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PRIVACY POLICY AND PROTECTION OF PERSONAL DATA OF SIEVE 92 EOOD

Effective from 25.05.2018

I. Introduction

SITO 92 EOOD respects the privacy of its customers and guarantees the maximum protection of their personal data. This Privacy and Data Protection Policy (hereinafter referred to as the "Privacy Policy") has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection.

This Privacy Policy governs the processing of personal data of individuals or representatives of legal entities of our customers or potential customers, as well as users of our website: www.sito92.com ("Site"), in connection with the services provided by SITO 92 Ltd., including provided through and available on the Site.

This Privacy Policy sets out the rules that SITO 92 EOOD will follow when processing the personal data that we collect from you or about you, or that you provide to us. This Privacy Policy does not affect, restrict or revoke your rights arising from the Personal Data Protection Act (“PDPA”) or other applicable legislation.

If you have any questions or comments about this Privacy Policy, please contact us at: office@sito92.com .

Please read this Policy carefully before using the Site or providing your Personal Data, whether electronically on the Site or on paper, as by providing Your Personal Data you agree to its terms. If you do not wish us to process your personal data in the manner described in this Privacy Policy, please do not provide it to us. The provision of personal data by you is voluntary, in order to use certain services provided by us and the use of the Site and / or access to it. Please note that in some cases we will not be able to provide you with the service and / or sell the product you have requested if you do not provide us with the necessary information. Please also note that in certain cases your consent to the processing of personal data may not be necessary if SITO 92 EOOD has another legal basis, e.g. fulfillment of normatively established obligations.

II. Who processes and is responsible for your personal data?

SITO 92 EOOD (“we”) is the company registered in the Commercial Register at the Registry Agency with UIC 040235561, which collects, processes and stores your personal data under the terms of this Privacy Policy. SITO 92 EOOD is a personal data administrator within the meaning of the Personal Data Protection Act (PDPA). You can contact us at any of the following coordinates:

Management address: Sofia, 7 Nikola Genadiev Str

telephones: 02/973 32 40

e-mail: office@sito92.com

III. Categories of personal data processed by SITO 92 EOOD.

1. SITO 92 EOOD may process publicly available personal data and / or personal data provided by you. The main types of personal data that are processed are:

(i) Personal identification information (including name, email address, language of communication, etc.);

(ii) Contact details (including postal and e-mail addresses, telephone and fax numbers of you or a contact person designated by you, etc.);

(iii) Financial information (bank account and others);

(iv) Information about a representative (legal representative or proxy of such) of our client legal entity;

(v) Profile data on the Site (including name, postal and e-mail addresses, telephone number, date of birth, etc.);

(vi) Data on concluding sales contracts, wholesale sales, deferred payment, etc. with individuals or legal entities (such as names, PINs, etc.).

2. SITO 92 EOOD may process data prepared and generated by SITO 92 EOOD in the process of providing the services:

(i) Details of the final electronic communications device used, the type of device, the operating system used, the IP address, the location;

(ii) Details of your preferred goods and services

(iii) Data from the communication between us and you, habits, preferences, your satisfaction with our services (activity in using the services, complaints, requests, etc.);

(iv) Information about visits to the Site and use of the Site, including operations and history of use of the Site;

(v) Data obtained in the performance of obligations arising from regulations (ie data arising from inquiries, regulations, investigative bodies, notary, tax authorities, court, bailiff);

(vi) Video recording during a visit to the offices of SITO 92 EOOD;

(vii) Video recording or photograph made in accordance with the pre-announced conditions for participation promotional campaigns organized by SITO 92 EOOD.

3. In order to ensure the good performance of the services and the obligations arising from customer contracts, SITO 92 EOOD has the right to process any information that is available in public registers (including public database and data published on the Internet) as well as information received from third parties in connection with the implementation of legal provisions concerning customers.

4. SITO 92 EOOD has the right and obligation to check the accuracy of the personal data recorded in the database, for which purpose it requires you to verify the data and, if necessary, to correct them or to confirm the accuracy of your data.

5. The different types of personal data may be processed alone or in combination with each other.

IV. Objectives and legal grounds for personal data processing

1. Processing of personal data that is necessary for the conclusion or execution of contracts with us or in connection with the preparation for the conclusion of contracts with us.

SITO 92 Ltd. processes your data for the following purposes:

(i) Identification of a client when: concluding a new or amending an existing contract with us; explanations for the used services; execution of a concluded contract.

(ii) Preparation of proposals for concluding contracts, sending pre-contractual information and draft contract; management of pre-sales activities;

(iii) Data received from you in the performance of obligations arising from contracts concluded with you or a company represented by you, the exercise of rights and ensuring the performance of contracts by our customers;

(iv) Administration and response to customer complaints / inquiries / complaints / complaints; return of amounts and goods; product replacement;

(v) Technical assistance for creating account (s) and recovering a forgotten password to access our Site.

(vi) Payment of debts, rescheduling of amounts due; management of receivables collections;

(vii) Sharing important information regarding changes in our policy and other administrative information;

(viii) Management and administration of payment activities.

2. In fulfillment of its legal obligations, SITO 92 EOOD processes your data for the following purposes:

(i) Issuance of invoices;

(ii) For tax and social security control by the relevant competent authorities;

(iii) Fulfillment of obligations in connection with the distance selling, the sale outside the commercial site, provided for in the Consumer Protection Act;

(iv) Provision of information to the Commission for Personal Data Protection in connection with obligations provided for in the data protection legislation - Personal Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016, etc. ;

(v) Obligations provided for in the Accounting Act and the Tax and Social Security Procedure Code and other related regulations in connection with the maintenance of proper and lawful accounting.

3. SITO 92 EOOD processes the respective data provided with the explicit written consent of the client for their processing for the following purposes:

(i) Creating and managing a personal profile on the Site; technical assistance for creating account (s) and recovering a forgotten password for access to our Site;

(ii) Direct marketing of products and services;

(iii) Participation and management of surveys, gift games, promotional campaigns.

4. The processing is necessary for the purposes of the legitimate interests of SITO 92 EOOD.

(i) In order to protect and ensure the protection of the property, interests and security of SITO 92 EOOD, its visitors and employees, SITO 92 EOOD uses video surveillance equipment.

(ii) Evaluate and establish customer satisfaction, as well as the effectiveness of the advertising we offer to you and others, and meet your expectations by presenting adequate advertising;

(iii) Analysis of customer history data, customer preferences and behavior.

V. Categories of third parties that access and process your personal data

(i) Transport / courier companies, postal operators in order to fulfill our contractual obligations, sending correspondence and communications, in connection with the contract between us, sending purchased goods;

(ii) Persons who, on behalf of SITO 92 EOOD, maintain equipment and software used for processing your personal data;

(iii) Debt collection service providers, notary, lawyer, bailiff or other third party if the customer has breached the obligation arising from a contract with us;

(iv) Banks servicing payments made to and from you;

(v) Persons to whom SITO 92 EOOD has provided the performance of part of the activities or obligations related to a specific service that we owe to you; persons processing personal data, who on the basis of a contract with SITO 92 EOOD process your personal data on behalf of SITO 92 EOOD;

(vi) Persons providing consulting services in various fields - lawyers, accountants, marketing agencies, etc .;

(vii) Authorities, institutions and persons to whom we are obliged to provide personal data under applicable law;

(viii) Security companies holding a license for performing private security activity, processing the video recordings from sites / offices of SITO 92 EOOD and / or maintaining other registers in the process of providing the access regime in the same sites;

VI. How long is your personal data stored?

The duration of storage of your personal data depends on the purposes of processing for which they were collected:

1. The personal data processed for the purpose of concluding / amending and executing contracts between SITO 92 EOOD and you or a company represented by you - for the term of the contract and until the final settlement of all financial relations between the parties. SITO 92 EOOD may store some of your personal data for a longer period until the expiration of the relevant statute of limitations in order to protect against any claims of customers in connection with the execution / termination of contracts with us, as well as for a longer period in case of a legal dispute that has already arisen until its final settlement with an effective court / arbitration decision;

2. Personal data processed for the purpose of issuing accounting / financial documents for tax and social security control, as well as not only - invoices, debit, credit notices, handover protocols, contracts for the provision of services / goods are stored according to the term required by applicable law.

3. The personal data processed for the purpose of account management on the Site - until the explicit withdrawal of the given consent or receipt of an objection for processing of personal data for account management.

4. Personal data processed for the purpose of direct marketing - until the explicit withdrawal of the given consent for direct marketing or receipt of an objection for processing of personal data for direct marketing.

5. Data from video recordings from security cameras - up to 60 days from the creation of the recording.

VII. Your Rights in connection with the processing of your Personal Data

1. General rights

In connection with the processing of personal data, you have the following rights, which you can exercise at any time while storing or processing your personal data by sending an application to the address of SITO 92 Ltd., above, or electronically by email: office@sito92.com .

You have the right to request from SITO 92 EOOD:

  • a copy of your personal data and access to them at any time;

  • to correct without undue delay your inaccurate personal data, as well as data that are no longer up to date;

  • your personal data in a form convenient for transfer to another personal data controller, or to ask us to do so without being hindered by us (right of portability);

  • your personal data to be deleted without undue delay in the presence of any of the legal grounds for this;

  • restrict the processing of your personal data, in which case your data will only be stored but not processed. Our refusal to limit will be explicit only in writing, and we are obliged to motivate it with the lawful reason;

You also have the right to:

  • to withdraw your consent for the processing of your personal data at any time with a separate request addressed to SITO 92 EOOD, in case of processing based on a given consent;

  • object to the processing of your personal data;

  • object to automated processing, including profiling;

  • not be subject to a solution based solely on automated processing involving profiling;

2. You have the right to appeal to the supervisory authority

You have the right to file a complaint directly to the supervisory authority, the competent authority being the Commission for Personal Data Protection, address: Sofia 1592, Blvd. "Prof. Tsvetan Lazarov ”№ 2 ( www.cpdp.bg ).

In case you wish to file a complaint regarding the processing of your personal data by SITO 92 EOOD, you can do so on the contact details of the Administrator (on the above contact details).

3. Objection to use for direct marketing

You have the right to object to the future processing of your personal data for the purposes of direct marketing and advertising, as well as to their disclosure to third parties and their use on their behalf for the purposes of direct marketing and advertising, by withdrawing your consent. anytime. For this purpose, you can send an e-mail with the relevant request to stop using your data for the purposes of direct marketing to: office@sito92.com .

4. Can you refuse to provide personal data to SITO 92 EOOD and what are the consequences of this?

In order to enter into a contract with you and / or to provide you with the ordered products and / or services and / or to deliver the ordered goods in accordance with our legal and subsequent contractual obligations, SITO 92 EOOD needs certain data to identify the country. under the contract, her proxy, contact details, payment details.

Failure to provide such information prevents us from entering into a contract with you.

In order to receive certain information from our Site, you must have created an account on the Site. During the process of creating a profile, SITO 92 Ltd. needs certain data to identify you, contact information. Failure to provide such data limits your ability to use the Site.

VIII. How we protect your data

SITO 92 Ltd. applies organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and the monitoring of personal data processing.

Among other things, such security measures include the following activities:

- SITO 92 EOOD has established the requirements for processing, registration and storage of personal data with the internal procedures, the observance of which is constantly monitored;

- the access of the employees of SITO 92 EOOD to personal data and the permission for processing of personal data in the database of SITO 92 EOOD is limited, depending on their obligations;

- SITO 92 EOOD has established confidentiality obligations for its employees;

- the access to the office equipment of SITO 92 EOOD and the computers of each employee is limited.

- we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as the best practices of international standards.

- In order to ensure maximum security in the processing, transmission and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.

The security measures we apply are subject to constant improvement and adaptation to the latest technologies.

IX. Link to other sites

Sometimes the Site may contain links (hyperlinks) to other sites. We do not operate the linked sites and do not endorse the content, services and products of these sites. We advise you to use the linked sites carefully and with due regard to their content and terms of use. SITO 92 Ltd. is not responsible for the privacy policy or the content of such sites and we advise you to review their privacy policies. However, as soon as SITO 92 EOOD receives information about illegal activities or illegal information on such Internet pages, SITO 92 EOOD will take immediate measures to remove the electronic links to them.

X. Cookies Policy

How to control cookies

Cookies are small pieces of data stored in the browsers of site visitors, usually used to track their movements and actions on a site.

In accordance with the GDPR, as our visitors we inform you that we use cookies on our site.

We use two types of cookies:

Session cookies (transient): These cookies are deleted when you close your browser and do not collect information from your computer. They usually store information in the form of session identification that does not personally identify the user.

Persistent (or saved) cookies: These cookies are stored on your hard drive until they expire (ie based on a specific expiration date) or until they are deleted. These cookies are used to collect personally identifiable information, such as web browsing behavior or site-specific user preferences.

Take a look at the table below to see which cookies are on our site:

Name of the Life Purpose cookie

svSession constantly Communication between the site owner and the visitor (Wix Chat)

hs Session during the Security session

XSRF-TOKEN constant Security

smSession permanently (two weeks) Identifies the members entering the site

TSxxxxxxxx (where x is replaced by any sequence of numbers and letters) constant Security

TSxxxxxxxx_d (where x is replaced by any sequence of numbers and letters) constant Security

The

It is also possible to use cookies, which are not listed in the table above.

You can check which cookies are used on these platforms using Chrome's built-in cookie view. All you have to do is click on Secure next to the URL bar and then on cookies. Make sure you browse your site in incognito mode so that your browser does not recognize cookies that are currently in your own browser.

Personal data for children

We do not knowingly collect personal information from children under the age of 16. If we learn that we have collected personal information from a child under the age of 16, we will take steps to delete the information as soon as possible or obtain the consent of the person responsible for the child.

Amendments to the Privacy Policy

We may periodically update our Privacy Policy. In the event of a change in this policy, a notice will be published on our website, as well as the updated Privacy Policy. All changes and additions to the Privacy Policy will be applied only after the publication of its current content, available through our Site.

Working time

Monday - Friday: 09:00 - 17:30

Saturday and Sunday:

non working days

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