PRIVACY POLICY OF USM Bulgaria EOOD WHEN PROCESSING YOUR PERSONAL DATA
About us
Our website address: https://ballast.bg.
Introduction
By presenting these rules, we aim to explain to you what information we collect about you, why and how we do it, what your rights are under the Personal Data Protection Act (PDPA) and the General Data Protection Regulation (REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 – GDPR).
Why is your consent necessary?
Our utmost priority is to protect your personal data and to obtain your free, informed and unambiguous consent for the processing of your personal data by USM Bulgaria EOOD.
If you tick "I accept the Privacy Policy", you agree that you are providing your personal data voluntarily, that you have become familiar with your rights under the PDPA and REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of April 27, 2016 - GDPR, and you give your consent for your personal data to be collected, processed, stored and transferred to third parties for the purposes we have indicated below.
Definitions
“Personal data” means any information relating to an identified or identifiable natural person (“data subject” or “user”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental and mental, economic, cultural or social identity of that natural person;
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
"Processing" means any operation or set of operations which is performed upon personal data or upon sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
"Supervisory authority" means an independent public authority from a Member State of the European Union responsible for monitoring the application of personal data protection rules. For the Republic of Bulgaria, the supervisory authority is the Personal Data Protection Commission.
Policy objective
This privacy policy aims to ensure that the Administrator:
· complies with data protection legislation, namely the Personal Data Protection Act (PDPA) and the General Data Protection Regulation and other applicable legislation, and follows good practices;
· protects users, employees, clients and partners of USM Bulgaria EOOD;
· ensures transparency about the ways in which subjects' personal data are stored and processed;
· provides protection from the risks associated with data breaches.
How do we collect information about you?
We may collect information about you in several ways:
Forms filled out and sent by you related to registration or services used, or in connection with the conclusion of a purchase contract.
By sending them, you are knowingly sharing personal data.
For each form containing the submission of personal data, we will indicate the purposes of use, the period of their storage, third parties with whom we may share them, and the ways to exercise your rights under the Regulation.
We will minimize the amount of data in the form according to the stated goals.
For example:
· when you create a profile on the USM Bulgaria EOOD website, you provide us with personal information, including your name, phone number, address and email address.
· when you participate in games, contests or promotions of USM Bulgaria EOOD and/or third parties – Partners of USM Bulgaria EOOD. You provide personal information according to the specifics of the game, usually – names, phone number, e-mail.
· when you purchase items and goods from our online store for auto parts and car accessories, you usually provide us with personal data - names, phone number, e-mail, delivery address, bank account. The data is provided in connection with the performance of the contractual relationship between the parties. You provide us with personal data through the various methods of creating an order: through your profile, through the quick order option, by phone, by email or other form of communication.
Our operators answer your calls by phone in connection with your inquiries or directly concluding a contract for the sale of a product of your choice. When concluding a contract by phone, we will request your personal data in order to process your order and send you the goods. We process this data on the basis of our contractual relationship and our legitimate interest.
We also provide the opportunity to contact us via online chat, through which you can again provide us with your data in connection with the processing of your order or inquiry about a specific item. We process this data on the basis of our contractual relationship and our legitimate interest.
· when you sign up for our newsletter, you provide us with your email address.
Data collected through observations
We sometimes collect information about you by observing your behavior on our sites and in our mobile applications.
For this purpose, we use standard Internet approaches to track user behavior, e.g. use of network equipment, to track your IP address, analyze the information available as part of the communication in the protocols we use to record and exchange identifiers of you and your device, e.g. HTTP GET/POST requests, use the functionalities of JavaScript and other standard and widely used WEB programming languages to extract data and information about your browser context, operating system, screen resolution, language, etc.
Data received from third parties
Sometimes, after your explicit consent given through the partner's tools, we may receive data from third parties, e.g. data from your social network account, such as Facebook.
This data may be combined with other personal data about you that we already have.
By using various online analytics tools, we can obtain detailed but aggregated data about the audience of our sites. This is not personal data within the meaning of the Regulation.
Cookies
USM Bulgaria EOOD uses cookies on its sites to store settings and identifiers necessary to provide the services listed on the site.
Some of these cookies are technically necessary for the proper functioning of the sites.
What information do we collect and process when you use our services?
Forms you fill out and submit
We may collect various personal data, depending on the purposes of the form and our agreements with advertising partners. We also collect personal data for the purpose of fulfilling our contract when you order products from our online store, when filling out the complaint form, and when you sign up for a newsletter.
Typically, we collect the following data:
· Your names;
· Username;
· Password;
· Mobile phone;
· Email address;
· City;
· Physical delivery address – for e-commerce;
· Data for correspondence with you – in the case of e-commerce;
· Bank account number – in case of a complaint;
· Information about the legal representative of a legal entity, UIC and address of management of a legal entity - if you wish to issue an invoice to a legal entity.
When paying by card (Visa, Mastercard, Visa Electone, etc.) or via Paysera, our site redirects to the Operator's site (https://www.paysera.com/), and we do not receive or collect personal data in connection with your payments.
Data collected through observations
For all visitors, we and the providers of the tools we use, typically collect the following data about you:
· The IP address from which you are making the visit;
· Your browser identifier;
· Your mobile device identifier;
· Your identifier, which does not contain personal data;
· History of your behavior – pages visited, time spent on them, products purchased, etc.;
· Behavior towards the content of the site/mobile application – navigation, interface elements used, dwell time;
· Your searches;
· Behavior regarding the ads served to you – what and how many ads were served; where they were served; ads viewed; clicks made, ads missed, and more;
· Your comments.
For logged-in users, in addition to the data mentioned above, we also collect identifiers linking them to the specific user profile.
Data received from third parties
Depending on the data source, this includes:
· Basic profile information, such as name, email address, date of birth;
· Details you choose to share according to specific social media account settings;
· Your contacts and how you connect with them.
You can view the privacy policies of the major social platforms at the following addresses:
https://www.facebook.com/about/privacy
https://polcies.google.com/privacy
For what purposes do we process the information?
The information we collect and process about you may be used for the following purposes:
Normal functioning of our sites
This data is strictly necessary for the normal operation of our sites and mobile applications. Through it, we can verify your identity as a logged-in user, show you better content, load the site faster, and protect the sites and you from attacks.
Such data, for example, is your session data - information about whether you are logged in, cached content, and more.
This also includes data related to your identification in connection with registering to use our service.
For contractual performance of our services
E-commerce requires that you share personal data with us. We use it to be able to fulfill our contract with you, for the sale and delivery of the goods we offer. When concluding a contract, your data is processed in connection with: processing the order, acceptance, validation, specification, shipping, etc.; issuing documents in connection with the processing of the order; resolving problems related to the cancellation of orders or any other changes to orders already placed by you; returning products in accordance with legal provisions; refunding the value of products in accordance with legal provisions; providing support, including answering your questions in connection with your order or the products we offer.
Other services we offer include the ability to add a profile of your car to your created account, profile pictures, news, comments, etc. We use your personal data, which allows us to identify you and, if necessary, moderate the content you add.
This also includes data related to the identification of the user in connection with registration to use our service.
To save and access information
This goal is ancillary to the fulfillment of other goals - through the use of various technical mechanisms, USM Bulgaria EOOD will be able to fulfill any of the other described goals.
Includes storage and access to information stored on your device, such as device identifiers, user identifiers, advertising identifiers, cookies, and other technologies.
This goal is auxiliary - by using the technical mechanisms described in it, we will be able to fulfill any of the other goals described.
For personalization and profiling
We collect and process information about the use of our services for subsequent serving of personalized advertising and/or content in other contexts, e.g. other sites and mobile applications, over time.
Typically, your content and behavior on the site/mobile application is used to create conclusions about your interests, which then guide the future selection of served advertisements and/or content.
The goals pursued by USM Bulgaria EOOD are: ensuring a better experience for users of the sites, mobile applications and services of USM Bulgaria EOOD, by displaying relevant advertisements.
For selection, delivery and reporting of served ads
USM Bulgaria EOOD offers free websites and mobile applications for its users to access. In order to finance its activities, USM Bulgaria EOOD serves advertisements to its users.
It is known that serving advertisements and the related collection of data on user behavior and building user profiles are among the most serious reasons for creating the GDPR.
USM Bulgaria EOOD understands its responsibilities to users and strives to limit the collection and processing of data for the purposes of optimizing advertising serving to the minimum possible. However, technological development has led to the creation of a complex system of relationships and data exchange for these purposes.
We collect information and combine it with previously available information to select and deliver relevant advertising to you and to measure its delivery and effectiveness. This may include previously collected information about your previous interests in selected advertisements, processing data about your behavior when the advertisement was shown to you, how often you were shown certain advertisements, where and when they were shown to you, whether you took an action related to the advertisement, including clicking on the advertisement and making a purchase.
This purpose does not include personalization and profiling.
For selection, delivery and reporting of served content
We collect information and combine it with previously collected information to select and deliver relevant content to you and to measure its delivery and effectiveness. This may include previously collected information about your interests in the content, processing data about the content shown to you, how often or for how long it was shown, whether you took an action related to the content, including clicking on the content.
This purpose does not include personalization and profiling.
For measurement
We collect information about your use of the content and combine it with previously collected information to measure, understand and report on your use of our services.
Our business model is built on providing users with free access to our website content. In order for our websites to function properly and to follow normal business logic, we need a basic measurement of your user behavior.
For this purpose, we only use the Google Analytics tool, and until we receive your consent, we have disabled the Google Analytics advertising features and have sent a command to anonymize your IP to Google Analytics.
We believe that in this way, on the one hand, we have minimized the volume of information collected for measurement purposes to the minimum necessary for this purpose and thus ensure that this data is not used for purposes other than Measurement, and on the other hand, we believe that we are protecting our legitimate interest in the normal and necessary functioning of our services.
This purpose does not include personalization and profiling.
On assignment and for third-party projects
For specific projects commissioned by third parties, we collect your personal data, which we share with them to achieve the goals of their projects.
Detailed information about the purposes can be found in the General Terms and Conditions of each specific project, which will be provided to you for your consent.
To inform you about games and promotional offers of USM Bulgaria EOOD and/or third parties – Partners of USM Bulgaria EOOD
To fulfill this purpose, we collect your personal data to inform you about ours or third parties, our partners, initiatives, promotions, games, offers and more.
For all of the purposes described above, we may use third-party tools.
For processing your personal data, including provision to competent authorities in cases provided for by law and for the fulfillment of legal obligations of USM Bulgaria EOOD (including accounting and tax purposes according to accounting and tax legislation), as well as for purposes related to the fulfillment of the obligations of the parties under a contract
For planning, reporting and statistical purposes
For the purposes of planning, reporting and statistics, it means any operation of collecting and processing personal data necessary for statistical research or for the preparation of statistical results, as well as for the preparation, implementation and verification of plans and their results.
For Marketing Purposes
In order to always send you up-to-date and useful information about our initiatives, we collect data such as an email address or another way to contact you - Viber, Skype, Messenger account or one on another communication platform.
Who else has access to this information?
We sometimes disclose your personal information to third parties - Partners of USM Bulgaria EOOD, including such third parties located outside the European Union, in compliance with the requirements of the Regulation, such as:
· Third parties with whom USM Bulgaria EOOD has contractual relationships to organize games, competitions or promotions for these Partners;
· Third parties with whom USM Bulgaria EOOD has contractual relationships to publish advertisements and promote their products and services through other appropriate means;
· Third parties with whom USM Bulgaria EOOD has contractual relationships for the performance of Measurements, for the selection, delivery and measurement of serving content or advertisements, including servers for the delivery of advertising content, stock exchanges (Ad Exchanges), publishing tools (SSP), advertising tools (DSP);
· Third parties with whom USM Bulgaria EOOD has contractual relationships for the use of colocation services;
· Third parties with whom USM Bulgaria EOOD has contractual relationships for the use of Virtual Servers (VPS);
· Third parties – courier service providers with a view to fulfilling the contractual relations for the delivery of the products ordered by you;
· Third parties providing services to improve the advertising targeting of the products and services of USM Bulgaria EOOD and/or the Partners of USM Bulgaria EOOD;
· Third parties providing services in connection with the creation of depersonalized user segments, according to user behavior;
· Industry-recognized solution providers that have publicly declared compliance with GDPR and e-privacy policies, such as Google and Facebook. Consent also includes the placement and use of unique depersonalized identifiers, including through the use of cookies, localStorage or other appropriate commonly accepted web technology;
· Third parties providing services to USM Bulgaria EOOD such as Accountants and accounting firms; Auditors and Auditing firms; Lawyers - Attorneys, law firms and legal consultants; Notaries; Advertising and PR agencies; Companies engaged in systematic data administration; Companies developing and maintaining our online store.
How long do we keep your personal data?
Depending on the purposes of their processing, personal data may be stored for different periods of time. We process and store your personal data as long as you have an account with us, until you unsubscribe from our newsletter, we process them for the period in accordance with tax and accounting laws in the presence of a concluded contract, etc. You can always ask us to delete the information or close your account, we will respond to this request and in certain cases we will retain certain information, even after closing the account, when applicable legislation requires it.
How do we protect the security of your personal data?
USM Bulgaria EOOD is committed to ensuring the security of your personal data by implementing appropriate technical and organizational measures in compliance with industry standards.
Despite the measures we take to protect your personal data, we are aware that the transmission of information over the Internet or other public networks is not completely secure, and there are risks that data may be viewed and used by unauthorized third parties. We cannot accept responsibility for vulnerabilities in systems that are not under our control.
What are your rights regarding personal data?
Our priority is to both inform you of your legal rights and to ensure that they are respected. You have the following rights that must be respected when processing your personal data:
· The right to withdraw your consent to the processing of your personal data at any time;
· To request correction or completion of your data if an inaccuracy is found through a written application sent to us;
· Right to access your personal data;
· Right to restrict the processing of your personal data;
· Right to object to the processing of your personal data;
· The right to data portability;
· The right to request the deletion of your personal data that is processed unlawfully or on an expired legal basis (withdrawn consent, fulfilled initial purpose for which they were collected, etc.);
· The right to request from the Administrator of your personal data to notify third parties to whom the Administrator has provided your data regarding correction, deletion or restriction of the processing of personal data.
· You have the right to file a complaint with the Personal Data Protection Commission.
Please send your questions and comments to: office@ballast.bg
When can USM Bulgaria EOOD use your data to contact you?
We may use the information you provide to contact you about various matters such as:
· to notify you of changes to USM Bulgaria EOOD policies and these rules;
· to respond to you when you contact us or to respond to your comment or complaint;
· to invite you to participate in our surveys regarding the services of USM Bulgaria EOOD;
· for marketing purposes;
· to send you suitable offers for products and services of USM Bulgaria EOOD and/or third parties – Partners of USM Bulgaria EOOD;
· to inform you about games, competitions or promotional offers of USM Bulgaria EOOD and/or third parties – Partners of USM Bulgaria EOOD;
We will never contact you to request your account password.
How can I obtain, update and manage my personal data?
You can easily update and manage your information by contacting us at office@ballast.bg
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Conclusion
This privacy policy is current as of May 25, 2018.
USM Bulgaria EOOD reserves the right to change and/or supplement this Policy at any time. Changes shall be effective immediately upon their publication on the website, unless otherwise provided in the updated version of the Policy. You should periodically visit this page to review the Policy. The Policy may be updated at any time without special notice to the users of the Site. USM Bulgaria EOOD is not responsible if a user of the websites has not familiarized himself with the latest current version of this Policy.
