Effective from 15.04.2019.
I.
Introduction
Raytron
Group Ltd. respects
the privacy of its clients and guarantees the protection of their
personal data as much as possible. This Privacy and Privacy Policy
(hereinafter referred to as the "Privacy Policy") has been
prepared and is based on current Bulgarian and European legislation
on data protection.
This Privacy Policy governs the processing
of personal data by individuals or agents of legal entities of our
clients or potential clients, as well as users of our websites:
www.raytron.eu, www.hotellobg.eu
and www.4controlshop.eu, hereinafter referred to as the "Site"
in connection with the services provided by the Raytron
Group, including
provided through and available on the Site.
This Privacy Policy,
along with the General Terms and Conditions for Use of the Site and
the Cookie Policy and any other documents mentioned on the Site, sets
forth the rules thatRaytron
Group will observe
in processing personal data that we collect from you either to you or
to us. This Privacy Policy does not affect, limit or invalidate your
rights under the Personal Data Protection Act ("PDPA") or
other relevant legislation.
If you have any questions or
comments about this Privacy Policy, please contact us at
info@raytron.eu
Please
read this Policy carefully before using the Site or providing your
Personal Information, whether electronically on the Site or on paper,
as with the provision of your Personal Information you agree to its
terms and conditions. If you do not wish to process your personal
information in the manner described in this Privacy Policy, please do
not provide it to us. The provision of personal data on your behalf
is voluntary, in order to use certain services provided by us and the
use of the Site and/or access to it. Keep in mind that in some cases
we will not be able to provide you with the service or goods you have
requested if you do not provide us with the necessary information.
II.
Who processes and is responsible for your personal data?
Raytron
Group Ltd is a commercial company registered in the Commercial
Register of the Registry Agency under UIC 131186415, which collects,
processes and stores your personal data under the terms of this
Privacy Policy. Raytron Group is an
administrator of personal data within the meaning of the Personal
Data Protection Act (PDPA). You can contact us at any of the
following locations:
Office:
Sofia, 1527, 3, Hristo Kovachev str
phones: 02/9433145,
9433647
e-mail: info@raytron.eu
III.
Categories of personal data processed by Raytron
1.
Raytron Group may process the publicly available
personal data and/or personal data provided by you. The main types of
personal data processed are:
•
Personal identification information (including name, PIN, ID number,
place of residence, nationality, language of communication,
etc.);
• Information about the field
of activity (including education, educational institution, workplace,
a position occupied, etc.);
• Contact
details (including postal and e-mail addresses, telephone and fax
numbers, etc.);
• Financial
information (bank account and others);
•
Information about a legal representative (legal representative or
proxy) of a legal entity customer;
•
Data from the communication between us and you, your habits,
preferences, your satisfaction with our services (service activity,
complaints, requests, etc.);
•
Information on site visits and use of the Site, including operations
and history of use of the Site;
• Data
obtained from the performance of obligations deriving from regulatory
acts (ie data resulting from inquiries, regulations, investigative
bodies, notary, tax offices, court, executor);
•
Data obtained from the performance of contractual obligations
(including name, PIN, address, telephone and/or e-mail address,
etc.).
• Data when creating a Site
Profile (Name, Email Address, Phone, Address)
2. Raytron
Group may process data generated and generated by
Raytron in the process of providing the
services:
• Data about the final
electronic communication device used, the type of the device, the
operating system used, the IP address, the location;
•
Details of your preferred goods and services;
3. In order to
ensure the proper execution of the services and obligations arising
from client contracts, Raytron is
entitled to process any information that is available in public
registers (including public database and data disclosed on the
Internet) as well as information obtained from third parties
regarding the implementation of legal provisions regarding
customers.
4. Raytron Group
has the right and the duty to verify the accuracy of the personal
data stored in the database and for this purpose requires you to
verify the data and, if necessary, to correct or verify the
correctness of your data.
5. Various types of personal data may
be processed individually or in combination.
IV.
Objectives and legal bases for the processing of personal data
1.
The processing of personal data that is necessary for the conclusion
or performance of contracts with us or in connection with the
preparation for concluding contracts with us.
Raytron Group
processes your data for the following purposes:
•
Identify a customer upon signing a new or changing an existing
contract with us; explanations of the services used; performance of a
contract.
• Making proposals for
signing contracts, sending pre-contractual information and draft
contract;
• Data obtained from you in
fulfilling obligations arising from contracts concluded with you or a
represented company, exercise of rights and ensuring the performance
of contracts by our clients;
• Service
and response to customer complaints / inquiries / complaints /
complaints;
• Technical assistance for
creating an account (s) and recovering a forgotten password to access
our Site for electronic service of electronic invoices.
•
Technical maintenance and troubleshooting and any technical problems
- on site and through remote access to your equipment.
•
Payment of obligations, rescheduling of amounts due;
•
Warranty and service;
2. By performing legal obligations,
Raytron Group processes your data for the following
purposes:
Invoices issuing;
• To
carry out tax and social control by the respective competent
authorities;
• Obligations stipulated
in the Accountancy Act and the Tax and Social Insurance Procedure
Code and other related normative acts in connection with the conduct
of correct and lawful accounting.
3. Raytron Group processes the
relevant data provided with the explicit written consent of the
client for their processing for the following purposes:
•
Data when creating a profile on the Site;
•
For direct marketing of products and services;
•
Electronic bulletin;
• Data provided
by you when participating in raffles, polls, games, etc.
4.
Processing is necessary for the legitimate interests of Raytron
Group.
• Evaluating and identifying
user satisfaction as well as advertising performance;
•
Analysis of customer purchase history, customer preferences, and
behavior;
V.
Categories of third parties who access and process your personal
data
1.
Transport/courier companies, postal operators with a view to
fulfilling our contractual obligations, sending correspondence and
communications, in connection with the contract between us;
2.
Persons who, under the assignment of the Raytron Group,
maintain equipment and software used to process your personal
data;
3. Providers of debt collection
service, notary, lawyer, bailiff or other third parties, if the
client has breached the obligation arising from a contract with
us;
4. Banks servicing payments made by
you;
5. Persons to whomRaytron
Group has provided the performance of part of the
service or service obligations we owe to you;
6.
Persons performing consultancy services in different spheres -
lawyers, accountants, etc .;
7. Bodies,
institutions, and persons to whom we are obliged to provide personal
data under current legislation.
VI.
How long is your personal data stored?
The
length of time that your personal data is stored depends on the
processing purposes for which it was collected:
1. Personal data
processed for the purpose of concluding/modifying and executing
contracts between Raytron Group and you or a represented company for
the duration of the agreement and for the final settlement of all
financial relations between the parties. Raytron may store some of
your personal data for a longer period of time until the expiration
of the applicable limitation period in order to protect any customer
claims regarding performance/termination of contracts with us and for
a longer term in the event of a legal dispute has already arisen
until its final settlement by a court / arbitration award that has
entered into force.
2. Personal data processed for the purpose
of issuing accounting / financial documents for the implementation of
tax and social security controls, but not only-invoices, debit notes,
credit notes, delivery / delivery protocols, service contracts /
goods shall be kept at least 11 years after expiry of the limitation
period for repayment of the public claim, unless the applicable law
provides for a longer period.
3. Personal data processed for the
purpose of direct marketing - to the explicit withdrawal of the given
direct marketing consent or receipt of an objection to the processing
of personal data for direct marketing.
4. Personal data when
creating a profile on the Site - until the explicit withdrawal of the
given consent or receipt of an objection to the processing of
personal data from the profile of the Site.
5. Photography
and/or video data provided by you when participating in lotteries,
polls, games, and more. - until the explicit withdrawal of the
consent or receipt of an objection to the processing of personal
data.
VII.
Your Rights in relation to the processing of Your Personal
Information
1. General rights
In relation to the
processing of personal data, you have the following rights you may
exercise at any time while we store or process your personal data by
sending an application to the address of the Raytron Group mentioned
above or electronically by e-mail: info @ raytron.eu
You have
the right to ask us:
• A copy of your
personal data and access to them at any time;
•
Correct without undue delay, inaccurate personal data, and data that
are not current;
• Your personal data
in a form convenient to transfer to another data controller, or ask
us to do so without being impeded by us (the right of
portability);
• Your personal data may
be deleted without undue delay in the presence of any of the legal
grounds for doing so;
• Restrict the
processing of your personal data, in which case your data will only
be stored but not processed. Our refusal to restrict will be explicit
only in writing, and we are obliged to motivate it for the legitimate
reason;
You may also:
• Withdraw
your consent to the processing of your personal data at any time with
a separate request addressed to the Raytron Group upon consent-based
processing;
• To object to the
processing of your personal data;
•
Objection to automated processing, including profiling;
•
Do not be the subject of a decision based solely on automated
processing including profiling.
2. You have a right to appeal to
the supervisory authority
You have the right to submit a
complaint directly to the oversight body and the competent authority
is the Personal Data Protection Commission, address: Sofia 1592,
"Prof. Tzvetan Lazarov "№ 2 (www.cpdp.bg).
If you
wish to file a complaint about the processing of your personal data
by the Raytron Group, you can do so at the contact details of the
Administrator (the above mentioned contact details).
3.
Automated decision making
The administrator does not use your
personal data for automated decision making. In the event that we
intend to use your personal data for automated decision making, you
are entitled to be informed and therefore to receive information
about the logic of any automated processing of personal data relating
to you.
4. Opposition against 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 disclosure to third parties and their use on their behalf for the
purposes of direct marketing and advertising by withdrawing your
consent anytime. To do so, you may send an email with the request to
discontinue use of your data for direct marketing purposes at
info@raytron.eu
5. Can you refuse the release of personal data
to Raytron Group and what are the consequences of this?
In order
to conclude a contract with you and / or to provide you with the
requested products and / or services and / or to deliver the ordered
goods in accordance with our statutory and consequent contractual
obligations, Raytron needs certain data to identify the party to the
contract, its proxy, contact details, payment details of the
obligations.
Not providing such data prevents us from signing a
contract with you.
VIII.
How we protect your data
Raytron Group applies
organizational, physical, IT, and other necessary measures to ensure
the security and protection of your personal data and the monitoring
of the processing of personal data.
Among other things, such
security measures include the following activities:
•
There are established procedures for the processing, registration,
and storage of personal data by internal procedures in Raytron Group,
the observance of which is constantly observed;
•
The access of Raytron Group employees to personal data and permission
to process personal data in the Raytron Group database is limited,
depending on their obligations;
•
Access to the office equipment of Raytron Group and the computers of
each employee is limited and is done after identification;
•
We apply with all necessary organizational and technical measures
provided by the Personal Data Protection Act, as well as the best
practices of international standards;
•
For maximum security when processing, transferring and storing your
data, we may use additional protection mechanisms such as encryption,
anonymization, and more.
The security measures we apply are
subject to constant improvement and adaptation to state-of-the-art
technologies.
IX.
Link to other sites
Sometimes the Site may contain
links/hyperlinks to other sites. We do not operate the linked sites
and we do not approve the content, services, and products of these
sites. We encourage you to use the linked sites carefully and with
due attention to their content and terms of use. Raytron Group is not
responsible for the privacy policy or the content of these sites and
we encourage you to review their privacy policies. However, as soon
as Raytron Group receives information about illegal activities or
illegal information on such websites, we will take immediate action
to remove the electronic links (links) to them.
X.
Cookie Policy
To learn about the Cookies Policy, please
visit the Cookies Policy
Personal
data for children
We do not consciously collect personal
information from children under the age of 16. If we learn that we
have collected personal information on 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 bearing the parental responsibility
for the child.
Amendments
to the Privacy Policy
We may periodically update our Privacy
Policy. Upon a change in our policy, a message will be posted on our
website as well as the updated Privacy Policy. Any amendments and
additions to the Privacy Policy will be applied only after publishing
its current content available through our Site.