- IN GENERAL
- Your personal data are processed by Index-6 Ltd., with address: 28 B, Kuklensko Shose Street, Plovdiv 4004, Bulgaria (hereinafter “we”, “us”, “our”). You can contact us via e-mail at: firstname.lastname@example.org
- TYPES OF PERSONAL DATA WE PROCESS
- Whenever you visit or use our Website and social media channels, we collect:
When you fill out a contact form or create a user account on our Website, or contact us via e-mail, telephone, fax or social media channels, we might collect:
- Technical information associated with the device you use, such as your internet protocol (IP) address, browser type, geographical location and operating system;
- Information concerning your browsing behaviour, such as how long you visit, which links you click on, which pages you visit and how many times you visit a page of the Website.
We receive all personal data mentioned above directly from you. It may happen that we receive additional information about your preferences and surfing behaviour from partners such as Google. If you require more information about the personal data these parties process about you and make available to others, you are kindly requested to consult their respective privacy policies.
PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
- The basic identity information that you provide us with (name, e-mail address, postal address, telephone number, country, family composition, date of birth etc.);
- The content of your communication or enquiry and the technical details of the communication itself (with whom at Spadel you correspond, date, time, etc.);
- Your preferences with regard to the communication medium used;
- Publicly available information of your profile on social media channels;
- Any other personal data you choose to provide to us.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
- We process your personal data to provide you in a personalized and efficient way the information, products and services you request via the Website, e-mail, telephone, fax or social media channels.
- We process your personal data for marketing purposes, i.e. to provide you with targeted communications, promotions, offerings and other advertisements of Spadel and selected partners.
Unless you are an existing customer who has already purchased similar goods or services from us and who we wish to target with our own marketing material, we will only send you communications, promotions, offerings, newsletters and other advertisements via e-mail or other person-to-person electronic communication channels if you explicitly consented to receiving such communications, promotions, offerings, newsletters and other advertisements.
- In the framework of providing you e-mail and online marketing or other commercial communications, we process your personal data for collecting information about which of our content in those communications you have accessed or on which links in those communications you have clicked (e.g. via tracking technologies such as web beacons in our e-mails).
- We process your personal data for profiling you based on your location, your consumption habits of our products and/or on which of our content in our e-mail and online marketing and other commercial communications you have accessed.
- We process your personal data to comply with legal obligations or to comply with any reasonable request from competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities.
Your personal data may be transferred upon our own initiative to the police or the judicial authorities as evidence or if there are justified suspicions of an unlawful act or crime committed by you through your use of or registration with the Website, our social media channels or other communication with us.
- We process your personal data to perform statistical analyses so that we may improve our Website, advertisement, products and services or to develop new products and services.
- If your personal data is processed for the purpose outlined in Article 3.1 and in order to take steps prior to entering into a contract with us, we base the processing of your personal data on the necessity for the performance of that contract, or in the process of entering into that contract.
- The processing of your personal data for the purpose outlined in Articles 3.2, 3.3 and 3.4 is based on your consent.
- For the purpose mentioned in Article 3.5, the processing of your personal data is necessary for a legal obligation that we have to comply with.
- For the purposes mentioned in Articles 3.1, 3.6 and 3.7 above, the processing of your personal data is necessary for purposes of our legitimate interests, such as:
TO WHOM WE SEND YOUR DATA
- Continuous improvements of our Website, social media channels, products and services to ensure that you have the best experience possible;
- Keeping our Website, social media channels, products and services safe from misuse and illegal activity;
- Marketing and promotion of our products, services, brands and overall successful commercialization of our products and services.
LOCATION AND TRANSFER
- We rely on third-party processors to provide you our Website and process your personal data on our behalf. These third-party processors are only allowed to process your personal data on our behalf and upon our explicit written instruction.
We warrant that all third-party processors are selected with due care and are committed to observing the safety and integrity of your personal data.
- We do not send your personal data in an identifiable manner to any other third party than the ones mentioned in Articles 5.1 and 5.2 without your explicit consent to do so. However, we may send anonymized data to other organizations that may use those data for improving products and services as well as to tailor the marketing, displaying and selling of those goods and services.
- We process your personal data within the European Economic Area (EEA). However, in order to process your personal data for the purposes outlined in Article 3 above, we may also transfer your personal data to other entities of the INDEX-6 Ltd. or to third parties which process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards will be the consequence of:
We may transfer anonymized and/or aggregated data to organizations outside the EEA. If such transfer takes place, we will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data that you enjoy under applicable mandatory law.
- The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
- A contractual arrangement between us and that entity.
- We do our utmost best to process only those personal data which are necessary to achieve the purposes mentioned in Article 3 above.
- Your personal data are only processed for as long as needed to achieve the purposes mentioned in Article 3 above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. We will de-identify your personal data when these data are no longer necessary for the purposes mentioned in Article 3 above, unless there is:
We will take appropriate technical and organizational measures to keep your personal data safe from unauthorized access or theft as well as accidental loss tampering or destruction. Access by our personnel or of our third-party processors will only occur on a need-to-know basis and be subject to confidentiality obligations. You acknowledge, however, that safety and security are best-efforts obligations which can never be guaranteed.
If you are registered to receive communications, promotions, offerings, newsletter and other advertisements via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such communications, promotions, offerings, newsletter and other advertisements by following the opt-out link provided in such communications.
- An overriding interest of Index-6 Ltd. or any third party in keeping the personal data identifiable;
- A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
- You have the right to request access to all personal data pertaining to you that we process. We reserve the right to charge an administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request has to specify for which processing activity you wish to exercise your right of access and which data categories you wish to gain access to.
- You have the right to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request has to be accompanied of proof by the flawed nature of the data for which correction is asked.
- You have the right to withdraw your earlier given consent for the processing of your personal data.
- You have the right to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes outlined in Article 3 above or if you withdraw your consent for processing the data. However, we will evaluate a request for deletion against:
- Overriding interests of us or any third party;
- Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
Instead of deletion you can also ask that we limit the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is illegitimate, or (c) the data are no longer needed for the purposes mentioned in Article 3 above.
- You have the right to oppose to the processing of personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. If the intended processing qualifies as direct marketing, you have the right to oppose to such processing free of charge and without justification.
- You have the right to receive from us in a structured, commonly-used and machine-readable format all personal data which you have provided to us.
- If you wish to submit a request to exercise one or more of the rights mentioned above, you can send an e-mail to email@example.com. An e-mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request has to clearly state which right you wish to exercise and the reasons for it if such is required. It should also be dated and signed, and accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form on the Website, we may ask you for your signed confirmation and proof of identity.
We will promptly inform you of having received this request. If the request proves valid, we will honour it as soon as reasonably possible and at the latest within thirty (30) days after having received the request.
If you have any complaint regarding our processing of your personal data, please feel free to contact us via e-mail at firstname.lastname@example.org. Should you remain unsatisfied with our response, you have the right to file a complaint with the competent data protection authority.