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The General regulation on the protection and security of personal data (General Data Protection Regulation, GDPR) entered into force on 25 May 2018 for all EU Member States. It is directly applicable in Bulgaria as well, just as any other national act and provides for the rights and obligations of data controllers, processors and subjects; certain details are further provided for in the Bulgarian Personal Data Protection Act. All users of www.tesy.com are data subjects and have various rights in this respect. This policy is intended to provide more information about the principles concerning the protection of the personal data of the users of www.tesy.com, about our responsibilities as the data controller and about the measures that we have undertaken, so as to avoid any use of your data without knowing by whom and for what purposes or without having the opportunity to object or to withdraw your consent for their processing. The policy will not remain the same for the whole period of existence of our website; since the digitalization is advancing and the regulation of the relations concerning the personal data processing is developing, we will try to constantly enhance our practices and adjust them to such development, which in turn will be reflected in the policy. TESY strictly complies with the applicable provisions in the personal data protection field in any operation involving personal data processing that is carried out through the website.
This Policy is approved by the Managing Director of “TESY” OOD on 25 May 2018 and provides for the processing of personal data through www.tesy.com.
In cases of uncertainties concerning the implementation of this Policy and the exercise of your rights, you can contact the data protection officer of TESY at firstname.lastname@example.org.
“Personal Data” means any information relating to you, the visitor/user of our website or software application, which is able, either individually or in combination with other information, to help us identify you or associate your consumer behavior with a specific device that you are using to access our website;
“Data Subject” means you, the user of www.tesy.com;
“Data Processing” means any operation that we perform or can perform on your personal data, including, but not limited to collection, analysis, destruction, etc.;
“Data Controller” means “TESY” OOD (TESY), registered in accordance with the legislation of the Republic of Bulgaria, having its seat and registered address in the Republic of Bulgaria, town of Shumen, 48 “Madara” Blvd., registered with the Trade Register kept by the Registry Agency of the Republic of Bulgaria under UIC: 040029337, which is the owner of www.tesy.com domain. We determine the purpose of the processing of your data on one of the grounds provided by the law: basically, we also determine the means to be used for the processing, for example, the technical infrastructure and applications for the carrying out of the processing.
“Data Processor” means a third person who processes your personal data on our behalf, provided that TESY shall strictly define the purpose and the means of the processing, including the verification of the person’s compliance with GDPR requirements. For example, such a processor can be an agency which is entrusted with the marketing campaign of TESY in a social network and prepares reports on its success rates;
“Cookies” means small text files stored in the directories of the user’s browser. The cookies are used to help users use the websites effectively and ensure the accessibility of certain functionalities. The cookies play an important role in facilitating and enhancing the usability of the websites; therefore, if erased or blocked, certain websites or some of their functionalities may be inaccessible for the users;
“Information Society Services” means any service normally provided for remuneration, at a distance, by electronic means. The recipient of such service must have expressly requested it. The e-commerce is such a service as well.
Data Security and Protection
TESY undertakes the necessary technical and organizational measures for the protection of your data on www.tesy.com against any unlawful acts, including loss and unauthorized access. With a view to ensure high security, the measures are undertaken in two directions – by design of the individual segments of the website and the offered services and by default, when you, as the user, fill in the contact form/subscribe for the information bulletin or in another similar way. The measures consist of limiting the access to your personal data, strict compliance with the internal policy rules, suitable training of the persons who are in charge of the processing of your personal data and adherence to the good practices, guidelines and instructions of the competent supervisory authorities concerning the personal data protection. All measures are subject to regular review and are periodically updated. In case of a security breach affecting your personal data, we will notify you without undue delay, within a reasonable time after learning about the incident, if the personal data security breach is able to potentially lead to a high risk for your rights and freedoms.
Personal Data Processing Activities
Your personal data will be processed by TESY in compliance with the applicable data protection legislation. When you send us an e-mail or fill in a form/feedback form on our website, you undertake that the data you submit are precise, correct and up-to-date. Through www.tesy.com, TESY collects personal data in the following ways:
· feedback form;
· subscription for the information bulletin;
· business partner form (Partner log in);
· cookies and other similar ways.
When you visit the website, cookies are attached to your terminal device, which enable “remembering” your actions and preferences for a given period of time. For further information, please consult our Cookies Use and Management Policy.
Personal Data Categories
The following categories of personal data are collected through the website:
|Your personal data||Our goals|
|Name||We need it, so as we can identify you and know how to address you
Contact with you
Providing of the requested service/replying to your questions
Offering of new products and services
|Telephone/Fax/E-mail||Contact with you
Providing of the requested service/replying to your questions
Offering of new products and services
|Data related to the users’
behavior when using the website
|Improving of the services and understanding of your interests and behavior as users, so as we can respond to your preferences
Offering of new products and services
Period of Storage and Destruction
The personal data are kept for the periods necessary for the achieving of the objectives that they have been collected for. TESY undertakes the necessary technical and organizational measures for the destruction of the data that are no longer needed, except for the cases where there are legal grounds to continue processing them for a longer period of time; if you request restriction of the processing in accordance with your rights detailed herein below; or for purposes compatible with the initial objective of the processing, about which you will be informed in due time.
The personal data are processed on the grounds specified in art. 6 of the General Data Protection Regulation, as follows:
When you fill in the contact form, we are processing your personal data on the basis of your consent and for the purposes of responding to your specific request (for example information of the appliance models, functionalities, questions related to the purchasing of our appliances and warranty services, positive comments and criticism, etc.).
When you fill in the business partner form (Partner log in), we are processing your data for the purposes of providing the requested service – you will have easy access to and opportunity to download files containing the service documentation (explosion drawings, spare part lists, prices and pictures, electrical connections, instructions for use).
When you enter your e-mail to subscribe for the information bulletin, we will consider this as a confirmation of your freely given, specific, informed and unambiguous consent to process your data for the purposes of receiving the information bulletin that presents our products and services.
You are entitled to withdraw your consent at any time, and TESY will not send you information materials anymore, unless you expressly state again that you give your consent to that effect by entering your e-mail again into the form. You can withdraw your consent by following the link in the e-mail message that you receive with the information materials or at email@example.com.
If you are not sure about the grounds on which we are processing your personal data, you can always ask us about that, as well as about how exactly you have given your consent.
Processing on the grounds of the legitimate interest of TESY or of a third person and objecting to such processing
TESY is processing your data on the ground of your consent and for the purposes of providing the service that you have requested through the functionalities of www.tesy.com. When your consent was not requested and given for the purposes of a specific processing, or the processing is not immediately necessary for the provision of the service that you have requested, most likely our grounds are based on our legitimate interest, or on the legitimate interest of a third person, that we have assessed as not damaging or insignificantly affecting your personal data privacy rights. We will always document such an assessment and it will be based on specific criteria and arguments. You are entitled to get acquainted with its basic points upon your request, as well as to raise objections stating that with a view to the particularities of your specific situation, the relevant processing is affecting your right to personal data privacy and/or protection more substantially that specified in the reasoning. In such cases, we will consider your objection and come out with a reasoned opinion on its acceptance or rejecting within 10 working days. By the sending of an objection to that processing, you can also exercise your right to object specified herein above. The objection may be submitted to us at firstname.lastname@example.org.
Disclosing of Data to Third Parties
TESY will not disclose any personal data to third parties, except in the cases when it is necessary to protect the vital interests of you/other natural persons, or when this is done for the purposes of complying with a legal obligation applicable to TESY, in the capacity of data controller.
TESY does not submit the personal data collected through www.tesy.com to third countries or international organizations other that the European Union.
As a data subject and user of www.tesy.com, you have the following rights:
a) Right to information
Besides the information specified herein above, please be informed that you are not the object of automated decision-making, however, we are carrying out profiling for the purposes of solvency assessment. In accordance with the applicable legislation in the field of personal data, you are entitled to the right specified herein below, provided that we undertake to respond free of charge to each request of yours within a 1-month period as from the receipt of your request. In case of factual or technical difficulties to respond in due time to such requests, the period may be extended by further 2 months, and you will be notified within a month as from the receipt of your request.
b) Right to access
You can request a confirmation as to whether and what personal data about you are processed, as well as an access to these data.
Each piece of information, communication or actions in relation to your rights shall be provided and performed free of charge. When the requests of a user are manifestly groundless and excessive, in particular due to their repeatability, TESY may impose a reasonable fee, taking into account the administrative costs for the provision of the information or communication, or the undertaking of the requested actions.
c) Right to rectification
If we are processing incomplete or incorrect personal data about you, you can request their rectification or their supplementing at any time.
d) Right to erasure
You can request the erasure of your personal data in the following cases:
· the personal data are no longer necessary for the purposes, for which they have been collected or otherwise processed;
· you have withdrawn your consent on which the processing is based and there are no other legal grounds for the processing;
· you consider that the personal data have been processed unlawfully.
Please be informed that there might be other reasons preventing the immediate erasure of your data, for example statutory obligations for storage, pending proceedings, establishment, exercise or defense in case of legal actions, etc.
e) Right to restriction of processing
You are entitled to request a restriction of the processing, provided that:
· you object to the precision of the personal data, for a period that enables us to verify the precision of the personal data;
· the processing is unlawful, however, you do not want to erase your personal data, but to restrict their usage instead;
· we do not need the personal data anymore for processing purposes, but you require them for the establishment, exercising or defense in relation to legal actions;
· you have objected to the processing of the data pending the verification as to whether the legal grounds of TESY for the processing of the data override your interests.
If we have received a request for restriction of processing, we will inform you before the lifting of the restriction of processing.
f) Right to data portability
You can request the data that you have submitted, in a structured, commonly used and machine-readable format, where the following two conditions are simultaneously met:
· the specific data processing is based on a received consent or on a contract; and
· the processing is carried out by automated means.
g) Right to object
On grounds relating to your particular situation, you have the right to object at any time to the processing of your personal data, which is based on a legitimate interest or is necessary for the performance of a task carried out in the public interest or the exercise of official authority, if such tasks or authorities are vested with TESY, including profiling based on these grounds.
When you have granted your consent as to the processing of personal data for the purposes of direct marketing, you are entitled to object to the processing of the personal data at any time, without stating the grounds to that effect.
h) Right to lodge a complaint
If you think that we have breached the applicable personal data protection legislation while processing your data and as a result of this we have affected your rights, please contact us. Of course, you also have the right to lodge a complaint with the supervisory authority. In Bulgaria, this is the Commission for Personal Data Protection.
Settlement of disputes and applicable law
In case of disputes, the applicable law is the law of the Republic of Bulgaria and the competent court is the relevant court in the city of Sofia.
Any disputes between TESY and the users of www.tesy.com in relation to the personal data may be settled through negotiations between the parties. In the less likely case of a legal dispute, it shall be referred to the Commission for Personal Data Protection or directly to the competent court in the city of Sofia.
For further information, as well as in relation to the exercise of your rights, you can contact us at email@example.com.