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Personal Data and General Confidentiality Agreement

Privacy Policy

Information about the personal data controller:

"Web Forge" Ltd is a company registered in the Commercial Register of the Registry Agency under UIC 207655583, with registered office and management address: Burgas, 33 Radi Nikolov St., Tel: 0893 688 309; e-mail: office@forge.bg

Grounds and purposes for which we use your personal data

We process your personal data on the following grounds:

The contract concluded between us and you, in order to fulfill our obligations under it; Your explicit consent – the purpose is specified for each individual case; Where there is a legally established obligation;

In the following paragraphs you will find detailed information regarding the processing of your personal data depending on the ground on which we process it.

FOR THE PERFORMANCE OF A CONTRACT OR IN THE CONTEXT OF PRE-CONTRACTUAL RELATIONS

We process your personal data in order to perform our contractual and pre-contractual obligations and to exercise the rights arising from the contracts concluded with you.

Purposes of the processing:

establishing your identity; managing and fulfilling your request and performing a concluded contract; preparing an offer for the conclusion of a contract; preparing and sending an invoice/bill for the services you use with us; ensuring the comprehensive service you need, as well as collecting the amounts due for the services used; keeping correspondence related to orders made, processing of requests, reporting of problems, etc.; notification regarding everything related to the services you use with us; analysis of customer history; establishing and/or preventing unlawful actions or actions contrary to our terms for the respective services.

Data we process on this ground:

On the ground of the contract concluded between us and you, we process information about the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including:

personal contact data – names, e-mail, telephone number; identification data – full name, address; data on orders made; correspondence related to overall service – e-mail, letters, information on your requests for resolving problems, complaints, requests, grievances, feedback received from you; information on credit or debit cards, bank account numbers or other banking and payment information related to payments made.

other information such as:

Customer number, code or other identifier created for identification purposes; IP address when visiting our website; Demographic data; Information about your actions on the website.

The processing of the personal data indicated above is mandatory for us in order to be able to conclude the contract with you and to perform it. Without you providing us with the above-mentioned data, we would not be able to fulfill our obligations under the contract.

We provide personal data to third parties

We provide your personal data to third parties, our main purpose being to offer you a high-quality, fast and comprehensive service. We do not provide your personal data to third parties before making sure that all technical and organizational measures have been taken to protect that data, as we strive to exercise strict control over the fulfillment of this purpose. In this case, we remain responsible for the confidentiality and security of your data.

We provide personal data to the following categories of recipients (personal data controllers):

postal operators and courier companies; persons who, under assignment, maintain equipment, software and hardware used for the processing of personal data and necessary for the company's activity; persons providing consulting services in various fields.

When we delete the data collected on this ground

We delete the data collected on this ground 1 year after termination of the contractual relationship, regardless of whether this is due to expiry of the contract term, rescission or another ground.

FOR THE FULFILLMENT OF STATUTORY OBLIGATIONS

The law may impose an obligation on us to process your personal data. In such cases we are obliged to carry out the processing, for example:

Obligations under the Measures against Money Laundering Act; Fulfillment of obligations related to distance selling and off-premises selling, provided for in the Consumer Protection Act; Provision of information to the Consumer Protection Commission or third parties, provided for in the Consumer Protection Act; Provision of information to the Commission for Personal Data Protection in connection with obligations provided for in the personal data protection legislation; Obligations provided for in the Accountancy Act and the Tax-Insurance Procedure Code and other related legislation, in connection with the keeping of lawful accounting records; Provision of information to the court and third parties, within the framework of court proceedings, in accordance with the requirements of the legislation applicable to such proceedings; Age verification when shopping online.

When we delete the personal data collected on this ground

We delete the data collected pursuant to a statutory obligation once the obligation to collect and store it has been fulfilled or ceases to apply. For example:

under the Accountancy Act, for the storage and processing of accounting data (11 years); obligations to provide information to the court, competent state authorities, and other grounds provided for in applicable legislation (5 years).

Provision of data to third parties

Where we have a statutory obligation to do so, we may provide your personal data to the competent state authority, natural person or legal entity.

ON THE BASIS OF YOUR CONSENT

We process your personal data on this ground only after your explicit, unambiguous and voluntary consent. We will not provide for any adverse consequences for you if you refuse the processing of personal data.

Consent is a separate ground for processing your personal data, and the purpose of the processing is specified therein and does not coincide with the purposes listed in this policy. If you give us the relevant consent, until its withdrawal or the termination of any contractual relations with you, we prepare suitable offers for products/services for you by carrying out detailed analyses of your basic personal data.

Detailed analysis is a method of analysis that allows the processing of large volumes of data through statistical models, algorithms and others, which involve the use of personal data, as well as pseudonymization and anonymization processes thereof, with the aim of extracting information on trends and various statistical indicators.

Data we process on this ground:

On this ground we process only the data for which you have given us your explicit consent. The specific data are determined for each individual case. Usually this data is your e-mail.

Provision of data to third parties

We do not provide data to third parties.

Withdrawal of consent

Given consents may be withdrawn at any time. Withdrawal of consent has no effect on the performance of contractual obligations. If you withdraw your consent to the processing of personal data for any or all of the methods described above, we will not use your personal data and information for the purposes specified above. Withdrawal of consent does not affect the lawfulness of processing based on consent given before its withdrawal.

In order to withdraw given consent, you only need to use our website or simply our contact details.

When we delete the data collected on this ground

We delete the data collected on this ground upon your request, or 12 months after their initial collection.

PROCESSING OF ANONYMIZED DATA

We process your data for statistical purposes, meaning for analyses in which the results are only aggregate and the data are therefore anonymous. Identification of a specific individual from this information is impossible.

Your data may also be anonymized. Anonymization represents an alternative to data deletion. Upon anonymization, all personally identifiable elements/elements allowing your identification are irreversibly removed. There is no statutory obligation to delete anonymized data, as it does not constitute personal data.

Why and how we use automated algorithms

For the processing of your personal data we use partially automated algorithms and methods with the aim of continuously improving our products and services, in order to adapt our products and services to your needs in the best possible way. This process is called profiling.

How we protect your personal data

In order to ensure adequate protection of the data of the company and its clients, we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act.

For maximum security in the processing, transfer and storage of your data, we may use additional protective mechanisms such as encryption, pseudonymization and others.

Personal data we have received from third parties

We do not receive data from third parties.

Rights of Users

Every User of the website enjoys all rights regarding the protection of personal data under Bulgarian legislation and European Union law.

The User may exercise their rights through the contact form or by sending a message to our e-mail.

Every User has the right to:

Be informed (in connection with the processing of their personal data by the controller); Access their own personal data; Rectification (if the data are inaccurate); Erasure of personal data (the "right to be forgotten"); Restriction of processing by the controller or the data processor; Portability of personal data between different controllers; Object to the processing of their personal data; The data subject also has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects them; The right to judicial or administrative protection, in the event that the rights of the data subject have been violated.

The User may request erasure if one of the following conditions is met:

The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; The User withdraws the consent on which the processing of the data is based and there is no other legal ground for the processing; The User objects to the processing and there are no overriding legitimate grounds for the processing; The personal data have been unlawfully processed; The personal data must be erased for compliance with a legal obligation under Union or Member State law to which the controller is subject; The personal data have been collected in connection with the offer of information society services to children, and the consent has been given by the holder of parental responsibility for the child.

The User has the right to restrict the processing of their personal data by the controller where:

They contest the accuracy of the personal data. In this case, the restriction of processing applies for a period enabling the controller to verify the accuracy of the personal data; The processing is unlawful, but the User does not want the personal data to be erased and instead requests the restriction of their use; The controller no longer needs the personal data for the purposes of the processing, but the User requires them for the establishment, exercise or defense of legal claims; They have objected to the processing pending verification as to whether the controller's legitimate grounds override those of the User.

Right to portability.

The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent or on a contractual obligation and the processing is carried out by automated means. When exercising their right to data portability, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

Right to object.

Users have the right to object, before the controller, to the processing of their personal data. The personal data controller is obliged to cease the processing, unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims. Where an objection is raised to the processing of personal data for direct marketing purposes, the processing must cease immediately.

Complaint to the supervisory authority

Every User has the right to lodge a complaint regarding unlawful processing of their personal data with the Commission for Personal Data Protection or with the competent court.

Maintaining a register

We maintain a register of the processing activities for which we are responsible. This register contains all of the information listed below:

The name and contact details of the controller; The purposes of the processing; A description of the categories of data subjects and of the categories of personal data; The categories of recipients to whom the personal data have been or will be disclosed, including recipients in third countries or international organizations; Where possible, the envisaged time limits for erasure of the different categories of data; Where possible, a general description of the technical and organizational security measures.

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