Table of Contents
Definitions 2
List of Information Collected by GINA 3
2.1. Information Necessary for Platform Use 3
2.2. Information You May Provide Additionally 3
2.3. Information Automatically Collected When Using the Platform 4
2.4. Information We May Receive from Third Parties 5
How We Use Collected Information 6
Disclosure of Personal Information 8
4.1. Company Access 8
4.2. Internal Information Sharing Within the Platform 8
4.3. Sharing with Your Consent or at Your Direction 8
4.4. Disclosure to Third Parties 8
4.5. Disclosure to Law Enforcement Authorities 9
4.5.1. Grounds 9
4.5.2. Tax Authorities 9
4.5.3. Government Agencies for Registrations, Notifications, Permits, or License Numbers 10
4.5.4. Notification 10
4.5.5. Business Transfers 10
Third-Party Partners and Integrations 10
5.1. Linking Third-Party Services 10
5.2. Terms of Service for Third-Party Providers 11
Your Rights 11
6.1. Managing Your Information 11
6.2. Accessing and Transferring Your Information 11
6.3. Deletion 12
6.3.1. Legitimate Business Interests 12
6.3.2. Legal, Tax, Reporting, and Audit Obligations 12
6.3.3. Shared Information 12
6.3.4. Backups 12
Security 12
Changes to this Privacy Policy 12
Contact Information and GINA Representatives 13
Company Access 13
Information Storage 13

GINA Privacy Policy
Date of Last Update: July 3, 2024
GINA was created to simplify the process of migration and integration. However, GINA is not just a service for addressing individual relocation tasks; it is a platform that accumulates knowledge, open information about cities and countries, and diverse migrant experiences to help you settle in a new place faster and more easily. This makes the Platform a space for mutual assistance, transparency, and opportunities.
In accordance with the principle of transparency, this GINA Privacy Policy (hereinafter referred to as the "Privacy Policy") describes how Vetta 2013 LTD and its affiliates ("we," "us," or "the Company") process personal information related to the use of the GINA Platform by Users ("you," "your").
The purpose of this Policy is to protect the rights and freedoms of Users in the processing of their personal data, including the protection of rights to privacy, personal, and family confidentiality.
Depending on your citizenship, your place of residence, or where you receive services through the Platform, additional provisions of the Privacy Policy listed below may apply to you and are considered integral parts of this Policy:
Additional provisions under GDPR (EU)
Cookie Policy

1. Definitions
Personal Data – Any information relating directly or indirectly to an identified or identifiable individual (the data subject).
Processing of Personal Data – Any operation or set of operations performed with personal data, whether using automation or not.
Operator or Controller – An entity organizing and/or performing personal data processing and determining the purposes, scope, and operations with personal data.
If a term is not defined in this Privacy Policy, its definition matches the one provided in the GINA User Agreement ("Agreement").

2. Information Collected by GINA
2.1. Information Necessary for Platform Use
2.1.1 Contact Information, Account, and Profile Data
To access Platform features, we may request:
Your email address.
Depending on the features you use, we may also request your name, surname, phone number, postal address, date of birth, profile photo, and passport details (if needed for specific services).
2.1.2 Identity Verification
Where required, we may request a copy of your government-issued identification or other documents for identity verification purposes. If you provide an ID copy, we may extract information from it.
2.1.3 Payment Information
This includes details necessary for processing payments for services, such as credit card or bank account numbers, issuing bank names, payment dates and amounts, transaction numbers, and reasons for the payment. If a Platform User uses your bank card for bookings on GINA, we may collect this information. If you receive unauthorized payment notifications, report them immediately to GINA Support.
2.1.4 Compliance with EU "Digital Services Act" (DSA)
If you operate as a business or professional offering services to consumers within the EU, we may collect:
Trade Registry Information: Registration details and your registration number (or equivalent identifier).
Self-Declaration: A declaration confirming that your services comply with applicable EU laws.

2.2. Information You May Provide Voluntarily
2.2.1 Additional Profile Information
Such as cultural identity, visited countries, gender, preferred language(s), city, personal descriptions, or preferences relevant to the services provided by Partners.
2.2.2 Information About Others
This includes payment details or contact information belonging to another individual (e.g., family members). When sharing personal data of others, you confirm that you have informed them and obtained their consent.
2.2.3 Biometric Data
For example, data from facial recognition technology used in processing identity documents or photos you provide for verification purposes.
2.2.4 Other Information
This includes data shared during form completion, account updates, survey participation, community posts, promotions, interactions with GINA Support, address or geolocation details, and feedback.

2.3. Automatically Collected Information
2.3.1 Geolocation
This includes approximate or precise location based on IP address, GPS, or other device data. Geolocation data may also be collected when you are not actively using the app if your device permissions allow it.
2.3.2 Usage Statistics
This includes data about ad searches, bookings, services added, access dates and times, pages visited, activities on the Platform, or interactions with external applications.
2.3.3 Device Information
Examples include IP addresses, hardware and software details, device information, crash data, and read notifications.
2.3.4 Cookies and Similar Technologies
For details on cookie usage, refer to the [Cookie Policy].
2.3.5 Payment Transactions
Includes details about the payment method, payment date and time, amount, expiration date, zip code, and more.

2.4. Information Received from Third Parties
2.4.1 Third-Party Applications
If you link GINA to third-party services (e.g., Google or GitHub), these services may share your registration details, contact lists, or profile data with us.
2.4.2 Background Information Providers
We may request background information, including criminal records and offenses, from authorized providers with your consent, as required by law.
2.4.3 Complaints
If another User or third party files a complaint against you, we may receive details of the complaint to investigate and address it.
2.4.4 Financial Institutions
If you process payments via your bank account, we may receive related details (e.g., account numbers, balance).
2.4.5 Other Sources
We may collect additional data from third-party providers, Users, public records, or government agencies, to prevent fraud and ensure security.
3. How We Use Collected Information
We process information collected on the Platform to:
3.1. Enable Platform Functionality, Improvement, and Development:
Provide you access to the GINA Platform, facilitate and process payments.
Allow you to communicate with others.
Handle your requests.
Conduct analytics, debug systems, and perform research.
Develop and enhance our products and services.
Analyze migration trends.
Train staff on user interactions.
Send technical updates, support messages, account notifications, and security alerts.
Determine your country of residence by analyzing account and interaction information.
Personalize and tailor your user interface based on Platform interactions, search history, bookings, account preferences, and other submitted content.
Enable the use of our products and services.
3.2. Ensure Platform Security and Community Protection:
Detect, prevent, evaluate, and address fraud risks and security breaches.
Verify or authenticate information, including identity data.
Cross-check details with databases and other sources, including background information.
Comply with legal obligations and safeguard public and user welfare.
Resolve disputes with Users.
Enforce agreements with third parties.
Determine eligibility for certain services.
Comply with laws, respond to legal requests, prevent harm, and protect our rights.
Enforce the User Agreement and other policies.
Evaluate your Platform interactions and information from third parties.
In certain cases, if an action poses risks to the Company, our community, or third parties, Platform access may be automatically restricted or suspended based on account and activity analysis.
If you disagree with automated decisions, contact GINA Support.

Submit a request
Service d’assistance GINA
FR
https://airtable.com/appgXc9h9MbnUIn3i/pagwNQgNiqfeT3zYb/form
Submit a request
Служба Підтримки GINA
UA
https://airtable.com/appgXc9h9MbnUIn3i/pagpBtIe1U9u1CWU1/form
Submit a request
Обслужване на клиенти GINA
BG
https://airtable.com/appgXc9h9MbnUIn3i/pagrx6oY8LuxqSGA9/form
Submit a request
Support Service GINA
EN
https://airtable.com/appgXc9h9MbnUIn3i/pagQXddSaQqu5k3Ks/form
Submit a request
Служба Поддержки GINA
RU
https://airtable.com/appgXc9h9MbnUIn3i/pagfYBU5bUhfwc940/form

3.3. Analyze Messages
We may review or analyze your messages on the Platform to:
Prevent fraud.
Assess risks.
Comply with regulations.
Conduct security investigations.
Improve products, research, and analytics.
Enforce the User Agreement and support users.
Where possible, automated tools are used for this analysis. Manual reviews may be required to evaluate or improve automated tools, especially in cases involving fraudulent activity or user support.
We do not review or analyze messages to send third-party advertising or sell analysis results. Messages may be shared as outlined in the "Disclosure of Personal Information" section.

4. Disclosure of Personal Information
4.1. Company Access
The Company may review Platform content (e.g., ads, images, comments, reviews, and other user content) for accuracy, compliance with the User Agreement, and local laws. Non-compliant content may be removed.
To monitor User Agreement compliance, the Company reserves the right to access communications between Migrants and Partners, as well as phone call recordings made through Platform tools.
4.2. Internal Information Sharing Within the Platform
The Platform provides some user data to other GINA Users, such as ratings, reviews, account creation dates, and profile photos.
4.3. Sharing with Your Consent or at Your Direction
If you consent or instruct us to share your information, we will do so as described at the time of consent or instruction.
4.4. Disclosure to Third Parties
We may share personal data with third parties or outsource its processing when necessary to provide services. In other cases, explicit consent will be required.
We may share your information with:
Affiliated and unaffiliated service providers to support business operations and comply with regulatory requirements.
Service providers assisting in:
Verifying identity or document authenticity.
Checking data against public databases.
Conducting fraud prevention and security investigations.
Developing and maintaining products.
Providing user support, advertising, and payment processing.
Offering additional services requested by you.
Reviewing messages for specific purposes (e.g., identifying evidence of exploitation).
Third-party providers are contractually obligated to protect your personal information and may only use it for agreed purposes.

4.5. Disclosure to Law Enforcement Authorities
4.5.1. Grounds
We may disclose your information to comply with laws, respond to law enforcement requests, prevent harm, and protect rights. Disclosure may be made to courts, government agencies, or third parties if legally required or necessary to:
Fulfill legal obligations.
Respond to legitimate requests (e.g., subpoenas or court orders).
Address investigations into criminal activity.
Enforce agreements with Users.
Protect the Company, its employees, Users, or the public from harm.
4.5.2. Tax Authorities
When required or permitted by law, we may share Partner and Migrant information with tax authorities or other government agencies to ensure compliance with tax obligations.
4.5.3. Government Agencies for Registrations or Permits
In jurisdictions requiring Partner registration, notifications, permits, or licenses, we may share Partner details with relevant authorities.
4.5.4. User Notification of Legal Requests
We may notify Users of legal requests unless prohibited by law or deemed ineffective, harmful, or risky.
4.5.5. Business Transfers
In the event of mergers, acquisitions, reorganizations, or similar transactions, we may transfer personal information to involved parties. Users will be notified of such changes.

5. Third-Party Partners and Integrations
5.1. Linking Third-Party Services
You may link your GINA Account to third-party services (e.g., Google, GitHub). Linked accounts may result in:
Data being shared or displayed in your public profile.
Data storage and processing for fraud prevention or security purposes.
5.2. Third-Party Service Terms
Interactions with third-party services are governed by their privacy policies (e.g., Google Maps, Stripe).

6. Your Rights
You may exercise rights under applicable laws. EU residents have additional rights under GDPR.
6.1. Managing Your Information
You can access and modify personal information via Account settings.
6.2. Access and Data Portability
In some jurisdictions, you may request a copy of your data, information about its processing, or its transfer to another service provider.
6.3. Deletion
Deletion requests must comply with business, legal, and backup retention policies:
Legitimate Interests: Data may be retained to prevent fraud or improve security.
Legal Obligations: Retention may be required for tax or audit purposes.
Shared Information: Public content (e.g., reviews) may remain visible.
Backups: Data in backups will be deleted with a delay.

7. Security
We implement measures to protect your data from unauthorized access, loss, or misuse, though absolute security cannot be guaranteed.

8. Changes to the Privacy Policy
We reserve the right to update this Policy and will notify Users of significant changes at least 30 days in advance. Continued Platform use confirms acceptance of the updated Policy.

9. Contact Information
Questions or complaints about this Policy or data processing can be directed to:
Vetta 2013 LTD
Burgas Region, Nesebar Municipality, Nesebar City, 8230
Email: easymovingapp@gmail.com
Payment-Related Questions
For payment-related inquiries, please use the contact details provided in the Supplement to the Privacy Policy for EU citizens.