FOR THE PROTECTION OF PERSONAL DATA
Information about ELLEYA Ltd as an administrator of personal data:
ELLEYA Ltd, UIC: 201319138, with headquarters and management address in Ruse, 19 Dondukov Korsakov str., 4 fl., phone: +359 82 507 606, fax: +359 82 593 286, email: firstname.lastname@example.org
We implement the Personal Data Protection Policy both for data, collected from you via our website elleya.eu ("the Website"), and via paper forms, filled in personally by you or our representative, via an email correspondence, conclusion of a contract or other methods for collecting personal data as allowed by law.
Through this privacy declaration, we inform you about our practices, which we use when protecting your data, about your rights, which you have regarding your collected personal data through our website and/or collected by us through other means, mentioned above.
When collecting and processing your personal data, ELLEYA follows all laws and regulatory rules, which state how these actions must be carried out, for what purposes and what safeguards should be applied to protect personal data. The relevant regulatory rule includes, but is not limited to, the General Data Protection Regulation (Regulation (EU) 679/2016), the Personal Data Protection Law, as well as all related regulations.
Principles when collecting, processing and storing your personal data
We comply with the following principles when processing your personal data:
- lawfulness, good faith and transparency;
- limiting the purposes for data protection;
- minimizing data collection;
- accurate and up-to-date data;
- limiting data storage to only the necessary data for the needed purpose;
- integrity and confidentiality of the processing, as well as ensuring an adequate level of security of the personal data;
Why do we collect personal data and what do we use it for:
ELLEYA processes your personal data for the purposes described below:
- for registration in our website, in order to use the services, which require registration;
- for access to our info database, for which you have subscribed;
- for your registration and permission to attend events, which ELLEYA organizes or co-organizes;
- to send you electronic newsletters, for which you have explicitly subscribed;
- to send you information about our services and invitations for events, if you have explicitly given permission for that;
- to send you information about products, services and events of our partners, when you have explicitly given your permission for that.
What personal data do we collect from you
In most cases, we collect data from you, which are explicitly specified in the law or data, which is necessary for the conclusion and execution of a particular contract between us.
We will inform you in a clear and transparent way in case we need to collect personal data from you, which is not explicitly specified in the law as obligatory, but ELLEYA finds necessary and/or has a legitimate interest in collecting it or is necessary in order to defend your vital interests.
Data for the purpose of using the services and registering at ELLEYA’s website
You could register at the website elleya.eu
In the forms, through which personal data is being filled in, we clearly indicate the provision of which data is obligatory. This is such data, without which it would be impossible for us to provide the respective service or part of it.
Data, related to the electronic newsletters, for which you have subscribed
You personally and voluntarily subscribe to our media newsletter, which ELLEYA offers. This happens through the website elleya.eu, and the newsletter subscription can be terminated at any moment by sending an email, expressing your will to unsubscribe.
Data, which we collect during registration for events, which ELLEYA organizes
When you register for an event, which ELLEYA organizes or co-organizes, we collect from you the following data: name and family name, company position, company which you work in, company address, postal code (not obligatory), phone number, email. The data is necessary for the provision of the service and your identification in order to gain access to the respective event.
For the purposes of events, which require special access, we may collect other data needed to gain access to the event.
Cookies and other passive technologies
ELLEYA uses "cookies" and other tracking technologies, which collect information from you when interacting with our website, in order to improve their performance.
What are cookies?
The cookies are small text files, which the website can store on your computer or mobile device, when you visit a webpage or a website. The cookie will help the website or other websites recognize your device the next time you visit them. Web beacons or other similar files can do the same. We use the term “cookies” in the Policy to name all the files that collect information in this way.
There is video surveillance at the entrance to our office. The video surveillance is based on our legitimate interest, for the purposes of guarding the office and assets of ELLEYA. The video surveillance is done taking into account the rights and freedoms of individuals and its perimeter is limited to the degree required for security purposes. The necessary technical and organizational measures have been taken to protect your privacy. Records are kept for a period no longer than 30 days and are then destroyed.
Data, collected by other sources
We may collect information about you from other legitimate sources in order to provide you with quality services. Such sources can be information from our partners (in case you have agreed) and publicly available information. This information includes:
- contact data about you;
- publicly available information with data about the individuals, who represent your organization.
We collect other publicly available information only after we have an explicit declaration from the individual, who shares it with us, that you have agreed for it to be shared with us.
When we contact you, we will inform you where we have your personal information from, in case we have not collected it personally from you.
Your consent and our legitimate interest
Outside the cases, where we collect personal data because of law requirement, contract, legitimate interest or to protect your vital interests, we will ask for your permission.
We will use your personal information only after your explicit consent for the specific purpose.
You have the right, if you change your mind later, to withdraw your consent.
Disclosure of your data to third parties
ELLEYA does not share your personal data with third parties, except in cases where this is required by law or when it’s necessary to provide services that you have requested. ELLEYA discloses your personal data only in the following cases:
- only before state authorities, institutions and persons, to which we are required to provide personal data by law;
- to persons, which under contract maintain equipment, software and hardware, used for the processing of personal data;
We use service providers when processing personal data for purposes, such as measuring and tracking user behavior on sites, sending emails, sharing user content, etc. These companies are (the list is not full):
- Google (with Google Analytics, Google Tag Manager, DoubleClick for Publishers, AdX, AdSense, AdWords, Google Plus): https://privacy.google.com
- Facebook (with Facebook Tracking Pixel, Facebook Tools – Plug-in "like" button, Sign in with Facebook profile etc.): https://www.facebook.com/privacy/
- LinkedIn: https://www.linkedin.com/legal/privacy-policy
- Mail Chimp: https://mailchimp.com/legal/privacy/
ELLEYA collects, processes and stores personal data while following all legal requirements and implementing adequate technical and organizational safety measures.
When we store the information, it is physically saved on servers, located in data-storing centers.
Period (term), during which we store your personal data
Your personal data is stored for a period, determined in the current legislation, depending on the purpose, for which they are collected.
In case there is no such legal period, ELLEYA assumes, that it will store your personal data for a reasonable period, defined on the basis of additional criteria. The period-defining criteria are consistent with our desire to provide you with high quality services, as well as with a normal development of our affiliate relationships.
Our goal is for the processing of your personal data to require minimum efforts on your part in terms of re-registrations or repeated provision of data.
When the personal data, which we collect, is no longer necessary for the purposes in question, we delete it, anonymize it or destroy it in another appropriate manner.
Rights of the data subjects
(1) Each person has the right to access his/her own personal data, including asking for confirmation on whether data related to it is being processed, to be informed about the purposes of this processing, data categories and everyone they will be revealed to, as well as the purposes for each personal data processing related to it.
(2) The right to access is accomplished via a request of the individual in question, received at the address of ELLEYA’s headquarters or the official email.
(3) Each individual person has the right to request the deletion, correction or blocking of his personal data, the processing of which does not comply with the requirements of the law.
(4) Each person has the right to object, in writing, against the processing of and/or the provision of his personal data to third parties without the necessary legal basis.
(5) ELLEYA is obligated, in two weeks’ time since receiving the request under the preceding paragraphs, to notify the requester whether there is legal basis for approving the request. If ELLEYA establishes, that there is legal basis to respect the request, it informs the person and the manner, in which he/she can exercise his/her right.
(6) Data subjects also have the right to:
- withdraw their consent for processing at any time;
- object to the use of their personal data for the purposes of direct marketing;
- request information for the basis, under which their personal data is provided for processing to a data processor outside the EU/EEA;
- object to a decision, which is taken based on entirely automatic processing, including profiling;
- be informed about a breach in data protection, which will possibly lead to high risk for their rights and freedoms;
- file complaints with the regulatory body;
- in some cases, to request their personal data to be transferred to a third party in a structured, widely used format, appropriate for machine reading (right of portability).
In some cases, we are required by law to store your personal data. In these cases, it won’t be possible to delete your personal data from our systems.
Update/renewal of the internal rules
The current rules are revised and updated by us regularly, in order to be as clear as possible, accurate, transparent and to accommodate new changes (if it’s necessary).
Date of last update – November 2019
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