties, but no longer than 5 (five) years from the termination of use of the Platform;

Personal data processed for the purpose of issuing accounting/financial documents for tax and social security control, such as but not limited to invoices, debit and credit notes, acceptance and delivery protocols, service contracts, etc. are stored for at least 5 (five) years after the expiration of the limitation period for repayment of the public claim, unless the applicable legislation provides for a longer period.

We may store some of your personal data for a longer period until the expiration of the relevant statute of limitations for the purpose of protection against possible claims, as well as for a longer period in the event of an already existing legal dispute until its final resolution with an effective court/arbitration decision.

Personal data processed in connection with a contract concluded between the users of the Platform, such as Timesheet reports, contracts and terms and conditions of the contracts, are stored for a period of up to 5 (five) years from the termination of the relevant contract.

User profiles are stored for a period of 24 (twenty-four) months after the User ceases to use the service.

Records from communication channels are stored for a period of up to 24 (twenty-four) months.

Where we process personal data for marketing purposes based on legitimate interest or your consent, we process the personal data until you ask us to stop and for a short period thereafter (so that we can fulfill your requests).

We will delete or destroy your personal data at the end of the relevant retention periods above.

6. HOW WE PROTECT THE DATA

Building and maintaining trust between us and you is our main strategic priority. Therefore, the protection of our systems and personal data is of paramount importance, both for you and for us. Our main goal is for you to feel in “safe hands” when using the “INSPECTA PREMIUM” platform. In accordance with the requirements of current legislation and good practices, we take the necessary technical and organizational measures to keep your personal data safe.

6.1. Controlling the visibility of data in the platform:

We have built the platform according to the model of controlled visibility of data, in which the user's identification data is hidden from other users of the platform. When registering on the Platform, each User receives a PPID (Primary Platform Identifier), which serves as the main identifier in all interactions between Users in, with and through the Platform. In this way, the security of each user's data is guaranteed. Your user data is disclosed to another user only after you have accepted the terms of the contract offered by the other user, as the disclosure is made for the purpose of concluding the contract between you. With this unique feature, we strive to ensure that your identification data remains protected (hidden) for every visitor and user of the platform until you decide otherwise by accepting an offer from another user of the platform to conclude a contract between you.

NOTICE! Please note that sharing your identification data with other users occurs only at your express request when you approve an offer made to you and proceed to the stage of concluding a contract. In addition, in the event of a dispute between you and another user, for actions on and through the platform before proceeding to the stage of concluding a contract, we may share your data for the purpose of settling the dispute between you.

6.2. Technical measures:

To ensure the protection of your personal data, we use modern technologies combined with uncompromising management of security controls such as, but not limited to, Role-Based Access Control (RBAC), limited administrator access to sensitive data, secure storage of communication and identification data, protection of agreements and work time records, and mechanisms for data backup and recovery are in place.

7. CATEGORIES OF PERSONS TO WHOM WE DISCLOSE DATA

7.1 Personal data processors

Personal data processors are persons who process personal data on our behalf on the basis of a written agreement. They are not entitled to process the personal data provided to them for purposes other than the performance of the work assigned to them by us. Processors are obliged to comply with all our instructions.

We take the necessary measures to ensure that the processors involved strictly comply with personal data protection legislation and our instructions, and that they have taken appropriate technical and organizational measures to protect personal data.

Examples of personal data processors:

• Courier service providers;

• Information systems implementation and/or maintenance service providers who sometimes need to access personal data processed in the relevant systems for the purposes of providing the services;

• Out-of-court debt collection companies who process users' personal data on our behalf;

• Law firms, accounting firms or other consultancy service providers.

7.2. Banks and payment institutions

In connection with the servicing of payments by Platform users to us, made by bank transfer or through a payment institution, it is necessary to exchange data between us and the relevant bank or payment institution.

7.3. Competent authorities

Competent authorities that, by virtue of a regulatory act, have the right to require us to provide information, including personal data, such as - a Bulgarian court or a court of another country, various supervisory/regulatory authorities - Consumer Protection Commission, Communications Regulation Commission, authorities with powers to protect national security and public order.

8. THIRD PARTY WEBSITES

Third party websites will be governed by their own terms of use, depending on the owner and data controller of such websites (including privacy notices), and you are solely responsible for browsing and using any such website in accordance with their applicable terms of use. We are not responsible for the way your personal information is processed by such third party websites and they are not covered by this Policy. An example of such is the Google Meet website.

9. TRANSFER OF PERSONAL DATA

Transfers outside the European Economic Area (EEA)

"INSPECTA GLOBAL NETWORK" EOOD notifies you in case of intention to transfer part or all of your personal data to third countries or international organizations.

We do not intend to transfer your personal data to third parties without obtaining your prior consent.

10. HOW TO CONTACT US

If you wish to make comments, complaints, inquiries or if you have any questions related to this Policy, your rights, you can contact us by sending us using the communication functions available on the Platform.

You can also contact the Personal Data Protection Commission on their page here.

11. CHANGES TO THIS POLICY

This policy is subject to periodic review to ensure that it is in compliance with applicable law.

We retain all applicable ownership rights to the information we collect. We reserve the right to change, modify, add or remove provisions of this Policy. Any changes to this policy will be posted on the “INSPECTA PREMIUM” platform.

We will inform you of changes or additions to this Privacy Policy before they become effective by sending a notification via the “INSPECTA PREMIUM” platform.

This Privacy Policy is drafted in both English and Bulgarian languages. In case of any discrepancies between the texts of the two versions, the Bulgarian version shall prevail.

This policy was last edited on 13 May 2026.