Privacy Policy

I. SUBJECT

This Privacy Policy provides information about how Namereni v prevoda EOOD, hereinafter referred to as the “Provider,” “Administrator,” “we,” and/or “us,” owner/operator of the Website: www.transliterra.com, hereinafter referred to as the “Website,” processes (including, but not limited to, collects and stores) personal data of data subjects, such as users of the Website and the Provider’s services, hereinafter referred to as “User(s)”, “you” and/or “your”, as well as regarding the rights of the latter in this regard.

The term “personal data” used in the Privacy Policy has the meaning given to it in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, hereinafter referred to as the “General Data Protection Regulation” and/or “GDPR” for short, namely: “any information relating to an identified or identifiable natural person (“data subject”); a natural person who can be identified is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.”

Below you will find brief information about:

  • The provider;
  • The competent supervisory authority;
  • The legal basis on which we process personal data;
  • The purposes for which we use personal data;
  • Principles of personal data processing;
  • What personal data we collect;
  • The period for which we store personal data;
  • Access to and transfer of personal data; and
  • The rights and guarantees that the DPO provides to data subjects.

II. INFORMATION ABOUT THE PROVIDER

  1. Name: Namereni v prevoda EOOD, Company ID: 207573823
  2. Address: 23 Blaga Dimitrova St., Sofia, Bulgaria
  3. Mob.: +359 887 182341, email: office@transliterra.com
  4. Entry in public registers: Commercial Register at the Registry agency of the Ministry of Justice of the Republic of Bulgaria.

III. INFORMATION ON THE COMPETENT SUPERVISORY AUTHORITY

  1. Name: Commission for Personal Data Protection of the Republic of Bulgaria
  2. Address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
  3. Telephone: 02 915 3 518
  4. Email: kzld@cpdp.bg
  5. Website: www.cpdp.bg/en/

IV. BASIS FOR THE COLLECTION, PROCESSING, AND STORAGE OF PERSONAL DATA

We process (including, but not limited to: collect and store) your personal data solely in connection with our activities and in accordance with the requirements of applicable law, including the Personal Data Protection Act of the Republic of Bulgaria and the General Data Protection Regulation.

We process your personal data on at least one of the following grounds:

  • Consent of the User for the processing of personal data;
  • The processing of personal data is necessary for the performance of the Supplier’s contractual obligations to the User;
  • Processing of personal data is necessary to take steps at the request of the User prior to entering into a contract;
  • Processing of personal data is necessary for compliance with the Provider’s legal obligations;
  • The processing of personal data is necessary for the purposes of the legitimate interests pursued by the Supplier in the performance of its activities.

V. PURPOSES OF COLLECTION, PROCESSING, AND STORAGE OF PERSONAL DATA

We collect, process, and store Users’ personal data in connection with the provision of our services and communication in connection with the use of the Website, as well as for the following purposes:

  • Communication and identification in the performance of contracts (including in the performance of the relevant contract);
  • Communication, identification, processing, and fulfillment of requests, requests, reservations, and purchases of services (including preparation for the conclusion of a contract, acceptance of orders, sending orders, resolving issues related to order cancellations, reservations, returns of purchased services, refunds of paid amounts, and others);
  • Compliance with tax and other legal obligations;
  • Accounting purposes in connection with the use of our services;
  • Protecting our legitimate interests in connection with the fulfillment of our obligations to state and municipal authorities (e.g., the National Revenue Agency);
  • Protection of our legitimate interests in connection with the storage of information for the purpose of protection against legal or tax claims and for the purpose of improving the performance of the Website;
  • Protecting the information security of the Website;
  • Statistical information about the use of the Website;
  • Providing advertising content tailored to the User’s interests;

If a data subject refuses to provide us with some or all of the personal data necessary for the relevant purpose specified above, we may not be able to provide the relevant service (e.g., to perform a contract concluded with the relevant User) or to comply with the relevant legal requirements (e.g., to enable the data subject to exercise their rights under the GDPR).

VI. PRINCIPLES OF COLLECTION, PROCESSING, AND STORAGE OF PERSONAL DATA

We adhere to the following principles when collecting, processing, and storing your personal data:

  • lawfulness, fairness, and transparency;
  • purpose limitation;
  • limiting the storage period to achieve the purposes for which the data is processed;
  • minimization of the data processed;
  • accuracy and relevance of the data;
  • integrity and confidentiality of data processing and ensuring an appropriate level of security for personal data.

VII. PERSONAL DATA

We collect the following categories of personal data from Users for the following purposes and on the following grounds:

  • your identifying data (first and last name, phone number, and email address), as well as other data you voluntarily provide to us for the purposes of processing your inquiries, providing service offers, and providing services on our part, at your request, including communication with you in this regard, and on the basis of taking steps at your request to possibly conclude a contract, performing a contract to which you are a party, or your consent to processing;
  • your personal data (first and last name, telephone number, and email address) and information related to payment and selected payment methods for the purposes of issuing and sending accounting/tax documents (invoices) in connection with the services you use, including communication with you in this regard, and on the basis of taking steps at your request for the possible conclusion of a contract, the performance of a contract to which you are a party, or the performance of our legal obligation;
  • your IP address, browser settings and language preferences, pages visited, and actions taken for the purpose of sending push notifications, if you have expressed a wish to receive them;
  • your IP address, pages visited, for the purposes of information security;
  • other data that may be necessary in certain cases or related to the provision of services to Users by us, including data necessary for the performance of contractual obligations (e.g., date of birth, signature, personal identification number) or other data that Users voluntarily choose to share with us, and on the basis of the performance of a contract to which you are a party, your consent to processing, or compliance with our legal obligation.

We use cookies on the Website. You can read more about this here: Cookie policy.

We do NOT process or collect special categories of personal data from Users (e.g., data revealing racial or ethnic origin, political opinions, genetic or biometric data, as well as data concerning the sex life or sexual orientation of the data subject).

We do not make decisions based solely on automated data processing, including profiling.

We usually receive personal data directly from the data subject. However, we may also receive personal data from other persons, such as: other employees in the company where the data subject works, as well as from publicly available sources such as the Commercial Register and the Register of Non-Profit Legal Entities at the Registry Agency of the Ministry of Justice of the Republic of Bulgaria.

VIII. RETENTION PERIOD OF PERSONAL DATA

We store Users’ personal data for no longer than is necessary to fulfill the relevant processing purpose or for the legally established period, where applicable. For example:

  • personal data provided by you when filling out the contact form will be stored until the request is fulfilled or your inquiry is satisfied, in connection with which you have contacted us, as well as for a maximum of one year thereafter for statistics and marketing analysis;
  • personal data of our customers processed in connection with contracts concluded between us and the respective User will be stored for a period not exceeding ten years, starting from January 1 of the year following the year in which the contract was reported for tax purposes;
  • personal data of our customers processed in connection with the issuance of tax documents (invoices) will be stored for a period not exceeding ten years, starting from January 1 of the year following the year in which the document was reported for tax purposes;
  • personal data of our partners/suppliers processed in connection with contracts concluded between us and the respective partner/supplier will be stored for a period not exceeding ten years, starting from January 1 of the year following the year in which the contract was reported for tax purposes;
  • personal data of participants in recruitment and selection procedures will be stored for a period not exceeding six months from the date of the final completion of the recruitment/selection procedure in which the relevant data subject participates; after the expiry of the deadline for appealing the procedure in question, unless the data subject has consented to the storage of his/her personal data for a longer period, in which case the data subject has the right to withdraw his/her consent at any time and without giving reasons.

The storage period depends, among other things, on the duration of the legal relationship between us and the respective User, as well as on the purposes for which the personal data is processed. Where there are indications of potential legal claims or liability, these periods will be extended accordingly. When the processing is based on the User’s consent (e.g., in cases of personal data provided by third parties for direct marketing), we store this personal data for as long as we have valid consent for its processing.

Upon expiry of the above-mentioned periods, we take the necessary steps to delete and/or destroy your personal data without undue delay.

IX. ACCESS TO PERSONAL DATA AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES

In principle, the personal data of Users that we process is accessible to our employees, representatives, and partners who need it to fulfill legal obligations and/or to fulfill contractual obligations (e.g., providing a service under a contract with a User). In this regard, it is possible, at our discretion and in compliance with the requirements of the GDPR, to transfer all or part of your personal data to third parties such as accountants, professional consultants, including lawyers (for the purposes of financial, accounting, and administrative services related to our activities), cloud platforms for data processing/storage (for the purposes of organizational services for our activities, e.g., storage and processing of contracts with Users of cloud platforms for greater security), companies providing postal services (for the purposes of organizational services for our activities, e.g., sending paper contracts to Users), IT service providers, system administration, marketing services (for the purposes of providing more reliable and higher quality work on the Website and more secure data processing), providers of third-party information storage services (i.e., hosting companies) (for the purposes of performing contracts with Users).

Based on applicable law or at the request of public authorities, all or part of your personal data may also be accessible to public authorities.

We do not intend to transfer your personal data to countries outside the European Economic Community or to international organizations.

X. RIGHTS OF DATA SUBJECTS

At any time while we are processing your personal data, and subject to the restrictions set out in applicable law, you, the data subject, have the following rights:

Right of access – you have the right to request information about whether we are processing your personal data, as well as to obtain access to and a copy of such personal data; if you request more than one copy of such personal data, you may be required to pay a fee for each additional copy;

Right to rectification/correction – you have the right to request that your personal data be corrected if you believe it is inaccurate or incomplete. We will make such corrections/rectifications without undue delay;

Right to erasure/to be forgotten – in certain circumstances (e.g., the personal data is no longer necessary for the purposes for which it was collected; you have withdrawn your consent for the processing of certain personal data for which there is no other legal basis), you may request that your personal data be erased. you have withdrawn your consent to the processing of certain personal data for which there is no other legal basis for processing) you may request that your personal data that we process be deleted from our records/database without undue delay. In certain cases, we may refuse to delete such personal data (for example: the processing of personal data is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims);

Right to restriction of processing – where certain conditions apply (for example, the processing of certain of your personal data is unlawful, but you do not want the data to be deleted), you have the right to request that the way in which your personal data is processed be restricted;

Right to data portability – when your personal data has been provided to us by you and is processed by automated means, you have the right to request that your personal data be transferred to you in a structured, commonly used, and machine-readable format, as well as to be transferred to another personal data controller, if technically feasible;

Right to object – you have the right, at any time, to object to the processing of your personal data for specific purposes, in which case we will stop using your personal data for that specific purpose, unless we have compelling legitimate grounds for doing so (for example: you have the right, at any time, to object to the processing of your personal data for direct marketing purposes, in which case we will cease processing your personal data for these purposes without undue delay);

Right to object to automated processing, including profiling – you have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, and you also have all the rights that arise for you if you are subject to the legal consequences of such processing;

Right to withdraw consent for processing – if we process your personal data on the basis of consent, you have the right to withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

If, at the request of a User, we delete their personal data from our database, we will only retain information that may be necessary to protect our legitimate interests or for public authorities.

You have the right to request that we inform you of all recipients to whom the personal data for which correction, deletion or restriction of processing has been requested has been disclosed. We may refuse to provide this information if it is impossible or requires disproportionate effort.

If we are required to transfer personal data to another controller, to correct or delete personal data, to restrict the processing of personal data or to terminate such processing, to provide information about the recipients to whom the personal data for which correction, deletion or restriction of processing has been requested has been provided, or to provide access to personal data, and if there are concerns regarding the identity of the User who made the request, we will do so. deletion or restriction of processing, or to provide access to personal data, and in case of concerns regarding the identity of the User who made the request, we may first request additional information to confirm the identity of the data subject in question.

If, during the processing of your personal data, there is a third party to whom all or part of your personal data has been transferred (as indicated in section IX above), all of the above requests will be forwarded to that third party.

The exercise of the above rights is free of charge for Users, except where the requests made are manifestly unfounded or excessive. In such a case, we may either charge a reasonable fee for the performance of the request or refuse to act on the request.

Users may exercise the above rights by contacting us by email at: office@transliterra.com

XI. COMPLAINT TO A SUPERVISORY AUTHORITY

If you believe that your personal data is not being processed lawfully or that any of your rights relating to the protection of personal data have been violated, you have the right to lodge a complaint with the competent supervisory authority for personal data protection specified in Part III above of the Privacy Policy. You also have the right to seek legal protection of your rights.

If the Website contains links to other websites, we recommend that you carefully review the privacy/confidentiality policies of these other websites, because when you visit these websites, your personal data may be processed by these websites, which processing is not covered by the Privacy Policy.

We reserve the right to change the Privacy Policy at our discretion and whenever we deem it appropriate.