Your personal data are very important to us and we make all reasonable efforts to undertake the necessary measures to keep your privacy. Please read carefully our privacy policy related to the use of our website before you provide us with your personal data.

Smartcom – Bulgaria AD is a joint stock company, registered with the Commercial Register at the Registry Agency under UIC 130985811, with registered office and address: 1421 Sofia, 20 Lozenets St. (“Smartcom”). This website: smartcom.bg (the “Website”) is owned and operated by Smartcom.

Smartcom is the data controller in respect of the personal data it collects and holds about you on the Website. This policy outlines the basis on which Smartcom processes your personal data as well as your rights in respect of such personal data.

The data subject is a user, who visits and browses our Website.

1. Personal data we process

Depending on how you use our Website, the categories of personal data we may collect and hold about you include:

Personal data when visiting the Website

With standard opening of our website and menus in it, we receive information about you in the form of an information protocol with the following content:

  • the web page that forwarded you to our Website;
  • IP address;
  • date and duration of access;
  • the amount of data transferred;
  • information about the browser and operating system you are using, as well as other technical information which tells us about how you use our Website.

Personal data related to inquiries via our contact details, published on the Website

In case you wish to send a request through our contact details, you could choose to provide us with information of your own discretion, where we will contact you, if necessary, to respond to your inquiry. You may also request information in relation to conclusion of a contract or initiation of a business arrangement.

Personal data related to inquiries via our support contact details, published on the Website

In case you send a request through our support contact details, you could choose to provide us with information of your own discretion, where we will contact you, if necessary, to respond to your inquiry. This could concern your personal data, such as:

  • name;
  • email;
  • telephone;
  • company and position.

Personal data related to marketing information

In case you wish to receive information and updates in connection to current services and products offered by us, we will request you [to actively register] and provide us your contact details, such as:

  • name;
  • salutation;
  • email;
  • telephone;
  • company and position.

Smartcom does not request to receive from you any sensitive personal data, e.g. racial or ethnic origin, political views, religious or philosophical conviction, union membership, health or sexual orientation, neither children personal data, so please do not submit such information in your inquiries.

2. Purposes of personal data processing

The purpose for processing your personal data depend on the functions and options that you have chosen, when browsing the Website.

Personal information when visiting the Website

Your personal data are processed for the purpose to ensure network and information security, to analyze how our Website is being used and improve your browsing experience, to host maintain and otherwise support the operation of our website, for risk management purposes, for business and disaster recovery (e.g. back-ups) and to ensure the quality of our services we provide to our users.

Personal information related to inquiries via our contact details, published on the Website

Your personal data are processed for the purpose to manage our business, to communicate with you, to answer any query that you may have and to ensure the quality of our services we provide to our users.

Personal data related to inquiries via our support contact details, published on the Website

Your personal data are processed for the purpose to meet our contractual obligations and provide to our clients the required technical support under agreements, concluded with them.

Personal data related to marketing information

Your personal data are processed for the purpose to provide you with up-to-date information about our current products and services if you agree so, as well as to contact you and offer marketing information about our products and services only in case that you agree with this.

If you choose not to provide personal information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfill the purpose(s) for which we have asked for the personal information. Aside from this, your visit to our Website will remain unaffected.

3. The basis for personal data processing

Personal information when visiting the Website

The legal ground for processing your personal information when visiting our Website is the legitimate interest to ensure IT security and better browsing experience.

Personal information related to inquiries via our contact details, published on the Website

The legal ground for processing your personal information, related to inquiries via our contact details, published on the Website is the legitimate interest to respond to your queries and provide services and/or information to you. In case you have requested information in relation to the conclusion of a contract or initiation of a business arrangement, the legal ground for processing the information is for the conclusion of a contract.

Personal data related to inquiries via our support contact details, published on the Website

The legal ground for processing your personal information, related to inquiries via our support contact details, published on the Website is for the performance of our obligation under concluded contract.

Personal data related to marketing information

The legal ground for processing your personal data is your informed and freely given consent, which you unambiguously express, by voluntarily providing your personal information for the purposes of receiving information and updates in connection to our products and services.

We consider that the risk to your data protection rights in connection with personal information that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.

4. Storage. Access to and sharing of your personal data

Your personal data will be stored within the European Economic Area (“EEA”) and will not be transferred and processed in countries outside the EEA. Your data will be stored in electronic format.

Some of the functionality on our Website involves us cooperating with, and sharing your personal information with, third parties.

Our Website uses Google Analytics, a web analysis service provided by Google Inc. (“Google“). Google Analytics works using the so-called “cookies”. We use the information collected by Google Analytics cookies to find out how visitors use our Website.

Google Analytics cookies collect your IP address, however because IP anonymisation is used in our Google Analytics settings, your IP address will be anonymised as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics.

The IP address sent by your browser in connection with Google Analytics will not be combined by Google, with other data.

In order to improve our users’ experience, we may use Google Analytics features such as Remarketing, Google Display Network Impression Reporting, Demographics and Interest Reporting and Integrated services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers (Google Display Advertising Features). Please see additional information in our Cookie Policy.

You can prevent Google Analytics cookies from being stored by setting your browser software accordingly (see our Cookie Policy for further information).

You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at the following link:

http://tools.google.com/dlpage/gaoptout

We store the information collected by Google Analytics for for the respective terms, provided in our Cookie Policy.

Smartcom will not disclose your personal information to third parties, unless this is required by law. We do not sell, make commercial arrangements, or otherwise outsource your personal data.

In very limited cases, your personal data may be disclosed to the following persons in accordance with the privacy principles:

  • Professional consultants with established reputation, including attorneys and other external professional consultants;
  • Service providers, including companies that provide products and services, such as IT service providers;
  • State and administrative authorities, including regulatory authorities, law enforcement agencies in the course of performing their mandatory functions.
5. Cookies

Where you use our Website, we will process your personal information collected by using cookies in accordance with our Cookie Policy.

6. Data security

Smartcom maintains appropriate technical and organizational measures against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure, we cannot guarantee the security of your information transmitted to our Website.

7. Data retention

We will process your personal data only as long as it is necessary to meet the specific purpose for which you have provided us with it.

Personal information when visiting the Website

We will keep your personal information when visiting the Website for a period of 14 months.

Personal information related to inquiries via our contact details

We will keep your personal data related to Website inquiries, as long as this is needed for answering your questions. If the personal data was provided in relation to a business arrangement or contract, the information is stored until the negotiation has been closed or a contract was signed, in which case you will be provided a separate privacy notice.

Personal data related to inquiries via our support contact form

We will keep your personal data related to inquiries via our support contact form, as long as the respective commercial agreement with our client/business partner is effective, and afterwards, if needed, until the legal prescription periods for protection of our rights expire.

Personal data related to marketing information

We will keep your personal data related to marketing information, as long as we have our consent before you withdraw it.

Once the purpose for which we have collected your personal data is achieved, we commit to immediately destroy them, unless there is a legal deadline for their storage. If you need more information on data storage please contact us on: privacy@smartcom.bg.

8. Links to other web pages

Our website may contain links to other websites, e.g. social networks, trading partners and advertisers. This Privacy Policy does not apply and is not applicable to the other sites mentioned. If you follow a link to such pages, please note that we are not responsible for the content and policies that apply to the protection of personal data on these other websites. Please check these policies before submitting your personal information there.

9. Your rights

You have the right to withdraw your consent for the processing of your personal data at any time. If you do so, Smartcom will not be able to go further in the recruitment process. You can withdraw your consent by sending email with your request at: privacy@smartcom.bg.

You can object to processing based on our legitimate interests at any time by contacting us at: privacy@smartcom.bg.

You have the following rights with respect to the processing of your personal data:

  • Right of access – to access and obtain a copy of your data on request
  • Right of rectification – to request Smartcom to change incorrect or incomplete data about you;
  • Right of erasure (“right to be forgotten”) – to request Smartcom to delete your data when they are no longer necessary for the purposes of processing; please note that we may reject or restrict the request in some circumstances depending on the information we hold and our lawful reason to keep the data;
  • Right to restrict processing – to request that we do not use the personal data you have provided (e.g. if you believe it to be inaccurate, unlawful, overriding our legitimate interest or no longer needed);
  • Right to object – to object to certain processing of your personal data unless we have overriding compelling grounds to continue processing;
  • Right to data portability – to request Smartcom to provide you with a copy of your personal data in a structured commonly used and machine-readable format as well as to request us to transmit your personal data directly to another controller, when this is technically feasible.

The rights listed here are not absolute and there may be an exception in cases provided by law. We will ensure to provide you with explanations regarding such exceptions when you contact us.

If you are willing to exercise any of the rights specified above, you may contact Smartcom as set out below.

10. Contact information

If you are willing to exercise your rights under Art. 7 above or if you have any questions with respect to this document, please contact Smartcom, as follows:

  • address: BIC IZOT, Building 1, Floor 3, Office 317, 133 Tzarigradsko Chausse Blvd., 1784 Sofia
  • phone: +359 (2) 9650650;
  • e-mail: privacy@smartcom.bg

If you think that Smartcom processes your personal data in breach of the applicable data protection legislation, you have the right to submit a complaint to the Personal Data Protection Commission: 1592 Sofia, 2, Tsvetan Lazarov Blvd.; https://www.cpdp.bg/; kzld@cpdp.bg.

11. Updates to our privacy notice

We may need to update our Privacy Notice from time to time. We will communicate any material changes to the Privacy Notice, for example the purpose of why we use your personal data, the identity of the Controller or your rights.