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 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 that
Raytron 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 whom
Raytron 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 R
aytron 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.