PRIVACY POLICY AND COOKIE POLICY
The protection of the personal data of individuals on the COMPLIANCE LOGISTICS ACCURACY LTD website is fully compliant with Regulation (EU) 2016/67 C (the “Regulation”). The use of the website of COMPLIANCE LOGISTICS ACCURACY LTD – www.clabulgaria.com is possible without submitting personal data. If a user wants to use special services through our site (inquiry, links to social networks, watching videos), the processing of personal data may be necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we ask for the user’s consent in advance and announce this policy for their protection.
The processing of personal data, such as name, address, email address or telephone number, is always in accordance with the General Data Protection Regulation (GDPR) and complies with country-specific data protection regulations. With this privacy statement, we want to inform you about the scope and purpose of the data we collect, use and process. Users are informed, through this declaration, about the protection of their personal data and about the rights they have under the Regulation.
COMPLIANCE LOGISTICS ACCURACY LTD has implemented numerous technical and organizational measures to ensure the full protection of the personal data of individuals received and processed through our site.
1. Definitions
The data protection declaration of COMPLIANCE LOGISTICS ACCURACY LTD is based on the terminology used in the General Data Protection Regulation (GDPR). The data protection declaration must be comprehensible to the general public as well as to our customers and business partners. To ensure this, we would first like to explain the terminology used.
In this data protection declaration we use the following terms:
1.1. Personal data
Personal data – any information that can be used to identify a natural person (“user”). A natural person who can be identified directly or indirectly, in particular by specifying data such as name, location data, online identifier and others.
1.2. Data Subject/ User
A data subject (“user”) is any identified or identifiable natural person whose personal data is processed by us under the terms of the Regulation.
1.3. Processing
Processing, storing, adapting or changing, retrieving, consulting, using, disclosing by transmission, distribution or otherwise making available or combining, limiting, erasing or destroying personal data.
1.4. Restriction of processing
Restriction of processing is the marking of stored personal data in order to limit their processing in the future.
1.5. Profiling
Profiling – any form of automated processing of personal data.
1.6. Controlling authority / administrator
The controlling authority or the administrator responsible for the processing is a natural or legal person, public body, agency or other body that alone or jointly with others determines the purposes and means of processing personal data; where the purposes and means of such processing are determined by the EU legal framework.
1.7. Recipient
The recipient is a natural or legal person, public body, agency or other body to which the personal data is disclosed, regardless of whether it is a third party or not. Public authorities that may receive personal data in the context of a specific investigation in accordance with EU law are not considered a third party; the processing of this data is in accordance with the applicable data protection rules in accordance with the purposes of the processing.
1.8. Third person
The third party is a natural or legal person, public body, agency or body other than the data subject, the controller, the processor and the persons who, under the direct right of the controller or processor, have the right to process personal data.
1.9. Consent
The consent of the user is any free, specific, informed and unequivocally indicated, by statement or by clear positive actions, and gives consent to the processing of his personal data.
2. Name and address: COMPLIANCE LOGISTICS ACCURACY LTD
Bulgaria, 1000, Sofia, St. “San Stefano” №5
Email: office@clabulgaria.com
Website: www.clabulgaria.com
Supervisory Authority:
Commission for the Protection of Personal Data with address: Sofia, str. “Ivan Evstatiev Geshov” 15, phone: 02 940 20 46 fax: 02 940 36 40; e-mail: kzld@government.bg, kzld@cpdp.bg: Website: www.cpdp.bg.
3. “Cookies”
The https://www.clabulgaria.com website uses cookies. “Cookies” are text files that are stored on the user’s device.
Through the use of cookies, COMPLIANCE LOGISTICS ACCURACY LTD can provide users of this site with more user-friendly services that would not be possible without the setting of cookies.
With the help of “cookies”, the information on our site can be optimized according to the behavior and wishes of the user. “Cookies” allow us to recognize our users. The purpose of this recognition is to make it easier for users to use our site.
The user can at any time prohibit the use of “cookies” through the corresponding setting of the Internet browser used. Already saved cookies can be deleted at any time through an Internet browser or other software applications used to visit our site. This is possible in all browsers and applications. If the data subject disables the use and storage of cookies in the browser used, not all functions of our website may be fully usable.
4. Collection of General Data and Information
The COMPLIANCE LOGISTICS ACCURACY LTD website collects general data and information when you visit it. This general data and information is stored in the log files of the server owned by “Superhosting.BG” OOD, which strictly comply with the Regulation on the protection of personal data. You can find information about this at https://www.superhosting.bg/web-hosting-page-terms-and-agreements.php#gdpr. Collected may be (1) the types and versions of the browser used, (2) the operating system used by the access system, (3) the site from which our website is accessed (so-called Referrers), (4) ( 5) the date and time of access to the website, (6) IP address, (7) the Internet service provider, (8) any other information that can be used in the event of a cyber attack on our site.
When using this general data and information, COMPLIANCE LOGISTICS ACCURACY LTD does not draw any conclusions about the data subject. Rather, this information is necessary to: (1) create the correct content on our site, (2) optimize the content on our site, (3) ensure quality access to information, (4) provide law enforcement authorities with the necessary information for prosecution in the event of a cyber attack.
Therefore, COMPLIANCE LOGISTICS ACCURACY LTD analyzes anonymously collected data and information statistically, in order to increase data protection and security, and to guarantee an optimal level of protection of the personal data it processes. Anonymous data in server log files is stored separately from any personal data provided by the user.
5. Possibility of contact through the site
The COMPLIANCE LOGISTICS ACCURACY LTD site contains information that allows for quick electronic contact with us, as well as direct communication, which includes submitting direct information by e-mail, using a form on the site. If a user contacts COMPLIANCE LOGISTICS ACCURACY LTD directly by e-mail or via the contact form, the personal data transmitted by the data subject is automatically stored. Such personal data, transmitted on a voluntary basis by the user, are processed and stored for the purpose of contacting him. This personal data is not provided to third parties.
6. Deletion and blocking of personal data
COMPLIANCE LOGISTICS ACCURACY LTD processes and stores the user’s personal data only for the period necessary to achieve the purpose or for a period provided for in the Regulation.
If the storage purpose is not applicable or if the storage period determined by the European legislator or other competent legislator expires, personal data is routinely blocked or deleted in accordance with legal requirements.
7. User Rights
7.1. Right of Confirmation
Every user has the right to receive from a confirmation whether the personal data relating to him are being processed. If a data subject wishes to exercise this right of confirmation, he or she may contact us at any time.
7.2. Right of access
Every user has the right to receive information about his personal data stored at any time, as well as a copy of this information. In addition, according to the Regulation, the user has the right to request access and information about:
– the purposes of processing;
– the categories of the relevant personal data;
– the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organizations;
– when possible, the intended period for which the personal data will be stored;
– the right to request correction or deletion of personal data or restriction of processing of personal data;
– the right to file a complaint with a supervisory authority;
– the availability of automated decision-making, including profiling, specified in Art. 22, paragraphs 1 and 4 of the Regulation, as well as the intended consequences of such processing.
The user has the right to receive information about whether his personal data is transferred to a third country or an international organization. Where this is the case, the user has the right to be informed of the safeguards taken in relation to the transfer.
If a user wishes to exercise this right of access, he or she may contact us at any time.
7.3. Right to rectification
Every user has the right to request, without unreasonable delay, the correction of inaccuracies in his personal data. Taking into account the purposes of the processing, the user has the right to have incomplete personal data completed, by providing an additional statement to this effect.
If the user wishes to exercise this right of rectification, he or she may contact us at any time.
7.4. Right to erasure
Every user has the right to request the deletion of his personal data without delay and we are obliged to delete it without undue delay when one of the following grounds is present:
– the personal data are no longer necessary in relation to the purposes for which they were collected or processed;
– the user withdraws the consent on which the processing of his personal data is based, according to Art. 6, paragraph 1a or Art. 9, paragraph 2a of the Regulation, and when there is no other legal reason for continuing their processing;
– the user objects to the processing, according to Art. 21, paragraph 1 of the Regulation and there are no legitimate grounds for their processing or the user objects to their processing, according to Art. 21, paragraph 2 of the Regulation;
– personal data were illegally processed;
– personal data are collected in connection with the provision of services specified in art. 8, paragraph 1 of the Regulation;
If one of the above reasons applies and the user wishes to request the deletion of personal data stored by COMPLIANCE LOGISTICS ACCURACY LTD, he or she may contact us at any time. An employee of COMPLIANCE LOGISTICS ACCURACY LTD will promptly ensure that the erasure request is complied with immediately.
When the administrator has made the personal data public, he is obliged, according to Art. 17, paragraph 1 to delete the personal data provided to third parties, taking into account the available technology and implementation costs, takes reasonable steps, including technical measures, to inform the other controllers processing the personal data that the user has requested to be deleted. COMPLIANCE LOGISTICS ACCURACY LTD employees will arrange the necessary actions on a case-by-case basis.
7.5. Right to restriction of processing of personal data
Every user has the right to request the restriction of the processing of his personal data when one of the following applies:
– the accuracy of the personal data is contested by the user, giving the administrator the opportunity to check their accuracy;
– the processing is illegal and the user’s data is opposed to the rules for their deletion and instead requests the restriction of their use;
– it is no longer necessary to process the personal data, but it is required to establish, exercise or defend legal claims;
– the user objects to the processing of his personal data, according to Art. 21, paragraph 1 of the Regulation.
If one of the above conditions is present and the user requests the restriction of the processing of his or her personal data, he or she may contact us at any time. The employee of COMPLIANCE LOGISTICS ACCURACY LTD will limit their processing.
7.6. Right to data portability
Every user has the right to receive their personal data provided to us in a structured electronic format. The user has the right to provide this data to another administrator, provided that the processing is based on Art. 6, paragraph 1a, Art. 9, paragraph 2a of the Regulation or of a contract, according to Art. 6, paragraph 1b of the Regulation.
In addition, when exercising the right to data portability pursuant to Art. 20, paragraph 1 of the Regulation, the user has the right to provide personal data directly from one administrator to another, when this is technically feasible in accordance with the Regulation.
To establish the right to data portability, the User can contact us at any time.
7.7. Right to object
Every user has the right to object at any time to the processing of personal data relating to him on the basis of Article 6, Paragraph 1 of the Regulation.
COMPLIANCE LOGISTICS ACCURACY LTD will not process personal data in the event of an objection, unless we have legitimate reasons for processing that outweigh the interests, rights and freedoms of the user or for the establishment, exercise or defense of legal actions.
If COMPLIANCE LOGISTICS ACCURACY LTD processes personal data for direct marketing purposes, the user has the right to object at any time to their processing for this purpose. This refers to profiling related to direct marketing. If the user does not wish to have their data processed for direct marketing purposes, we are obliged to comply with this request.
7.8. Automated decision making, profiling
Every user has the right to refuse automated processing, including profiling, which produces legal consequences in relation to him or a similar material impact on him, insofar as the decision is not necessary for the conclusion or performance of a contract between us and the user.
7.9. Right of withdrawal
Every user has the right to withdraw his consent to the processing of his personal data at any time.
If the user wishes to withdraw his or her consent, he or she may contact us at any time.
8. Data protection provisions regarding the use of Google Analytics on our site
We have integrated a Google Analytics script into our site. The purpose of this tool is to collect and analyze data on the behavior of website visitors: which pages were visited, how often and for how long a subpage was viewed. Web analytics are mainly used to optimize the website and possibly perform a cost-benefit analysis of Internet advertising.
Google Analytics is owned by Google Inc., 1600 Pkwy, Mountain View, CA 94043-1351, USA.
For web analytics via Google Analytics, we use “_gat. _anonymizeIp”. With the help of this application, the IP address of the user’s ISP is shortened by Google and anonymized.
The purpose of Google Analytics is to analyze the traffic on our website. Google uses the collected data and information to evaluate the use of our site and provide online reports.
Google Analytics places a “cookie” on the device of the user who has visited our website. The definition of cookies is explained above. With the help of the “cookie”, Google can analyze the use of our site. On each visit to any of the pages on our site where the Google Analytics tracking code is integrated, the internet browser of the user’s device will send data to Google Analytics. During this process, Google receives personal information about the user, such as IP address and location.
The “cookie” is used to store information such as the time of access, the location from which the access was made, and the frequency of visits to our site. With each visit to our website, such personal data, including the IP address, will be provided to Google. This personal data is stored by Google in the USA and the company may transfer this personal data to third parties.
The user can prohibit the use of “cookies” from our site at any time, through the appropriate setting of the browser used, and in this way refuse to permanently store information from “cookies”. Such a setting on each browser will prevent Google Analytics from saving a “cookie” on the user’s device. In addition, cookies already in use by Google Analytics can be deleted at any time from the settings of the user’s web browser and/or application that visited our site.
The user has the right to object to the collection of data generated by Google Analytics related to the use of this site, as well as to the processing of this data by Google. For this purpose, the user must download a browser add-on from https://tools.google.com/dlpage/gaoptout and install it. Through JavaScript, this add-on will prevent Google Analytics from providing the data and information about the visit and behavior to Google. Installing the browser add-on is considered an objection to the processing of personal data. If the user’s device is reinstalled, this opt-out add-on will need to be reinstalled. If the browser add-on is uninstalled by the user, a new installation and activation of the browser add-on may be required.
Additional information and applicable Google privacy regulations can be found at https://www.google.com/intl/bg/policies/privacy. The information that Google Analytics collects, its processing and storage is described in detail at https://www.google.com/analytics.
9. Data protection provisions regarding the use of Facebook
On our site we have references to the social network Facebook.
A social network is an online meeting place on the Internet, an online community where users are allowed to communicate with each other and interact in a virtual space. A social network can serve as a platform to share opinions and experiences, or enable users to provide personal or business information. Facebook allows users to create profiles, upload photos and connect with each other.
Facebook is owned by Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA.
If the user lives outside the United States or Canada, the data controller is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, in Ireland.
Each page of our site may have a link to our Facebook profile and/or installed Facebook plugins. It is possible that the device from which the user visits our site invites him to install an additional setting and/or the Facebook mobile application. An overview of all possible Facebook plugins can be found at https://developers.facebook.com/docs/plugins. During this procedure, Facebook is informed about which subpage of our site the user visited.
If the user is also logged into Facebook at the same time, Facebook detects this and collects information that is associated with the user’s user profile on the social network. If the user clicks on one of the Facebook links/buttons integrated on our site, the social network saves this information that it associates with the personal user profile there.
Facebook always receives information about the visit to our site when the user is logged into the social network system, regardless of whether the user clicks on one of the links from Facebook on our site or not. If he does not wish such a transmission of information to Facebook, it is advisable for the user to log out of his account on the social network before visiting our site.
Facebook’s privacy policy is published at https://facebook.com/about/privacy, where information is provided on the collection, processing and use of personal data by the social network. It also explains what possible settings Facebook offers to protect the privacy of the user’s personal data. Various configuration options are described that prohibit the transmission of data to Facebook.
10. Data protection provisions regarding the application and use of YouTube
On our website, we have links and/or videos downloadable directly into the content of one or more sub-pages on our website, directly from YouTube. YouTube is an Internet video portal that allows free posting and viewing of videos. YouTube allows posting of any type of video, as well as access to entire movies, TV shows, music videos, and user-created videos through the Internet portal.
YouTube is owned by YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, USA and is a subsidiary of Google Inc.
It is possible that when you visit one or more pages of our site, preset videos from the portal will be automatically downloaded and previewed. Additional information about YouTube can be found at https://www.youtube.com/yt/about/en/. When downloading video content, YouTube and Google receive information about which specific subpage of our website was visited by the user.
If the user is logged in to YouTube, YouTube recognizes the user account and receives information about the duration and which specific pages were visited by the user. This information is collected by YouTube and Google associates it with the respective YouTube user profile.
YouTube and Google will receive information that the user has visited our site only if he is logged into YouTube; this happens regardless of whether or not the user clicks on a link to or video on YouTube. If such a transmission of information to YouTube and Google is not desired by the user, this can be prevented after the user logs out of his account on the video portal before visiting our site.
YouTube’s data protection regulations can be found at https://www.google.com/intl/bg/policies/privacy/.
11. Data protection provisions regarding the application and use of Instagram
We have integrated components and links Instagram service. Instagram is a service that can be qualified as an audiovisual platform that allows users to share photos and videos, as well as distribute them to other social networks.
Instagram is owned by Instagram LLC, 1 Hacker Way 14, Menlo Park, California, USA.
When you visit any of the pages of our site, an Internet site, there is an integrated component Instagram, which can send information to the social network about the user behavior of any of the pages of our site and/or receive an invitation to install a component or mobile social network application.
If the user is logged into Instagram at the same time, Instagram records the duration and visits to each page of our site and associates this behavior with the user account on the social network. This information is collected regardless of whether the user has clicked on any of the social network buttons on our site or not.
Additional information and applicable Instagram data protection regulations can be found at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy.
12. Data protection provisions regarding the application and use of LinkedIn
We have settings and links from and to LinkedIn on our site. LinkedIn is a web-based social network that allows users with existing business contacts to connect and create new business contacts. Over 400 million registrants in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
LinkedIn is owned by LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, USA. For questions related to the protection of personal data for citizens of the European Union is responsible with Wilton Plaza, Wilton Place, Dublin 2, in Ireland.
When following a hyperlink on a page that has a link to LinkedIn, the browser on the user’s device may automatically download relevant LinkedIn settings and add-ons and/or an invitation to install the social network’s mobile application. Additional information about all possible LinkedIn plugins can be found at https://developer.linkedin.com/plugins. During this/these processes, LinkedIn obtains information exactly from which subpage a respective add-on was downloaded, if such a setting exists on the visited page of our site.
If the user is logged into his LinkedIn user account, LinkedIn tracks user behavior such as the duration of the visit and exactly which pages of our site are visited. This information is collected through the LinkedIn plugins and associated with the user’s respective LinkedIn profile. If the user clicks on one of the LinkedIn buttons integrated on our site, LinkedIn saves this information to the user’s profile.
LinkedIn receives information about the visits and duration of our site, regardless of whether the user will follow the links to the social network on our site or not, if he is logged into the social network system. If the user does not want this type of information to be transmitted to the social network, he must log out of his account there before visiting our site.
LinkedIn enables notification management. https://www.linkedin.com/psettings/guest-controls the user has the option to opt-out of email messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua and Lotame. The setting of such cookies can be refused with the guidelines posted at https://www.linkedin.com/legal/cookie-policy.
13. Legal basis for processing personal data
Art. 6, paragraph 1b of the Regulation serves as a legal basis for the processing of personal data, obtaining consent from the user for a specific purpose of processing his personal data. If the processing of personal data is necessary for the performance of a contract to which the interested party is a party, as is the case, for example, when the processing operations are necessary for the delivery of goods or for the provision of services, the processing is based on Art. 6, paragraph 1a of the Regulation. The same applies to processing that is necessary to carry out pre-contractual measures, for example in the case of inquiries about our products or services. The legal basis according to which the processing of personal data is required, for example for the implementation of tax operations, the processing of personal data is based on Art. 6, paragraph 1b of the Regulation. In rare cases, the processing of personal data may be necessary to protect the vital interests of the user or another natural person. Processing of personal data may be based on Art. 6, paragraph 1 b of the Regulation. This legal basis is used for processing, in cases where the basis for processing does not fall under any of the above legal grounds, if the processing is necessary for the purposes of our legitimate interests or those of a third party, unless such are disregarded from the fundamental rights and freedoms of the user.
14. The legitimate interests pursued by the controller or by a third party
When the processing of personal data is based on Art. 6(1) of the Regulation is the legal approach according to which we process personal data in order to be able to provide quality services for the benefit of the well-being of current and future customers.
15. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data are the legal frameworks provided for in the Regulation. After the expiration of the period defined by the Regulation, the relevant data are deleted according to established rules, if they are no longer necessary for the performance of a contract or for the creation of a contract between the two parties.
The provision of personal data in the event of a contractual relationship between us and the user, their processing and storage, as well as the rights arising from the Regulation are defined in this Privacy Policy.
We clarify that the provision of personal data may be partially required by law (for example, tax legislation) or may be as a result of contractual relations that have arisen. If it is necessary to conclude a contract, the user must provide his personal data for this purpose, which will be processed by us in the order established by the Regulation. Refusal to provide personal data may result in the impossibility of concluding a contract, delivery of services or goods on our part.