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Privacy policy

Privacy Policy for www.adsparx.com

I. GENERAL INFORMATION

The protection of personal data and the privacy of our website visitors, clients and partners is important to us.

This Privacy Policy is intended to explain in a clear and transparent manner what personal data we collect through www.adsparx.com and when communicating with us, for what purposes we use such data, the legal grounds on which we process it, how long we retain it, with whom it may be shared and what rights you have.

Personal data is processed in accordance with:

  1. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – the General Data Protection Regulation (“GDPR”);

  2. The Bulgarian Personal Data Protection Act;

  3. The applicable provisions of the Bulgarian Electronic Commerce Act and other applicable Bulgarian and European legislation.

This Privacy Policy primarily applies to cases in which ADSPARX acts as a personal data controller.

Where, in connection with the provision of marketing, advertising or other services, ADSPARX processes personal data on behalf of and under the instructions of a client, the Company may act as a personal data processor. In such cases, the terms of processing shall be governed by the relevant agreement between ADSPARX and the client and by the applicable provisions of the GDPR.

II. WHO IS THE DATA CONTROLLER?

The personal data controller is:

ADSPARX EOOD

UIC: 207674217

Registered office and management address: 19 Lavski Rid St., Vitosha District, Sofia, Bulgaria

Website: www.adsparx.com

Email: hello@adsparx.com

Hereinafter in this Privacy Policy, the company may be referred to as “ADSPARX”, the “Company”, “we”, “us” or “our”.

III. WHAT PERSONAL DATA MAY WE PROCESS?

Depending on the way in which you use www.adsparx.com or otherwise interact with us, we may process different categories of personal data.

1. Identification and contact data

This may include:

  1. First and last name;

  2. Company and job title;

  3. Telephone number;

  4. Email address;

  5. Other contact information voluntarily provided by you.

2. Data provided when submitting an enquiry

When you contact us through a contact form, by email, telephone or another communication channel, we may process:

  1. Information contained in your enquiry;

  2. Information about your company, project, product or service;

  3. Your budget or approximate budget, where voluntarily provided;

  4. The type of service you are interested in;

  5. Materials, files or other information submitted by you;

  6. Correspondence between you and ADSPARX.

Please do not provide personal data that is not necessary for us to process your enquiry.

3. Data relating to contractual relationships

When you become our client, supplier, subcontractor or partner, we may process:

  1. Identification data;

  2. Contact details;

  3. Information relating to the company you represent;

  4. Data contained in agreements, quotations, assignments and other correspondence;

  5. Data required for invoicing and accounting purposes;

  6. Information relating to payments made or received;

  7. Other data necessary for the performance of the relevant relationship.

4. Technical data

When you visit www.adsparx.com, certain technical information may be processed automatically by our server, hosting infrastructure or the technologies used on the website, including:

  1. IP address;

  2. Browser type and version;

  3. Device type and operating system;

  4. Date and time of visit;

  5. Pages visited;

  6. Technical logs relating to website security and functionality;

  7. Identifiers associated with cookies or similar technologies, where such technologies are used.

The use of non-essential cookies and similar technologies shall be subject to your choice where prior consent is required by law.

5. Payment data

Where payment is made by bank transfer, we may receive the information normally contained in a payment order or bank statement, such as the payer’s name or company name, IBAN, payment reference and payment amount.

ADSPARX does not request or store full payment card details through www.adsparx.com unless a separate payment functionality is introduced in the future, in which case the relevant information will be provided accordingly.

IV. HOW DO WE OBTAIN YOUR PERSONAL DATA?

We primarily obtain personal data directly from you when you:

  1. Complete a contact form on www.adsparx.com;

  2. Send us an email;

  3. Contact us by telephone;

  4. Request a consultation or quotation;

  5. Enter into negotiations regarding the provision of a service;

  6. Enter into an agreement with us;

  7. Subscribe to marketing communications, where such functionality is available;

  8. Communicate with us through another official communication channel.

In certain cases, we may also receive business contact details from the company you represent, from one of our clients or partners, or from publicly available professional and business sources where this is necessary for lawful business communication.

V. FOR WHAT PURPOSES AND ON WHAT LEGAL GROUNDS DO WE PROCESS PERSONAL DATA?

Personal data is not processed on one single legal basis. The applicable legal basis depends on the specific purpose of the processing.

1. Processing enquiries and preparing quotations

We use the data provided by you in order to:

  1. Respond to your enquiry;

  2. Understand your needs;

  3. Conduct a preliminary consultation;

  4. Prepare a proposal or individual quotation;

  5. Take other steps requested by you before entering into a potential agreement.

Where the enquiry relates to the possible conclusion of an agreement with the individual concerned, the legal basis is Art. 6(1)(b) GDPR – taking steps at the request of the data subject prior to entering into a contract.

In B2B communications involving representatives or employees of legal entities, processing may be based on Art. 6(1)(f) GDPR – the legitimate interests of ADSPARX and the relevant organisation in carrying out normal business communication and developing contractual relationships.

2. Entering into and performing an agreement

Where processing is necessary for entering into or performing an agreement with an individual, the legal basis is Art. 6(1)(b) GDPR.

Where the contracting party is a legal entity, the personal data of its representatives and employees may be processed on the basis of Art. 6(1)(f) GDPR – legitimate interest in performing and managing the contractual relationship.

3. Accounting, tax and other legal obligations

Certain personal data may be processed where necessary to comply with applicable legal obligations, including for:

  1. Accounting purposes;

  2. Issuing and retaining accounting documents;

  3. Taxation and tax control;

  4. Compliance with obligations towards competent public authorities.

The legal basis is Art. 6(1)(c) GDPR – compliance with a legal obligation.

4. Protection of the rights and legitimate interests of ADSPARX

We may retain and use information where necessary for:

  1. Establishing, exercising or defending legal claims;

  2. Preventing abuse;

  3. Ensuring the security of www.adsparx.com;

  4. Resolving disputes;

  5. Demonstrating communications or agreed contractual terms.

The legal basis is Art. 6(1)(f) GDPR – legitimate interest, provided that such interest is not overridden by your fundamental rights and freedoms.

5. Marketing communications and newsletters

Where you have expressly requested to receive a newsletter, marketing offers or other advertising communications and consent is required, the processing shall be based on Art. 6(1)(a) GDPR – your consent.

Consent to receive marketing communications is separate from processing necessary for the performance of an agreement.

Refusing to provide consent for marketing purposes will not affect your ability to submit an enquiry or enter into an agreement with ADSPARX.

6. Analytics and marketing technologies

Where www.adsparx.com uses non-essential analytics, advertising or other tracking technologies requiring consent under applicable law, such technologies shall be activated in accordance with your choice through the relevant cookie consent management mechanism.

VI. WHAT HAPPENS TO YOUR DATA WHEN YOU CONTACT US?

When you submit an enquiry through a form on www.adsparx.com, by email, telephone or another communication channel, we use the information provided to process your enquiry and respond to you.

Where necessary, we may also use the data for subsequent communication relating to the same enquiry, proposal or project.

Submitting an enquiry does not automatically mean that you consent to receiving advertising communications or newsletters.

We will not use data submitted through a contact enquiry for unrelated purposes without an appropriate legal basis.

VII. HOW LONG DO WE RETAIN PERSONAL DATA?

We retain personal data only for as long as necessary for the relevant purpose, unless applicable law requires a longer retention period.

1. Enquiries that do not result in an agreement

Correspondence and information provided may be retained for up to 12 months after the communication has ended, unless:

  1. There is a justified need for a longer retention period;

  2. The information is required in connection with a legal claim or dispute;

  3. The individual has provided separate consent for another purpose;

  4. Applicable law requires a different retention period.

2. Data relating to contractual relationships

Data necessary for the performance of an agreement shall be retained for the duration of the contractual relationship and, after its termination, for a period necessary to protect legal rights and comply with applicable statutory obligations.

Different documents may be subject to different retention periods.

3. Accounting and tax documents

Accounting documents and related information shall be retained for the periods provided for by applicable accounting and tax legislation.

Pursuant to Art. 12 of the Bulgarian Accounting Act, accounting registers and financial statements, including documents for tax control, audits and subsequent financial inspections, are retained for 10 years, calculated from 1 January of the reporting period following the period to which they relate.

Other categories of accounting information are retained for the relevant statutory periods.

4. Data used for marketing communications

Where processing is based on consent, we use the data for the relevant marketing purpose until:

  1. Consent is withdrawn;

  2. The relevant service is discontinued;

  3. Another reason requiring termination of the processing occurs.

We may retain minimal information concerning the withdrawal of consent or an objection where necessary to ensure that your preferences are respected and to demonstrate compliance with our legal obligations.

5. Technical data and logs

Technical and security logs shall be retained for a period necessary to ensure security, diagnose technical issues and prevent abuse, depending on the nature of the relevant log and the system used.

After the applicable retention period expires, the data shall be deleted, anonymised or securely destroyed unless another lawful basis exists for retaining it.

VIII. WITH WHOM MAY WE SHARE PERSONAL DATA?

We do not sell your personal data.

We may provide limited access to personal data to third parties only where this is necessary for a specific lawful purpose.

Such recipients may include:

  1. SuperHosting.BG EAD – in connection with hosting services and the technical infrastructure of www.adsparx.com;

  2. Accountants and accounting service providers;

  3. Banks and other payment institutions in connection with processing and recording payments;

  4. Email, information technology, technical support and cybersecurity providers;

  5. Legal, accounting and other professional advisers;

  6. Subcontractors or partners where access to certain information is necessary for the performance of an agreed service and an appropriate legal basis exists;

  7. Competent public and administrative authorities where disclosure is required by law;

  8. Other recipients where you have provided valid consent or another legal basis exists.

Where a third party processes personal data on our behalf as a data processor, we take the necessary steps to ensure that our relationship with that party is governed in accordance with the requirements of the GDPR.

IX. TRANSFERS OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Certain providers of digital, cloud, analytics or communication services may process information using infrastructure located outside the European Economic Area (“EEA”).

Where such processing constitutes an international transfer of personal data within the meaning of the GDPR, the transfer shall take place only where an appropriate legal basis and safeguard are available, such as:

  1. An adequacy decision adopted by the European Commission;

  2. Standard Contractual Clauses approved by the European Commission;

  3. Another permitted mechanism under Chapter V of the GDPR.

Where applicable, you may contact us at hello@adsparx.com to request further information regarding the safeguards used for an international transfer.

X. COOKIES AND SIMILAR TECHNOLOGIES

www.adsparx.com may use cookies and similar technologies necessary for the proper functionality, security and operation of the website.

Strictly necessary technologies may be used to the extent required to provide functionality explicitly requested by the visitor or to ensure the normal and secure operation of the website.

Analytics, marketing and other non-essential cookies for which consent is required by law shall be activated only in accordance with the choice made through the consent management mechanism.

You may change your choices through the “Cookie Settings” button or panel on www.adsparx.com where such functionality is available.

Withdrawal of consent shall not affect the lawfulness of processing carried out before consent was withdrawn.

Further information regarding cookie categories, providers, purposes and retention periods may be provided in the separate Cookie Policy of www.adsparx.com.

XI. NEWSLETTERS AND MARKETING COMMUNICATIONS

Where ADSPARX provides an option to subscribe to a newsletter or other marketing communications, we will process the email address provided and the information necessary to manage the subscription.

Where applicable law requires consent, such communications shall be sent only after valid consent has been obtained.

You may unsubscribe at any time by:

  1. Using the unsubscribe link included in the relevant email; or

  2. Sending a request to hello@adsparx.com.

Withdrawal of consent is free of charge and does not affect the lawfulness of processing carried out before the withdrawal.

XII. WHAT ARE YOUR RIGHTS?

Where the relevant conditions under the GDPR are satisfied, you have the following rights in relation to your personal data:

1. Right of access

You have the right to obtain confirmation as to whether we process personal data concerning you and, where this is the case, to obtain access to such data and the information concerning the processing required by law.

2. Right to rectification

You have the right to request correction of inaccurate personal data and completion of incomplete data.

3. Right to erasure (“right to be forgotten”)

In the cases provided for by law, you may request the erasure of your personal data.

The right to erasure is not absolute and does not apply where retention is necessary, for example, for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

4. Right to restriction of processing

Where the statutory conditions are satisfied, you may request a temporary restriction on the manner in which we process your personal data.

5. Right to data portability

Where processing is based on consent or a contract and is carried out by automated means, you may have the right to receive personal data provided by you in a structured, commonly used and machine-readable format and to transmit such data to another controller.

6. Right to object

Where processing is based on legitimate interests, you have the right to object to the processing on grounds relating to your particular situation.

Where personal data is processed for direct marketing purposes, you have the right to object at any time, after which your data will no longer be processed for such purposes.

7. Right to withdraw consent

Where processing is based on your consent, you may withdraw that consent at any time.

Withdrawal shall not have retroactive effect and shall not affect the lawfulness of processing based on consent before its withdrawal.

8. Right to lodge a complaint with a supervisory authority

If you believe that your personal data is being processed in breach of applicable data protection legislation, you have the right to lodge a complaint with:

Commission for Personal Data Protection (CPDP)

Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria

Registry telephone: +359 2 91 53 519

Email: kzld@cpdp.bg

Website: www.cpdp.bg

Information concerning complaints and reports is available on the website of the Commission for Personal Data Protection.

XIII. HOW CAN YOU EXERCISE YOUR RIGHTS?

You may submit a request concerning your personal data to:

Email: hello@adsparx.com

Address: ADSPARX EOOD, 19 Lavski Rid St., Vitosha District, Sofia, Bulgaria

Please clearly describe the right you wish to exercise and provide sufficient information to enable us to identify the relevant personal data.

Where we have reasonable doubts concerning the identity of the person submitting the request, we may request additional information necessary to confirm their identity.

We will respond to your request without undue delay and, as a rule, within one month of receiving it.

Where necessary, taking into account the complexity and number of requests, this period may be extended by a further two months in accordance with the GDPR. In such cases, we will inform you of the extension and the reasons for it.

The exercise of your rights is generally free of charge. In the case of manifestly unfounded or excessive requests, the relevant rules of the GDPR may apply.

XIV. SECURITY OF PERSONAL DATA

We implement appropriate technical and organisational measures to protect personal data against:

  1. Unauthorised access;

  2. Unlawful processing;

  3. Accidental loss;

  4. Destruction;

  5. Damage;

  6. Unauthorised disclosure or alteration.

The measures implemented are determined taking into account the nature of the personal data processed, available technical solutions, risks to individuals and the nature of the processing.

No information system can guarantee absolute security; however, ADSPARX takes reasonable measures to maintain an appropriate level of protection.

XV. AUTOMATED DECISION-MAKING

ADSPARX does not use personal data collected directly through the contact forms on www.adsparx.com to make decisions based solely on automated processing which produce legal effects concerning you or similarly significantly affect you.

If such processing is introduced in the future, this Privacy Policy will be updated and the information required by applicable law will be provided.

XVI. LINKS TO OTHER WEBSITES AND SERVICES

www.adsparx.com may contain links to websites, social networks or services operated by third parties.

This Privacy Policy does not govern the manner in which such third parties process personal data after you access their services.

We recommend reviewing the privacy policy of the relevant third-party provider.

XVII. CHANGES TO THIS PRIVACY POLICY

ADSPARX may periodically update this Privacy Policy where necessary due to:

  1. Changes to applicable legislation;

  2. Changes to the manner in which personal data is processed;

  3. Introduction of new functionalities or services;

  4. Changes to service providers or technologies used;

  5. The need to provide clearer or more detailed information to data subjects.

The current version will always be published on www.adsparx.com.

Where a change materially affects the manner in which we process your personal data, we will take appropriate steps to inform you where required by law.

XVIII. CONTACT DETAILS

For any questions regarding this Privacy Policy or the processing of your personal data, you may contact us at:

ADSPARX EOOD

UIC: 207674217

Address: 19 Lavski Rid St., Vitosha District, Sofia, Bulgaria

Email: hello@adsparx.com

Website: www.adsparx.com