Privacy policy

1.1. Data of visitors to www.votchina.eu and of persons who write to or call us (by phone, e-mail, WhatsApp, Viber, Telegram, Facebook, through the inquiry form or through property portals).

1.2. Data of clients — buyers and sellers (owners) of real estate, their proxies and representatives.

1.3. Data of counterparties to the transaction, related persons and partners, to the extent necessary for the transaction.

1.4. The website is not intended for persons under 16 and we do not knowingly collect their data.

2.1. Contact details: name, telephone, e-mail, preferred language and channel of communication.

2.2. Search details: type of property, area, budget, method of payment (incl. mortgage), timeframes, property requirements.

2.3. Details of the seller’s property: address, title documents, cadastre and property register data, photos and videos of the property.

2.4. Transaction details: agreements, offers, viewing protocols, payments, bank account for payment.

2.5. Anti-money laundering data: identity document, personal ID number or date of birth, citizenship, address, declarations on the beneficial owner, politically exposed persons and the origin of funds — where required by law.

2.6. Technical data from the website: IP address, browser, device, pages visited and cookies (see Section VIII).

3.1. Answering an inquiry, selecting and sending suitable properties, organising viewings — steps taken at your request before entering into an agreement (Art. 6(1)(b) GDPR).

3.2. Concluding and performing the brokerage agreement, the guarantee agreement and the transaction — contract (Art. 6(1)(b) GDPR).

3.3. Compliance with legal obligations under anti-money laundering, tax and accounting legislation — law (Art. 6(1)(c) GDPR).

3.4. Protecting our rights, including proving the introduction of a property or buyer, and internal organisation of work — legitimate interest (Art. 6(1)(f) GDPR).

3.5. A newsletter with new properties and publishing photos or videos featuring you — only with your consent (Art. 6(1)(a) GDPR), which you may withdraw at any time.

3.6. Website traffic statistics — legitimate interest; the data are aggregated and are not used to identify a specific person.

3.7. We use automated matching of properties to your criteria so that we offer you only what is suitable. It does not lead to decisions with legal effects for you — every offer is reviewed and sent by a broker.

3.8. When we use a telephone exchange, calls to the agency may be recorded — for service quality, staff training and proof of what was agreed (legitimate interest, Art. 6(1)(f) GDPR). You will be informed at the start of the call and may ask for the call not to be recorded.

3.9. Price calculator. On the website and in the online questionnaire for owners, the indicative price is calculated automatically from the listings in our database and from the published statistics of average asking prices on alo.bg. It is not a valuation of the property and does not lead to decisions with legal effects for you; the real price is determined by the broker after a viewing.

4.1. VOTCHINA brokers and employees working on your inquiry — only to the extent necessary and under a duty of confidentiality.

4.2. The counterparty to the transaction and its proxies, notaries, banks, credit consultants, valuers, lawyers and partner agencies — to the extent necessary for the transaction.

4.3. Public authorities — where required by law (National Revenue Agency, State Agency for National Security under anti-money laundering rules, courts, etc.).

4.4. Processors acting on our instructions: hosting and CRM (Superhosting.bg, Bulgaria), accounting services, communication services (Telegram, WhatsApp, Viber, e-mail) and Google (Analytics, Maps).

4.5. Some of these providers are outside the EU (e.g. the USA). Transfers are based on a European Commission adequacy decision (EU–US Data Privacy Framework) or on standard contractual clauses.

4.6. We do not sell data or share it with third parties for their advertising purposes.

5.1. Clients with an agreement — for the term of the agreement and 5 (five) years after its termination.

5.2. Inquiries without an agreement — up to 3 (three) years after the last contact, after which the data are deleted or anonymised.

5.3. Anti-money laundering documents — 5 (five) years after the end of the relationship, unless the law requires a longer period.

5.4. Accounting documents — for the periods under the Accountancy Act.

5.5. Google Analytics cookies — up to 14 months.

5.6. Recordings of telephone calls — up to 6 (six) months, or in case of a dispute or a transaction — until it is completed.

5.7. Files uploaded through the online questionnaire for owners (photos, notarial deed, other documents) where no contract has been signed for the property — up to 6 (six) months in the working system; after that they are moved to an archive with restricted access and kept within the periods under 5.2. Where a contract is signed — under 5.1.

6.1. You have the right of access to your data, rectification, erasure, restriction of processing, portability and objection to processing based on legitimate interest.

6.2. You may withdraw your consent at any time (e.g. for the newsletter), without affecting processing before the withdrawal.

6.3. Requests may be sent to office@votchina.eu or to the office address. We reply free of charge within 1 (one) month; where necessary, we may ask you to confirm your identity.

6.4. Erasure is not possible for data we are required by law to keep (e.g. anti-money laundering, accounting) until the statutory period expires.

7.1. If you believe your rights have been infringed, you may lodge a complaint with the Commission for Personal Data Protection: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria, www.cpdp.bg. We would be glad if you contacted us first — we will try to resolve the matter right away.

8.1. The website uses necessary cookies without which it does not work (e.g. language selection, remembering your cookie choice).

8.2. We use Google Analytics 4 for aggregated visit statistics; IP addresses are processed in shortened form.

8.3. The website contains embedded YouTube videos, Google Maps and Facebook buttons and pages. When they load, the respective company may set its own cookies and receive data about your visit under its own policy.

8.4. We do not use advertising pixels and do not show personalised advertising on the website.

8.5. You can delete or block cookies in your browser settings; some features may then not work.

9.1. Access to the CRM and documents is possible only with a personal account and password, according to the employee’s role.

9.2. The website works over a secure connection (HTTPS). Employees sign a confidentiality agreement.

9.3. In the event of a security breach that may affect your rights, we will notify the Commission and you within the statutory deadlines.

10.1. When you send the inquiry form or write to us, we use the data only to reply and to select properties matching your search. Only name and telephone are required.

10.2. When you choose WhatsApp, Viber, Telegram or Facebook to contact us, the messages are also processed under the rules of the respective platform.

10.3. Online questionnaire for owners. Your answers are saved automatically as you fill it in — even before you send them — so that you can continue where you left off. If you came from the website, your answers are not linked to you without your name and phone. Once you leave your contact details, the questionnaire is passed to a VOTCHINA broker who will contact you; if you chose e-mail, we may send you a reminder about an unfinished questionnaire. You can request deletion of your answers under section VI.

11.1. In case of changes, we publish the new version on this page with its date and version number. Material changes will also be announced on the website.