Privacy policy

1. An overview of data protection

General

The following gives a simple overview of what happens to your personal information when you visit our website. Personal information is any data with which you could be personally identified. Detailed information about data protection can be found in our privacy policy found below.

Data collection on our website

Who is responsible for the data collection on this website?

The data collected on this website is processed by the website operator. The operator’s contact details can be found in the website’s required legal notice.

How do we collect your data?

• When you provide it to us – for example, data you enter on a contact form.
• Automatically when you visit the website – This data is primarily technical such as the browser and operating system you were using when you accessed the page. It is collected automatically as soon as you open the website.

What do we use your data for?

• to ensure proper functioning of the website
• to analyse how visitors use the site

What rights do you have regarding your data?

You have the right to:

• request information about the data we store about you, its origin, its recipients, and the purpose of its collection at no charge
• request it be corrected, hidden, or deleted
• file a complaint with the competent regulatory authorities
• contact us using the address given in the legal notice if you have further questions regarding the issue of privacy and data protection

Right to object to data collection and direct marketing in special cases (Art. 21 GDPR)

If data processing is carried out based on Art. 6 para. 1 lit. e or f of GDPR, you have the right to object to the processing of your personal data for reasons arising from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which the processing is based can be found in this privacy policy. If you file an objection, we will no longer process the personal data concerned unless we can prove compelling reasons for the processing, based on justifiable grounds, which outweigh your interests, rights and freedoms or the processing serves the assertion, exercise or defence of legal claims (objection according to Art. 21 para. 1 of GDPR).

If your personal data is processed for the purpose of direct marketing, you have the right to object to the processing of your personal data for the purpose of such marketing; this also applies to profiling insofar as it relates to such direct marketing. If you object, your personal data will no longer be used for direct marketing purposes (objection according to Art. 21 para. 2 of GDPR).

Analytics and third-party tools

When visiting our website, statistical analysis may be made of your surfing behaviour. This happens primarily using cookies and other analytics tools. The data used for this analysis is usually anonymised, i.e. we will not be able to identify you from this data. You can object to this analysis or prevent it by not using certain tools. Detailed information can be found in the following privacy policy.

You can object to this analysis. We will inform you below about how to exercise your options in this regard.

2. General information and mandatory information

Data protection

The operators of this website take the protection of your personal data very seriously. We treat your personal data as confidential and in accordance with the statutory data protection regulations and this privacy policy.

If you use this website, various pieces of personal data will be collected. Personal information is any data with which you could be personally identified. This privacy policy explains what information we collect and what we use it for. It also explains how and for what purpose this happens.

We are not in control of all the systems and networks your data traverses.

Notice concerning the party responsible for this website

The party responsible for processing data on this website is:

Key Development OOD 141-143 Slivnitsa Blvd. 1233 Sofia Bulgaria Telephone: +359 2 439 0959 E-Mail: [email protected]

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (names, email addresses, etc.).

Revocation of your consent to the processing of your data

Many data processing operations are only possible with your express consent. You may revoke your consent at any time with future effect. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

Right to file complaints with regulatory authorities

Any data subject shall have the right of appeal to a supervisory authority, in particular in the Member State of his habitual residence, place of work or place of presumed infringement, without prejudice to any other administrative or judicial remedy, if the data subject considers that the processing of personal data concerning him is contrary to this Regulation. The lead regulatory authority for matters related to data protection legislation is the data protection office of the Bulgarian state in which our company is headquartered. This is the:

Comission for Personal Data Protection 2 Prof. Tsvetan Lazarov Blvd. 1592 Sofia Bulgaria Tel.: +359 2 915 35 55 E-Mail: [email protected]

Right to data portability

You have the right to have data which we process based on your consent or in fulfilment of a contract automatically delivered to yourself or to a third party in a standard, machine-readable format. If you require the direct transfer of data to another responsible party, this will only be done to the extent technically feasible.

Encryption

This site uses encryption for security reasons and for the protection of the transmission of confidential content, such as the enquiries you send to us as the site operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar.

We enforce encryption for all connections to our site, therefore the data you transfer to us cannot be read by third parties.

Information, rectification, limitation of the processing, blocking, deletion

As permitted by law, you have the right to be provided at any time with information free of charge about any of your personal data that is stored as well as its origin, the recipient and the purpose for which it has been processed. You also have the right to have this data corrected, its processing limited, blocked or deleted. You can contact us at any time using the address given in our legal notice if you have further questions on the topic of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data.

You can contact us at any time at the address given in our legal notice. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored with us, we usually need time to verify this. For the duration of the examination you have the right to demand the restriction of the processing of your personal data.
• If the processing of your personal data has taken place unlawfully, you can demand the restriction of data processing instead of deletion.
• If we no longer need your personal data, but you need it for the exercise, defence or assertion of legal claims, you have the right to demand the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection pursuant to Art. 21 Para. 1 GDPR, a balance must be struck between your and our interests. If it is not yet clear whose interests predominate, you have the right to demand that the processing of your personal data be restricted.

If you have restricted the processing of your personal data, this data may only be processed – apart from its storage – with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a member state.

Opposition to promotional Emails

We hereby expressly prohibit the use of contact data published in the context of website legal notice requirements for the purpose of sending promotional and informational materials not expressly requested. The website operator reserves the right to take specific legal action if unsolicited advertising material, such as spam email, is received.

3. Data collection on our website

Cookies

Some of our web pages use cookies. Cookies do not harm your computer and do not contain any viruses. Cookies help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called “session cookies.” They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser on your next visit of the site.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser.

Disabling cookies may limit the functionality of this website.

Cookies which are necessary to allow electronic communications or to provide certain functions you wish to use are stored pursuant to Art. 6 paragraph 1, letter f of GDPR.

The website operator has a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors. If other cookies (such as those used to analyse your surfing behaviour) are also stored, they will be treated separately in this privacy policy.

Server log files

The website provider automatically collects and stores information that your browser automatically transmits to us in “server log files”. These are:

• Browser type and browser version
• Operating system
• Referrer URL
• Time of the server request
• IP address

This data will not be merged with other data sources.

This data is collected on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a justified interest in the technically error-free presentation and optimisation of his website – for this purpose the server log files must be recorded.

Contact form

Should you send us enquiries via the contact form or per email, we will collect the data entered on the form or sent per email, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.

We will, therefore, process any data you enter onto the contact form or send per email only with your consent per Art. 6 (1)(a) GDPR. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.

We will retain the data you provide on the contact form or per Email until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.

Enquiry by email, telephone or fax

If you contact us by email, telephone or fax, your request including all personal data (name, request) will be stored and processed by us for the purpose of processing your request.

This data is processed on the basis of Art. 6 Para. 1 lit. b GDPR if your request is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on your consent (Art. 6 para. 1 lit. a GDPR) and / or on our legitimate interests (Art. 6 para. 1 lit. f GDPR), as we have a legitimate interest in the effective processing of enquiries addressed to us. 
The data you send to us via contact requests remains with us until you ask us to delete it, revoke your consent to the storage thereof or the purpose for the data storage no longer applies (e.g. after completion of your request). Mandatory statutory provisions, especially statutory retention periods, remain unaffected.

Processing of data (customer and contract data)

We collect, process, and use personal data only insofar as it is necessary to establish, or modify legal relationships with us (master data). This is done based on Art. 6 (1) (b) GDPR, which allows the processing of data to fulfil a contract or for measures preliminary to a contract. We collect, process and use your personal data when accessing our website (usage data) only to the extent required to enable you to access our service or to bill you for the same.

Collected customer data shall be deleted after completion of the order or termination of the business relationship, unless we require them to fulfil our legal obligations or to assert, exercise or defend our legal claims.

Data transmitted to third parties

We transmit personally identifiable data to third parties only to the extent required to fulfil the terms of your contract or for measures preliminary to a contract. Examples are banks entrusted to process payments between the parties or trusted partners/subcontractors of the website operator. Your data will not be transmitted for any other purpose unless you have given your express permission to do so. Your data will not be disclosed to third parties for advertising purposes without your consent or legal basis.

The basis for data processing is Art. 6 (1) (b) GDPR, which allows the processing of data to fulfil a contract or for measures preliminary to a contract.

4. Analytics and advertising

Google Analytics

This website uses Google Analytics, a web analytics service. It is operated by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

Google Analytics cookies are stored based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analysing user behaviour to optimize both its website and its advertising.

For more information about how Google Analytics handles user data, see Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.https.

IP anonymization

We have activated the IP anonymization feature on this website. Your IP address will be shortened by Google within the European Union or other parties to the Agreement on the European Economic Area prior to transmission to the United States. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there.

Google will use this information on behalf of the operator of this website to evaluate your use of the website, to compile reports on website activity, and to provide other services regarding website activity and Internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with any other data held by Google.

Browser plugin

You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Outsourced processing

We have entered into an agreement with Google for the outsourcing of our processing and fully implement the strict requirements of the European data protection authorities when using Google Analytics.

Demographic data collection by Google Analytics

This website uses Google Analytics’ demographic features. This allows reports to be generated containing statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google and third-party visitor data. This collected data cannot be attributed to any specific individual person. You can disable this feature at any time by adjusting the ads settings in your Google account or you can forbid the collection of your data by Google Analytics as described in the section “Refusal of data collection”.

Storage period

User- and event-level information stored by Google that is associated with cookies, user IDs (e.g., UserID), or advertising IDs (e.g., DoubleClick cookies, Android Advertising ID) is collected, after 26 months it is anonymized or deleted. Details can be found under the following link: https://support.google.com/analytics/answer/7667196?hl=en.

Google AdWords and Google Conversion Tracking

This website uses Google AdWords. AdWords is an online advertising program from Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

As part of Google AdWords, we use so-called conversion tracking. When you click on an ad served by Google, a conversion tracking cookie is set. Cookies are small text files that your internet browser stores on your computer. These cookies expire after 30 days and are not used for personal identification of the user. Should the user visit certain pages of the website and the cookie has not yet expired, Google and the website can tell that the user clicked on the ad and proceeded to that page.

Each Google AdWords advertiser has a different cookie. Thus, cookies cannot be tracked using the website of an AdWords advertiser. The information obtained using the conversion cookie is used to create conversion statistics for the AdWords advertisers who have opted for conversion tracking. Customers are told the total number of users who clicked on their ad and were redirected to a conversion tracking tag page. However, advertisers do not receive any information that can be used to personally identify users. If you do not wish to participate in tracking, you can opt-out of this by easily disabling the Google Conversion Tracking cookie by changing your browser settings. In doing so, you will not be included in the conversion tracking statistics.

Conversion cookies are stored based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analysing user behaviour to optimize both its website and its advertising.

For more information about Google AdWords and Google Conversion Tracking, see the Google Privacy Policy: https://www.google.de/policies/privacy/.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, accept cookies for certain cases or generally exclude them and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

Microsoft Advertising Program

This website also uses the online advertising program “Bing Ads” and the associated conversion tracking, a service of Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA, “Microsoft”). When you click on an ad from Microsoft Bing Ads, a cookie is set on your device, which is used for conversion tracking. If you visit a website of our online store and the conversion tracking cookie is still valid, then Microsoft Bing Ads and we can determine that you clicked on the ad placed with Bing Ads and were redirected to the page. We use the information collected with the conversion tracking cookie to compile statistics on the use of Microsoft Bing Ads. Among other things, we learn the total number of users who clicked on an ad placed by us at Microsoft Bing Ads and thus reached our website.

Conversion cookies are stored based on Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in analysing user behaviour to optimize both its website and its advertising.

You can object to our use of this analysis service by preventing the storage of cookies on your device by setting your browser accordingly (e.g. by generally blocking the acceptance of cookies). Your usage will then not be recorded in our conversion tracking statistics. You can also prevent the use of the analysis service by clicking the following link: http://choice.microsoft.com/opt-out to declare your objection. Further information can be found at: https://privacy.microsoft.com/en-ca/privacystatement.

5. Plugins and tools

Google Web Fonts

For uniform representation of fonts, this page uses web fonts provided by Google. When you open a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.

For this purpose, your browser has to establish a direct connection to Google servers. Google thus becomes aware that our web page was accessed via your IP address. The use of Google Web fonts is done in the interest of a uniform and attractive presentation of our website. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.

If your browser does not support web fonts, a standard font is used by your computer.

Further information about handling user data, can be found at https: https://developers.google.com/fonts/faq and in Google’s privacy policy at https://www.google.com/policies/privacy/.

Google Maps

This site uses the Google Maps map service via an API. It is operated by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To use Google Maps, it is necessary to save your IP address. This information is generally transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer.

The use of Google Maps is in the interest of making our website appealing and to an error-free entry of the billing and delivery address. This constitutes a justified interest pursuant to Art. 6 (1) (f) GDPR.

Further information about handling user data, can be found in the data protection declaration of Google at https://www.google.de/intl/de/policies/privacy/.

Application for employment

When you apply to work with us, we process the personal data you provide to us (such as personal details, contact details, certificates and credentials). We use this data exclusively for the application process, in particular to make a decision about your application. This data processing is based on Art. 6 para. 1 lit. b GDPR (general contract initiation).

Retention period of the data

If we are unable to make you a job offer, you reject a job offer, withdraw your application, revoke your consent to data processing or request us to delete the data, the data transmitted by you including any remaining physical application documents will be stored for a maximum of one year after completion of the application process (retention period) in order to be able to trace the details of the application process in the event of discrepancies (Art. 6 Para. 1 lit. f of GDPR). You may object to this storage if you have legitimate interests that outweigh our interests.

After expiry of the retention period, the data will be deleted unless there is a legal obligation to retain it or any other legal reason for further storage. If it is evident that the retention of your data will be necessary after the expiry of the retention period (e.g. due to an impending or pending legal dispute), deletion will only take place when the data has become irrelevant. Other legal storage obligations remain unaffected.