This policy aims to explain why and how we process your personal data. Our policy is fully compliant with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons in connection with the processing of personal data and on the free movement of such data and on the repeal of Directive 95/46/EC (General Data Protection Regulation), and presents detailed information, both on the rights of data subjects and on the data protection principles we have adopted when processing them.
I. BASIC CONCEPTS IN POLICY
„Personal data“ – any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by an identifier such as a name, an identification number, location data, an online identifier or by one or more characteristics specific to the physical, the physiological, genetic, psychic, mental, economic, cultural or social identity of that natural person;
„Processing“ – means any operation or set of operations performed on personal data or a set of personal data by automatic or other means such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, distribution or other the manner in which the data is accessed, arranged or combined, restricted, deleted or destroyed;
„Administrator“ – any natural or legal person, public body, agency or other structure that alone or jointly with others determines the purposes and means of processing personal data; where the purposes and means of this processing are determined by EU law or the law of a Member State, the controller or the special criteria for its determination may be established in Union law or in the law of a Member State;
„Consent of the data subject“ – any freely expressed, specific, informed and unequivocal indication of the will of the data subject, by means of a statement or clear affirmative action, which expresses his consent to the personal data relating to him being processed;
„Recipient“ – natural or legal person, public body, agency or other structure to which the personal data is disclosed, whether or not it is a third party. At the same time, public authorities that may receive personal data within the framework of a specific investigation in accordance with Union law or the law of a Member State are not considered “recipients”; the processing of this data by the specified public authorities complies with the applicable data protection rules in accordance with the purposes of the processing;
„Third side“ – any natural or legal person, public authority, agency or other body other than the data subject, the controller, the personal data processor and the persons who, under the direct supervision of the controller or the personal data processor, have the right to process the personal data;
II. CONTACT INFORMATION:
Web To Spec Ltd
Plovdiv, Veliko Tarnovo Str. №24
Email : grow@webtospec.com
III. PRINCIPLES WE FOLLOW:
Web Two Spec EOOD, as a personal data administrator, has adopted the following principles for the processing of personal data:
• legality, good faith and transparency;
• limitation of collection purposes (specific, explicitly stated and legitimate purposes);
• data minimization;
• storing accurate and up-to-date data;
• limitation of storage, for a period not longer than necessary to fulfill the objectives;
• integrity and confidentiality by ensuring an appropriate level of personal data security.
IV. DATA WE COLLECT:
Depending on the specific goals and grounds, Web Two Spec EOOD processes the data below individually or in combination:
• two names, telephone and/or e-mail address to contact you, or a contact person specified by you
V. PURPOSES AND LEGAL BASIS FOR WHICH WE PROCESS DATA
In order to carry out our commercial activities normally, as well as to fulfill our obligations as an employer, we need certain data, which if we do not receive, we have no reason to have relations with you. This is data that we need in order to:
• Contractual relations, including employment law, as well as with customers and suppliers of goods and services, including informal ones, for which the processing is necessary for the fulfillment of our obligations and the exercise of our special rights as an administrator;
• Accounting and reporting of relations with data subjects;
• To fulfill a legal obligation to provide this data to state bodies and institutions;
• To fulfill a legal obligation to provide this data to third parties.
Web To Spec EOOD processes your data for the following purposes:
Customer or supplier identification for:
• To respond to your inquiries, refund requests and complaints. Working with the information you provide allows us to respond to you effectively. We may also keep a record of these inquiries to inform you in future communications between us. We only process this data based on our contractual obligations to you, our legal obligations and our legitimate interests, in order to provide you with the best service;
• To communicate with you in case of changes to our services or in connection with those requested by you, as well as if there is an inquiry or problem with your orders;
• Normative obligation to provide this data to state bodies and institutions;
• For bank or cash payments between the enterprise and the data subject;
• To update your personal data upon your request for correction (change of data);
• To conduct correspondence and collect claims by extrajudicial or judicial order.
Web To Spec EOOD processes your data on the following grounds:
• Consent from the data subject;
• Contractual Obligation;
• Legal obligation;
• Protection of vital interests or task of public interest;
• Exercise of official powers;
• Legitimate interests of the controller.
VI. THIRD PARTIES WHO ACCESS AND PROCESS YOUR PERSONAL DATA:
• Personal data processors who, based on a contract with Web Two Spec EOOD, process your personal data on behalf of the company or have direct/indirect access to your personal data;
• Transport / courier companies with a view to fulfilling our contractual obligations to deliver goods and / or services;
• Persons who, on behalf of Web To Spec EOOD, maintain equipment and software used to process your personal data;
• Banks handling payments between us;
• Persons performing consulting services in various fields;
• Competent authorities that, by virtue of a regulatory act, have the authority to demand from us the provision of information, including personal data, such as – National Insurance Agency, National Insurance Institute, National Health Insurance Fund, Bulgarian court or court of another country, various supervisory / regulatory authorities – Commission for consumer protection, Labor Inspection, authorities with powers to protect national security and public order;
Your personal data may be disclosed by the company, provided that this is permitted by law, in connection with a corporate restructuring, sale, transfer of assets, merger, merger or other form of transformation, or any other form of change in the corporate or financial structure of the enterprise or its related legal entities.
Personal data may also be disclosed to protect vital interests of the individual, legitimate interests of the company (unless the rights and freedoms or interests of the individual, as a data subject, should prevail over these interests of the company) or when, on Company’s discretion, this is necessary for the Company to comply with applicable law or fulfill its obligations under law or to respond to requests or questions from competent supervisory authorities.
VII. STORAGE PERIOD OF YOUR PERSONAL DATA
The duration of storage of your personal data depends on the processing purposes for which they were collected:
• Personal data processed for the purpose of providing a service, concluding / amending and executing a contract are stored for the duration of the contract and until the final settlement of all financial relations between the parties, and when they are processed for the purpose of issuing accounting / financial documents for implementation of tax and insurance control, which have the quality of documents for tax control, audit and subsequent financial inspections are stored for 10 years, after the end of the reporting period following the reporting period to which the data refer, according to the Accounting Act, or for another a longer period if the applicable legislation provides for it.
• Personal data processed for the purpose of concluding, acting, amending and terminating an employment relationship are stored for the duration of the employment relationship and final settlement of all financial relationships between the parties, as well as for a period of 50 years after the termination of the legal relationship, when the same make up payrolls, employment contracts (appointment orders), reassignment orders, orders for unpaid leave of more than 30 working days, orders for termination of employment relationships, employment records and other documents establishing the insurance experience and income of the persons who have worked in the enterprise.
• Personal data collected on the basis of consent – until its withdrawal or 3 months, whichever occurs first (if collected in electronic form on our electronic site or received in writing at the administrator’s official address).
VII. STORAGE PERIOD OF YOUR PERSONAL DATA
The duration of storage of your personal data depends on the processing purposes for which they were collected:
• Personal data processed for the purpose of providing a service, concluding / amending and executing a contract are stored for the duration of the contract and until the final settlement of all financial relations between the parties, and when they are processed for the purpose of issuing accounting / financial documents for implementation of tax and insurance control, which have the quality of documents for tax control, audit and subsequent financial inspections are stored for 10 years, after the end of the reporting period following the reporting period to which the data refer, according to the Accounting Act, or for another a longer period if the applicable legislation provides for it.
• Personal data processed for the purpose of concluding, acting, amending and terminating an employment relationship are stored for the duration of the employment relationship and final settlement of all financial relationships between the parties, as well as for a period of 50 years after the termination of the legal relationship, when the same make up payrolls, employment contracts (appointment orders), reassignment orders, orders for unpaid leave of more than 30 working days, orders for termination of employment relationships, employment records and other documents establishing the insurance experience and income of the persons who have worked in the enterprise.
• Personal data collected on the basis of consent – until its withdrawal or 3 months, whichever occurs first (if collected in electronic form on our electronic site or received in writing at the administrator’s official address).
Use of collected personal data for marketing purposes:
User data is collected to allow Web Two Spec EOOD to provide its services, as well as for the following purposes: advertising, contact with the user, analysis, remarketing and behavioral targeting, interaction with external social networks and platforms, registration and authentication of authenticity, content commenting, content and functionality testing (A/B testing), display of content from external platforms, payment processing, delivery processing, hosting and infrastructure maintenance, monitoring, interaction with data collection platforms and others third parties for sending messages.
Detailed information on the processing of personal data on webtospec.com:
ADVERTISEMENT
This type of service allows the use of user data for the purposes of advertising communication, displayed in the form of banners and other advertisements based on the interests of users of our site. Some of the services listed below may use cookies to identify users or use behavior retargeting techniques, i.e. to display advertisements tailored to the user’s interests and behavior, including those found outside of webtospec.com. For more information, please check the privacy policies of the respective services.
1.1. DATA AND ANALYSIS ABOUT ACCESS AND BEHAVIOR ON OUR WEBTOSPEC.COM SITE
When you access and use our website, we receive information that we use only for statistical purposes and to protect against unauthorized access to the content we offer on the Internet. This helps us to tailor and optimize our website according to the needs of users and to improve the services and products we offer.
We do not create personal profiles of individual users of the page. In this regard, we use the following usage aggregated statistical data: page from which access to the relevant file was requested, file name, date and time of access, volume of information transferred, access status, (file transfer, file not was found, etc.), a description of the type of web browser used, the town from which the access was made, the time spent on the page, the number of pages viewed, the page from which the site was left and an anonymized IP address (through the Google program Analytics).
Google Analytics is a web analysis service provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”). Google uses the collected data to track and study the use of our website, prepare reports on its activities and share them with other Google services. We use Google Analytics on our website for anonymous reporting of site usage and for site advertising. Google may use the collected data to contextualize and personalize the advertisements of its own advertising network. Place of processing of your personal data: United States of America.
Please read Google’s Privacy Policy here: https://policies.google.com/privacy?hl=en
If you want to opt out of Google Analytics tracking your behavior on our site, please do so here: https://tools.google.com/dlpage/gaoptout?hl=en
1.2. ONLINE ADVERTISING THROUGH GOOGLE ADS
Google Ads are integrated on our website webtospec.com. Google Ads is an internet advertising service that allows Web To Spec EOOD as an advertiser to advertise in search results with the Google search engine, as well as Google’s advertising and partner network. Google Ads allows an advertiser to pre-determine specific keywords that only display an ad in Google search results when a user uses the search engine to retrieve a keyword-related search result. In the Google advertising network, ads are distributed on relevant web pages using an automatic algorithm, taking into account predefined keywords. The operating company of Google Ads is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, United States of America.
GoogleAds collects visit statistics for our website. Neither our company nor other GoogleAds advertisers receive information from Google that can personally identify the data subject. The data subject can at any time prevent the setting of cookies by our website and oppose Google’s interest-based advertising. Therefore, the data subject must access from any browser using the https://adssettings.google.com/authenticated link and set the desired settings.
1.3.FACEBOOK MARKETING
On our website webtospec.com we have integrated components of the social network Facebook. Facebook’s operating company is Meta Platforms Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If a person lives outside the United States or Canada, the controller is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
Each time you access one of the individual pages of this website, which is operated by the administrator and in which the Facebook component (Facebook plugins) is integrated, the web browser of the information technology of the data subject is automatically activated to download the display of the corresponding Facebook component from Facebook via the Facebook component. An overview of all Facebook plugins can be accessed at https://developers.facebook.com/docs/plugins/. During this technical procedure, Facebook is notified of which specific subsite of our website has been visited by the data subject.
If the user is logged in to Facebook and accesses our website, Facebook also receives information about the entire period of stay on our website – which specific subpage of our website was visited. If such transmission of information to Facebook is not desired by the user, he or she can prevent this by logging out of his or her Facebook account before accessing our website.
The data protection guide published by Facebook is available here: https://facebook.com/about/privacy/
2. REMARKETING AND BEHAVIORAL TARGETING
On the website webtospec.com, the administrator has integrated the remarketing services of Google and Facebook.
Google Remarketing is a feature of Google Ads that allows us to display advertisements to Internet search engine users who have previously visited our website. The operator of Google’s remarketing services is Google Inc., 1600 Amphitheater Pkwy, Mountain View, CA 94043-1351, United States of America.
The purpose of remarketing on Google is to show ads that are relevant to users’ interests. Google remarketing allows us to display ads on the Google Network or on other partner websites that are based on individual needs and match the interests of our users.
The data subject can prevent the setting of cookies via our website at any time by means of the appropriate adjustment of the web browser used and thus definitively refuse the setting of cookies. In addition, the user of our site has the option to object to interest-based advertising by Google. For this purpose, he must call the link to https://adssettings.google.com/authenticated and make the desired settings for each Internet browser he uses.
Further information and the actual data protection regulations of Google can be retrieved at https://www.google.com/intl/bg/policies/privacy/.
On our website, we use the Facebook Conversion Pixel and Facebook Remarketing services. The information collected with their help is intended for the preparation of statistics on the success and usage of our Facebook ads, as well as for targeted targeted advertising.Data in this process is aggregated and anonymized.
Please read more information about the purposes and scope of the collection and processing of your personal data by Facebook, as well as the options for settings to protect your privacy here: https://www.facebook.com/policy.php.
3. SITE CONTACT FORMS
Our website contains functionality that allows quick electronic contact with Web Two Spec Ltd., by sending an email address, as well as direct communication with us by phone. If a data subject contacts us by e-mail or via the contact form on the site, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or feedback to the data subject. There is no transfer of this personal data to third parties, unless this is necessary to place an order, correct delivery or order information, issue a payment document, claim, request an exchange or return a product, as well as to provide administrative and control bodies that have the right to receive it.
By manually filling out the contact form with the necessary personal data, the user allows us to use this data for the above. We collect the following personal data: address, city, names, email address, text content of the message as well as attachments, order number.
4. SENDING MESSAGES AND NEWSLETTER
On our website, webtospec.com, users are given the opportunity to subscribe to our monthly newsletter. Web Two Spec EOOD regularly informs its customers through a newsletter about special offers, promotions, the opportunity to participate in games.
The company newsletter can only be received by the data subject if:
the data subject has a valid email address through which he registered and
the mail the user uses is registered to receive the newsletter.
At their request, users could also provide the following data: address, first and last name. The user will receive a confirmation of inclusion in our email list through the double opt-in procedure at the e-mail address specified by him. This confirmation email is used to prove that the owner of the email address as the data subject expressly agrees to receive the newsletter.
During registration for the newsletter, we also store the IP address of the computer system assigned by the Internet Service Provider (ISP) and used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary to understand the (possible) misuse of the e-mail address of the data subject at a later date and therefore serves the purpose of legal protection of the controller.
Personal data collected as part of newsletter registration will only be used to send our newsletter.In addition, newsletter subscribers may be informed by e-mail as far as this is necessary for the functioning of the newsletter or the registration in question, as this may happen in the event of changes to the offer of the newsletter, or in the event of a change in technical circumstances .
The subscription to our newsletter can be terminated by the data subject at any time. The consent to the storage of personal data that the data subject has provided for sending the newsletter can be revoked at any time. For the purpose of revocation of consent, the corresponding hyperlink is located in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the administrator’s website or to communicate this to the administrator in a different way – via the contact form or direct email. Going forward, your email address will be immediately deactivated in our e-newsletter recipient list and you will no longer receive e-newsletters from us. After unsubscribing, your data will be deleted.
We use the Brevo platform, which is a messaging service provided by The SENDINBLUE LLC. It collects the following personal data: “cookies”, e-mail address, first name, last name and data on the response to the newsletter such as time and place of opening, operating system, internal links clicked and how many times, orders placed and others. Place of processing of this data: United States of America. For European citizens contacts: 106 boulevard Haussmann, 75008 Paris, France, contact@brevo.com
Please review Brevo’s privacy policy here: https://www.brevo.com/legal/privacypolicy/
If you have any questions about the security of your personal information at Brevo you can contact them at the following address: dpo@brevo.com
IX. YOUR RIGHTS
The Company provides and maintains appropriate technical and organizational measures to protect the personal data of individuals against unauthorized access or illegal use and/or against their accidental loss, modification, disclosure, access and/or damage or copying. These measures are intended to ensure the continued protection and privacy of personal data. The company evaluates the measures regularly in order to achieve permanent security of your personal data.
As our customer or employee in relation to your personal data, you have the following rights:
• of access to your personal data and information of the kind that we have included in this Policy in relation to the data in question. You can ask the company for information on whether, for what purposes and on what grounds we process your personal data with a written application;
- request that your personal data be corrected or deleted, as well as restrict the processing of personal data;
- withdraw your consent to the processing of your personal data only when the processing is based on your consent;
• of objection to the processing of personal data;
- data portability;
- file a complaint with the Commission for Personal Data Protection Address: Sofia 1592, “Prof. Tsvetan Lazarov” No. 2, tel. 02/91-53-518; Email: kzld@cpdp.bg; and seek legal protection of your rights;
- to be informed in writing about the actions taken on your request for information.
In the event of a significant change in the way Web Two Spec EOOD processes personal data and/or in the types of personal data it processes, the company will notify you of the relevant change on the company’s website.
This policy should be available in the internal company documentation and available to all natural persons whose data the company processes. The policy is subject to updating, in case of changes requiring its updating.