Privacy Policy

INSA Bulgaria LTD, unified code of incorporation at the Commercial Register 205510500, registered in Bulgaria, with its management address: Str 33 Simeonvsko Shose, Sofia. (“Insa”, “us”, “we”, or “our”) operates Colibra mobile applications, and Colibra website (colibra.io) collectively referred to as the Service.

Please note that if you open an account with the Service you become an account holder. By using the Service, you agree to the collection and use of information in accordance with our Privacy Policy, and also to our Terms of Service.

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data only to provide and improve the Service.

DEFINITIONS  

Personal Data 

Personal Data is any information about a living individual who can be identified from that information (or from other information either in our possession or likely to come into our possession). 

Usage Data 

Usage Data is the data automatically generated either by the use of the Service or by the Service infrastructure itself (for example, the duration of a page visit). 

Cookies 
Cookies are small pieces of data generated by a website or a mobile application. Their purpose is to remember information about you, similar to a preference file created by a software application. 

Data Controller 

Data Controller is the person who either alone or jointly determines the purposes for which and the manner in which any Personal Data is or will to be processed. For the purpose of this Privacy Policy, we are the Data Controller of your data. 

Data Processor 

Data Processor or Service Provider is the person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use various Service Providers in order to process your data more effectively. 

Data Subject

 
Data Subject is the person whose Personal Data is being collected, held or processed or any living individual who is the subject of Personal Data. 

User 

User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data. 

DATA COLLECTION AND USAGE  

We collect several different types of information for various purposes, all of which aim to provide and improve our Service to you. 

Types of data collected

Personal Data 

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you.

Personal Data may include (but is not limited to):

• First name and last name;
• Email address;
• Bank account details;
• Data relating to your travel/airflight
• Nationality.
• Geographical location

Usage Data 

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

When you are accessing the Service via an internet browser, Usage Data may include (but is not limited to):

• IP address (your computer’s internet address);
• Browser type and version;
• Pages of the Service that you visit;
• Time and date of your visit;
• Unique device identifiers;
• Time spent on the Service pages;
• Other diagnostic data.

When you are accessing the Service by or through a mobile device, Usage Data may include (but is not limited to):

• IP address (your mobile device’s internet address);
• Mobile device’s type and unique ID;
• Mobile device’s operating system;
• Type of mobile internet browser;
• Time spent on the Service pages;
• Unique device identifiers;
• Other diagnostic data.
• Geographical location

Cookies Data 

We use Cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. They are sent to your browser from a website and stored on your device. Other tracking technologies used to collect and track information and to improve and analyze our Service are tags, and scripts.

We use the following Cookies types:

• Session Cookies to operate our Service;
• Preference Cookies to remember your preferences and various settings;
• Security Cookies for secure login into our Service;
• Advertising Cookies to serve you with advertisements that is relevant to you and your interests.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Usage of Data 

We use the collected data for various purposes:

• to provide and maintain our Service;
• to analyze valuable information in order to improve our Service;
• to monitor the usage of our Service;
• to provide customer support;
• to detect, prevent and address technical issues;
• to notify you about changes to our Service;
• to allow you to participate in interactive features of our Service.
• To allow the Service to inform the client depending whether the client’s location is near an airport that there is a risk to travel without using the Service, and is advisable to use it;

Retention of Data 

We retain and use your Personal Data only for as long as necessary for the purposes set out in our Privacy Policy, and only to the extent necessary to comply with our legal obligations or applicable laws, to resolve disputes, and to enforce our legal agreements and policies.

We will also retain and use your Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or when we are legally obligated to retain this data for longer time periods.

Transfer of Data 

Your information, incl. Personal Data and Usage Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer your information, incl. Personal Data and Usage Data, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will reasonably take all necessary steps to ensure that your data is treated securely and in accordance with our Privacy Policy. No transfer of your data will take place to an organization or a country unless there are adequate controls in place.

DISCLOSURE OF DATA

Legal Requirements 

We may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Your Personal Data and Usage Data may be disclosed in the belief that such action is necessary:

• to protect and defend the rights or property of Insa;
• to prevent or investigate possible wrongdoing related to the Service;
• to protect the personal safety of users of the Service or the public;
• to comply with a legal obligation;
• to protect against legal liability;
• to exercise legal rights of Insa, incl. regarding contractual rights and obligations of Insa in connection with the use of the Service.

Security of Data 

The security of your data is important to us, but no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data we cannot guarantee its absolute security. 

Do Not Track Signals 

We do not support Do Not Track (DNT), which is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable/disable DNT by visiting the Preferences or Settings page of your web browser. 

ACCOUNT PRIVACY

Your Rights 

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

You have the right:

• to access and receive a copy of the Personal Data we hold about you;
• to rectify any Personal Data held about you that is inaccurate;
• to request the deletion of Personal Data held about you.

You can update your Personal Data entered in our Service directly within your account settings on our website. If you are unable to change your Personal Data, please contact us at: office@colibra.io.

You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it. Please note that we may ask you to verify your identity before responding to such requests.

Account Information 

We receive and use your Personal Data (e.g. your name, e-mail address and photo) to open your account and maintain it.

We receive and use your Usage Data to provide and improve the Service and also to better understand how you access and use the Service to offer you personalized user experience, including but not limited to features, language and customization.

We will not use or share your information, that is not already publicly available via our Service, with anyone except as described in our Privacy Policy.

Service Suppliers 

We also may link your account information with data we receive from our partners (Service Suppliers or other third parties) to help understand your needs and provide you better user experience.

For example, if you create or log into your account using your Google or Facebook credentials, if and where applicable and to the extend possible, we will have access to certain information (e.g. your name, e-mail address and photo) as authorized by your Google or Facebook profile settings.

Account Security 

We are very concerned about safeguarding the confidentiality of your information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access and use. However, please be aware that no security measures that we take to protect your information are absolutely guaranteed to avoid unauthorized access or use of your information.

Please do not buy, sell, transfer, rent, and/or lease your account and/or password to other people. We will not take any responsibility for the illegal use of your account by others that is caused by hacking or negligent password keeping.

Account Deletion 

 
You can delete your account by contacting us at office@colibra.io. All your Personal Data will be deleted together with your account. Please, bear in mind that you will also lose your account preferences, synced settings on different devices or other content in relation to the Services. We cannot restore any of these once your account is deleted. Moreover, such deletion may not be possible in the event that the Personal Data is necessary for the Services.

Communications 

We may use your Personal Data to contact you about your account, any maintenance related issues, or send you newsletters, marketing and promotional information that may be of interest to you. You may opt out of receiving some of these communications from us by following the unsubscribe instructions provided in any e-mail or message we send. We use mandatory email service announcements to update you about important changes to your account or the content you publish on our Service.

GDPR Compliance 

Our Privacy Policy ( or how we collect and store Personal Data and Usage Data) takes under consideration and is compliant with the EU General Data Protection Regulation (GDPR) of 27 April 2016 for European Union citizens personal data protection.

Changes of Privacy Policy 

Although significant changes are rare, this policy may be amended as new features, technology, or legal requirements arise, so please check back from time to time. We will notify you if we make any significant changes and seek your consent, when required.

SERVICE PROVIDERS 

We may employ Service Providers (third-party companies and individuals) to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data and Usage Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics 

We may use third-party Service Providers to monitor and analyze the use of our Service. 

Google Analytics and Firebase 

Google Analytics and Firebase are web analytics services offered by Google that track and report website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on.
For more information on the privacy practices of Google, please visit Google’s Privacy Terms.

Advertising 

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service. 

Audience Network by Facebook 

Audience Network is an ad service provided by Facebook.
You can customize your Audience Network preferences and opt-out of the Facebook Audience Network services at any time by changing your account settings with Facebook at this link.
For more information on the privacy practices of Facebook, please visit Facebook’s Privacy Policy.

Behavioral Remarketing 

We use remarketing services to advertise third-party websites to you after you visited our Service. We and our third-party vendors use Cookies to inform, optimize and serve ads based on your past visits to our Service. 

For more information on the privacy practices of Google, please visit Google’s Privacy Terms.

Payments 

We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

This Privacy Policy is subject to Bulgarian law. 

The relevant authority is: Commission for Protection of Personal Data

Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592

Е-mail: kzld@cpdp.bg

Web-site: www.cpdp.bg