Personal data policy

 

Policy for protection, confidentiality and integrity of personal data at www.GO e-motion.bg

 

I. INTRODUCTION

On May 25, 2018, the General Data Protection Regulation (GDPR) came into force in all EU member states. It applies directly in Bulgaria as well as any national law and covers the rights and obligations of administrators, processors and subjects of personal data; some of the details are additionally regulated by the Bulgarian Personal Data Protection Act. All visitors to our website are data subjects and have different rights in this regard. This policy aims to inform you about the principles of protection and the personal data of visitors to our site, about our obligations as a controller of personal data and about the measures we have taken to prevent your data from being used without your knowledge by whom and for what purposes or without being able to object or withdraw your consent to their processing.

The policy will not remain the same throughout the existence of our website; as digitization advances and the regulation of personal data processing relationships evolves, we will seek to continually improve and align our practices with these developments, which in turn will be reflected in policy. It is our intention to publish a short notice in the "news" section of www.goemotion.bg with the most important highlights every time we make a change to the policy on protection, privacy and privacy of personal data (the "Policy" or "this policy"). .

• This policy covers all activities related to the processing of personal data within the framework of digital assets - owned by "GREEN I-MOTION" OOD is a company registered under the Commercial Law of the Republic of Bulgaria with EIK 206783092, with headquarters and management address in the city of Varna , 28 Hristo Popovich St., email address phone +359897999425, hereinafter referred to as GO e-motion for brevity;

• in case of ambiguities related to the application of this policy or the exercise of your rights, you can contact us at E-mail: office@goemotion.bg or at the above address: city of Varna, "Hristo Popovich" street no. 28.

 

II. SOME IMPORTANT CONCEPTS FOR BETTER UNDERSTANDING OF THIS POLICY

"Personal data" - this is any information that relates to you - the visitor / user of our website and that alone or in combination with other information can help us to establish your identity or to associate your user behavior with a specific device, from which you access our website, for example.

"Subject of personal data" - this is you, the visitor of our site. What is written in this policy applies only to people, natural persons, unless something different is explicitly stated.

"Processing of personal data" is any action that we perform or may perform with your personal data, including but not limited to its collection, analysis or destruction.

"Administrator of personal data" - in relation to our website, this is us, GO e-motion - "GREEN E-MOTION" LTD. We determine the purpose of processing your data, on one of the grounds provided for by law; essentially, we also determine the means by which this processing takes place – for example, the technical infrastructure and applications with which the processing takes place. Obligations regarding the security and protection of your personal data arise for us. For some processing of personal data, we may act together with another controller.

"Joint controllers" - controllers who jointly determine the purposes and means of processing. This can be an agency for the implementation of GO e-motion's marketing strategies, with which we jointly determine the goals and means for this.

"Processor of personal data" - this is GO e-motion or a third party that processes your personal data on our behalf, where GO e-motion has strictly determined the purpose of the processing, the means by which it takes place and verified that the person complies with GDPR requirements. Such a processor could be, for example, an agency that is responsible for a GO e-motion marketing campaign on a social network and creates reports on its success.

A "cookie" is a small piece of text or data that is sent to your device (computer, laptop, tablet, phone) for storage and can be requested back from the domain from which it is "pinned" to the device. The function of the cookie can be very diverse: from keeping you in a "logged" state while filling out a certain registration form, to saving your language preferences for browsing our website, to tracking your behavior when surfing the Internet, sometimes for a long time period of time and regardless of the device used: in the latter case, as in all other similar cases, such a cookie cannot be used without your prior consent on the basis of detailed information received.

 

The GDPR introduces or reinforces substantial legal mechanisms for the benefit of data subjects. Below we have indicated some of them that are relevant to the processing of personal data in connection with the use of digital assets.

"Digital Assets" - the Website www.goemotion.bg and GO e-motion Facebook page; the website consists of two sections - in one, corporate information about GO e-motion and information about the products offered in them can be found, and the other section is an online store, from which the visitor can remotely purchase products offered in the GO e-motion online store motion products.

"User session" - The time between the authorization of the user and the moment of his exit or expiration due to inactivity of the same. During this time, the GO e-motion system uniquely recognizes the customer.

"Plug-in" - third-party software implemented in a GO e-motion digital asset and related to tracking user behavior and/or ensuring the operation of certain functionality by switching to the third-party domain.

"Information society services" are services generally provided for a fee and at a distance through the use of electronic means. The recipient of such service must have expressly requested it. E-commerce is also a type of such service.

 

III. COLLECTION AND USE OF PERSONAL DATA

GO e-motion strives to protect the privacy and ensure the security of the personal data of visitors and users of its digital assets. When you visit our website, the web servers of third parties that we have allowed on our site (e.g. Google) will temporarily store data about the connectivity of your device to our website, as well as the pages you have visited on our site, identification data about the type of Your browser and operating system, as well as for the website from which you were referred www.goemotion.bg. We do not collect or process other personal data about you - for example your name, address, telephone number or e-mail address, unless you provide it in connection with your specific information request, when filling out a registration form for a job application or for a given service or with a view to creating an account in our e-shop or requesting the issuance of a GO e-motion club card By creating an account, you receive additional convenience when shopping online, which requires registration on our website and an access password in order to easy identification and protection of your personal data.

Before receiving your personal data processed through the website, we will notify you of this in accordance with the requirements of Art. 13 of the GDPR. Thus, when processing occurs, you will know who is the administrator, on what grounds and for what purposes it processes your data, how it is stored, etc.

 

IV. FOR WHAT PURPOSES AND ON WHAT BASIS DO WE USE YOUR PERSONAL INFORMATION

1. Purposes of processing

GO e-motion collects through the website and uses your personal data for the following purposes:

• Provision of services requested by you

Almost all personal data that you fill in the registration forms or your profile is necessary to respond to your need or requested service that GO e-motion provides. In order to provide quality online and offline services, we need your identification data, the scope of which varies depending on the type of service requested and the legal requirements applicable to it.

In many cases, you use the registration forms prepared by us to ask a clarifying question in relation to the services provided, to express dissatisfaction or satisfaction, to file a complaint, complaint or claim.

• Selection of employees who applied for job advertisements

We offer a convenient opportunity through our website to familiarize yourself with announced job positions in GO e-motion and to apply for the ad of your choice. Thus, through the website, you can submit your documents, and for the purposes of the selection, we will identify you and process the information you sent and your personal data.

• Marketing activity

The personal data provided by you for the purposes of creating a profile for use of the e-shop, for example, as well as in other registration forms, may be used to inform you about new services provided by GO e-motion, available discounts on existing services or certain service facilities we have created for you. The messages sent by us will be in accordance with the applicable Bulgarian and EU legislation.

In order to offer you discounts and promotional products, we also process your data when issuing a club card in the course of the GO e-motion Loyalty Program and when you send a consultation request through the website.

You can also indicate on our website that you wish to subscribe to our newsletter by providing us with your email address.

You can object in an easy and convenient way to the use of your data for marketing, where the basis for the processing is a legitimate interest, and we will stop it immediately; information on how to withdraw consent once given or object to receiving an unsolicited marketing message will always be placed prominently in the message.

For the purposes of marketing activity, we perform traffic analysis and track user behavior on the website through codes from third-party domains, where we process your personal data using cookies. You can read more about them in Section VI of this policy.

 

2. Grounds for processing

When we process personal data for the purposes of providing services that you have requested through our website, we most often process your personal data on a contractual basis pursuant to Art. 6, paragraph 1, letter "b" of the GDPR. When you contact us through our contact form, the basis on which we process your data is the consent you give us - Art. 6, paragraph 1, letter "a" of the GDPR.

In the event that you apply for a position announced by GO e-motion through the website, we collect the data for selection purposes on the basis of your consent to this in accordance with Art. 6(1)(a) of the GDPR.

For the purposes of marketing activities, we process your personal data because we have a legitimate interest within the meaning of Art. 6, paragraph 1, letter "f" of the GDPR or because you have given us your consent for this on the basis of art. 6, paragraph 1, letter "a" of the GDPR.

 

V. WHAT TYPES OF PERSONAL DATA WE PROCESS

1. When providing services requested by you

• To purchase products from our online store - name, surname, phone number, city, postal code, address and e-mail address;

• In case you choose the online payment option for the product, we do not process the transaction data, but only refer you to the secure environment of the payment system ("Borika").

• To contact us - the contact form requires you to provide us with a name and e-mail address so that we can identify you and respond to your inquiry, request or other.

 

2. When applying for a job advertisement

When you apply for a job in GO e-motion, you provide us with the following data: names, details of your education, qualification, professional experience, motivation, etc., included in your CV or cover letter.

 

3. When carrying out marketing activity

• To apply for a card from the GO e-motion Club loyalty program and check the card - name, surname, phone number, city, postal code, address and e-mail address, date of birth, gender. When checking through the website of your card, you need to be a registered GO e-motion user in the mobile app.

• To subscribe to our newsletter, you voluntarily provide us with your e-mail address, to which we send you news.

• For the purposes of marketing activity, we also use cookies, and you can learn more about your personal data processed through them in our Cookie Policy.

 

 

VII. DISCLOSURE OF YOUR PERSONAL INFORMATION

In order to be fully informed about which third parties and for what purpose they can gain access to your personal data collected on the occasion of visiting/using our website, please familiarize yourself with the following.

Recipients of your personal data are GO e-motion marketing campaign agencies. These companies receive your data when setting cookie settings and conducting other marketing activities related to our website and our Facebook page.

Processors of your personal data are also all third parties that attach codes and cookies to your device when you visit our website, such as Google and Facebook.

A processor of personal data and in this capacity a recipient may be the companies that carry out the web hosting of our website.

Recipients of your personal data for marketing purposes may be companies that conduct e-mail marketing by sending you promotional e-mail messages and attaching codes when they are opened.

Companies that provide IT support for our information systems in which we store your data received through the website may also have access to your personal data. Their access to the data in the systems aims to ensure the normal and secure functioning of the systems, and thus the protection of the processed data.

 

VIII. PROTECTION OF PERSONAL DATA

GO e-motion takes safeguards, including administrative, technical and physical measures, to protect your personal information from loss, theft and misuse, as well as from unauthorized access, disclosure, alteration or destruction.

All employees of GO e-motion are obliged to protect the confidentiality of your information, as well as to comply with the applicable organizational and technical measures for protection. Access to your data is limited on the basis of necessity for the performance of the duties of the relevant employee/contractor who accesses it.

 

IX. STORAGE OF PERSONAL DATA

The personal data received through the forms on the website are stored in our information system, for the functioning of which technical and organizational security measures have been taken, i.e. h. use of a separate high-end server with limited access, on which only and only this website is located; using an encrypted connection to access the server; use of SSL and DDoS protection, HTTP/2, "smart" Firewall and fail2ban.

Personal data collected through cookies is kept for the periods indicated in the cookie table above.

CVs, photos and contact details sent through the website are collected with your consent and are subject to strict confidentiality; the data of applicants who are not selected to enter into a contract with GO e-motion are destroyed immediately after the end of the selection procedure, but no longer than 6 months; the details of successful job applicants become part of their employment records.

 

X. YOUR RIGHTS AS A PERSONAL DATA SUBJECT

1. Right to information

You have the right to receive information about important features of the processing of your personal data, including but not limited to its purpose, term and basis, about the recipients and categories of recipients of personal data and others. Depending on how the information was originally collected, we will display the most important information in that connection in a relevant and easily visible way each time.

 

2. Right of Access

You have the right to access your personal data collected directly by GO e-motion by logging into your GO e-motion account or by contacting us by e-mail: office@goemotion.bg

 

3. Right of portability

We are obliged to provide you with all personal data processed by us, provided to us in order to carry out a service at your request or collected by you with your consent, upon request, in a machine-readable format. The request should be sent by inquiry to us at an e-mail address office@goemotion.bg. When you make a request for portability, we must comply with it within 20 business days of receiving it via the electronic communication channel specified by you. The term may not be exactly 20 working days when the cookies through which your personal data are processed are attached by external domains with your consent; in our response to your request to exercise the right of portability, we will indicate the period within which we will be able to fulfill your request.

If you wish, we can forward the file to another online store. In the event that requests to us from the same data subject are made more than 2 times per year, we may collect a fee for this service in a reasonably reasonable amount.

 

4. Right to rectification

You have the right to ask us to correct incorrectly recorded or stored personal data about you that you have provided to us through our website and we must do so within 15 working days of receiving your request. You can send your request to us by email: office@goemotion.bg

 

5. Right to request restriction of processing of your personal data

You have the right to request that we temporarily suspend the processing of your personal data (without deleting them) in the event of your objection to specific processing or in the event of a legal claim or complaint to the Personal Data Protection Commission. You can address the request to us by email: office@goemotion.bg

 

6. Processing based on the legitimate interest of GO e-motion or a third party and objection to such processing

Where your consent has not been requested and given for the purposes of specific processing, or it is not immediately necessary for the performance of a service requested by you, we are most likely based on our or a third party's legitimate interest, which we have determined will not damaged or would slightly affect your right to privacy. Such judgment will always be documented by us and will follow certain criteria and reasoning. You have the right to familiarize yourself with the main points of it upon request, as well as to raise an objection that, given the particularities of your specific situation, the relevant processing affects your right to privacy and/or protection of personal data in a more substantial way than provided for in the justification way. In these cases, we should consider your objection and issue a reasoned opinion on its acceptance or rejection within 20 working days. By objecting to this processing, you can also exercise your right under item 5 above. The objection can be addressed to us by email: office@goemotion.bg

 

7. Withdrawal of Your Consent

In cases where we have requested your consent for a certain processing of your personal data, you can always withdraw it. If you are not sure on what basis we are processing your personal data, you can always ask us about this, as well as about the exact way in which you gave your consent - you can send the inquiry to us at office@goemotion.bg. We will respond to you within 15 working days. We maintain an up-to-date database of consents for the processing of personal data, which we can refer to at any time. Withdrawal of consent is done in the same way as you gave it and we will provide you with information or email where you can do this easily and conveniently in response to your inquiry.

 

8. Right to appeal to the Personal Data Protection Commission

Whenever you believe that your rights under the GDPR have been violated, you can lodge a complaint with the Commission for Personal Data Protection. However, it would be very constructive if you could contact us by e-mail beforehand office@goemotion.bg, to discuss the issue. We undertake to return an answer to you within 15 working days of receiving your complaint or question.

VIOLATION OF PERSONAL DATA RIGHTS

To submit a request regarding the rights of a subject of personal data at www.goemotion.bg se

Complete and send a concrete request to office@goemotion.bg