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PERSONAL DATA PROTECTION POLICY OF HL-TOPMIX OOD (LTD)

In force from May 17th, 2018

INTRОDUCTION

Performing its business activity HL-TopMix Ltd, Unified Identification Code 119520585, with registered office and corporate headquarters: 8881 Kaloyanovo, Sliven district, Bulgaria (“the Company”, “HL-TopMix”, “We”, “Us”), processes information containing, among the rest, also personal data.

The internet page – www.hl-topmix.com is owned by HL-TopMix Ltd and managed by the Company in compliance with the provisions of the Personal Data Protection Act and the related regulations, including, but not limited to Regulation (EU) 2016/679 (“GDPR”).

The present Policy aims at informing you on the way we process your personal data in our capacity of administrator, as well as on your related rights. “HL-TopMix” aspires to provide you with accessible and useful information on its website.

The personal data protection is extremely important to us. “HL-TopMix” shall not sell your data to other companies or persons. If we submit your data to third parties, these are our contractors who process the information on our behalf, following our instructions and applying our standard for personal data protection. We make efforts to be unambiguous, specific and transparent in terms of the information and processing of your personal data we provide you with.

WHAT IS PERSONAL DATA

Personal data is any information, connected to an identified or subject to identification natural person (e.g. e-mail address, names, age, date of birth, phone number, etc.).

Personal data, disclosing race or ethnic origin, political views, religious or philosophical convictions, membership in syndical organizations or processing of genetic data, biometric data with the purpose of unambiguous identification of a natural person, the health or data relative to the sexual life or sexual orientation of a person, are a special category of personal data. “HL-TopMix” does not process such information about you.

COLLECTION AND USE OF PERSONAL DATA

 “HL-TopMix” collects, uses and processes your personal data, required for the Company to offer its services and products of “HL-TopMix” and its partners. Your data serve for the management of your account and your purchases on our internet page. They can also be used for statistical purposes related to the improvement our services quality, as well as for the marketing activities of “HL-TopMix”.

 “HL-TopMix” observes the following principles when processing your personal data:

  • Conformity with the law, conscientiousness and transparency 
  • Limitation of the purposes of processing; 
  • Relevance to the purposes of processing and minimization of the amount of the data collected; 
  • Accuracy and relevance of data; 
  • Limitation of the storage in order to achieve the goals set; 
  • Thoroughness and confidentiality of processing and ensuring an appropriate level of safety of the personal data. 

As below are given examples for the types of information, which “HL-TopMix” can collect, as well as the ways we can use it. Detailed information regarding the different types of data collected, you can find when you use the respective service of “HL-TopMix” and provide information to the Company.

WHAT PERSONAL INFORMATION WE COLLECT

We collect and process all or part of the following personal data:

  • Personal data;
  • Data regarding your transactions and order history;
  • Payment information;
  • Information we collect regarding your participation in our promotions or competitions, or your attendance at our events; 
  • Information regarding your use of our chat-rooms, social network pages or other interactive forums;   
  • Information for surveys;
  • Our correspondence with you;
  • Data regarding the credit status and information against fraud; 
  • Technical data;
  • Information regarding your visits to our websites.

Sources for receipt of personal data

A substantial part of your personal data that we store, have been provided to us directly by you or collected via our contacts with you, our websites or social networks. It is possible to obtain your personal data from other sources, including business partners, subcontractors of technical, financial or logistic services, advertising networks, analysis providers, providers of information regarding the browsing, credit information agencies, databases against fraud or other databases of third parties, including sanctions lists, as well as business information and tools for survey performance.

PURPOSES AND REASONS FOR USING YOUR PERSONAL DATA

The main activities, purposes and reasons connected to your personal data processing for “HL-TopMix” are:

  • Establishing the identity of the customer via all commercial channels;
  • Management and execution of your requests/orders for products or services, performance of contracts for products and services; 
  • Preparation of proposals for conclusion of contracts;
  • Issue and sending of invoices for the products/ services used by you;
  • To provide for an adequate service, as well as to collect the due amounts for the use of the products and services; 
  • The data from your invoices to be consistent with the initial purpose of collection and for preparation of a comprehensive view of our products and services; 
  • To carry out credit evaluation;
  • Notification regarding anything related to the products and services you use with us, send different notifications or response to any requests, claims or proposals submitted by you; 
  • Analysis of the customer history and preparation of a user’s account (profile) for the purpose of drawing up of an adequate offer for you; 
  • To evaluate and measure the effectiveness of our advertisements, as well as to offer an advertising content appropriate for your needs; 
  • Research and analysis of the customer consumption of our products and services based on anonymous or personalized information, in order to establish the main trends, to improve our understating of our customer’s behavior and collaborate with third parties to develop new products and services for our customers; 

The personal information we collect allows us to keep you up-to-date with our newest products and forthcoming events. It helps us improve the development, supply and elaboration of our products, services, the content and advertising.

In case you do not wish to appear in our subscription list, you may unsubscribe at any time by updating your preferences in your account and on the internet page.

It is possible that we use your personal data to send important notifications regarding your purchase status and changes in the rules, terms and different policies.

It is possible that we use your personal data for internal purposes, e.g. verifications, data analysis and surveys in order to elaborate the products, services and communication with the customers of “HL-TopMix” Ltd.

If you participate in events, lottery or promotions, it is possible to use the information submitted by you for the administration of such programs.

Further, your data is processed by “HL-TopMix” for the purposes of:

  • Detecting of anomalies, claims connected to “HL-TopMix” products on the grounds of the legitimate interest;
  • Inquiries sent to us connected to products based on your consent; 
  • Organization of company events and registration of your participation based on your consent. 

COOKIES AND OTHER TECHNOLOGIES, USE OF COOKIES, WHAT ARE COOKIES?

Cookies are small files containing information that are saved on your internet browser (data for language used, connection time, visited internet pages) or hard disk drive when visiting the site. We can consult you in connection with your latest visits in order to facilitate and improve your search results. The paragraphs as below are intended, for the sake of transparency, to give you the necessary and comprehensive information regarding the cookies used by “HL-TopMix” on its website. Please note that if you share your device with other people, it is possible that the personalized character and action of cookies changes.

Cookies are a useful tool because they enable a specific site to recognize the user’s device. Cookies give you the opportunity to efficiently navigate through the pages, save your preferences and improve your user experience as a whole. They can also be used to adapt the ads to your preferences via browsing activity tracking through the sites. 

Cookies for separate sessions are deleted automatically when you close your browser, and the persistent cookies remain on the device after your browser is closed (for example, to save your user preferences when you return to the website).

 “HL-TopMix” shall not be responsible, if the internet browser you use does not support the functions for control of use, refusal for saving or deleting of saved cookies. In case you prohibit the saving of cookies, or delete cookies that were already saved, depending on their type, it is possible to that the site function be disrupted.

Consent

By using the company site of “HL-TopMix” – www.hl-topmix.com (the Website), you agree to use the cookies in compliance with this policy for use of cookies. On your first visit to the website, you will see a pop-up window, which informs you about that. Although, it will usually not appear when you successively visit the site, you can withdraw your consent at any time, following the instructions as below.

After your initial visit to the website, we can change the cookies we use. This policy for use of cookies will always give you the possibility to be aware of who and with what purpose installs cookies, and give you the means to deactivate them, therefore you should check it from time to time.

SOCIAL NETWORKS

Your access to social networks like Facebook, Google+, You Tube, Twitter, and similar, requires a separate registration and acceptance of the general terms of these sites. “HL-TopMix” shall not be responsible for your personal data protection upon acceptance of these general terms. Please read carefully the general terms of those sites.

PERSONAL DATA PROTECTION

 “HL-TopMix” undertakes safety measures including administrative, technical and physical security measures in order to protect your personal data from loss, theft or misuse /inappropriate use/, as well as from unauthorized access, disclosure, changes or destroying.

When you publish in forums, chatrooms or other social network services, the personal data you share is visible for other users and can be read, collected or used by them. You are responsible for the personal information you choose to share in such cases.

All “HL-TopMix” employees are obliged to safeguard the confidentiality of your data, as well as to observe the applicable organizational and technical measures for its protection. The access to your data is limited based on the need-to-know principle, to enable us perform our obligations.

For the cases in which “HL-TopMix” shares your personal data with third parties – suppliers of “HL-TopMix”, the Company has mechanisms to guarantee that they provide a level of data protection complying with the agreed standard.

STORAGE OF PERSONAL DATA

The personal data we dispose of shall not be stored for a period longer than the legally stipulated and only for the term necessary to provide you with products, services or information on your request or for other purposes, as laid down in the section PURPOSES AND REASONS FOR USE OF YOUR PERSONAL DATA, as above. For example, we may save some details on your transactions, as well as correspondence until the expiry of the term for submitting claims, resulting from a transaction or in order to observe the legal requirements on the storage of such data.

DISCLOSURE OF YOUR PERSONAL DATA

In some cases, “HL-TopMix” may disclose specific personal data to its strategic partners – subcontractors who work with us that supply products or services connected to the business activity of the Company, or assist “HL-TopMix” in the marketing activity to the customers. We will share your personal data only for the purpose of elaboration of our products, services or advertising. It will not be shared with third parties for their own marketing purposes.

For the cases in which “HL-TopMix” shares information about you with third parties – suppliers of “HL-TopMix”, the Company has mechanisms to ensure that such parties dispose of level of data protection in compliance with the agreed standard. Your data are considered confidential also by our partners.

It may become necessary, by law, in a lawsuit, court litigation and/or by request of public or governmental bodies, in or outside your country of residence, for “HL-TopMix” to disclose your personal data. It is possible that we disclose information about you, if we find that for the purposes of the national security, law enforcement or other matters of public importance, such disclosure is necessary or appropriate.  

It is possible that we disclose information about you, if we find that such a disclosure is reasonably required for the application of our rules and terms, or to protect our business activities or users. Moreover, in cases of reorganization, merger or sale, it is possible that we transfer any and all the personal data collected to the respective third party.

TRANSFER TO THIRD PARTIES

As a rule, “HL-TopMix” does not transfer your data to third parties out of the European Union. In specific cases, it is possible that your data be transferred to third parties by virtue of a contract between “HL-TopMix” and a company, acting as a contractor for specific services. In these cases “HL-TopMix” shall ensure that this transfer be executed in complete compliance with the relative legal regulations, guaranteeing the level of protection of your personal data (including but not limited to standard transfer clauses, as approved by the European Commission). The protection of the information remains with your data. If our partners are located in the USA, we shall verify their license under the “Privacy Shield”, a legal mechanism allowing transfer of data to this country.

RIGHTS RELATED TO YOUR PERSONAL DATA

If you have submitted your personal data to “HL-TopMix”, you dispose of the following possibilities at all times:

  • Right to access to your personal data processed by “HL-TopMix”;
  • Right to demand the performance of appropriate correction, deletion or block of your personal data;
  • Right to portability of your data in a structured, extensively used and appropriate for machine reading format;
  • right to object at any time against the processing of your personal data when there are legal grounds for that;
  • Right to refuse the processing of your personal data for the purposes of receipt of an electronic bulletin and other marketing communications, and etc.
  • Right to lodging a claim in the Commission of Personal Data Protection, if you think that your rights related to the protection of your personal data have been violated.
  • If you are willing to exercise your rights or express a refusal regarding the receipt of an electronic bulletin or other marketing communications, you may contact us by sending an email to sales@hl-topmix.com, or by sending a letter to the postal address: 8881 Kaloyanovo, Sliven district, Bulgaria, for the attention of Data Protection Officer.

We may refuse to process requests which are unreasonably repeated, require disproportionate technical efforts, endanger the confidentiality of other users, or requests which are extremely impractical, or otherwise legally not required to be accessed.

The exercise of your rights, when they are not repeatable or groundless, shall not be subject to charges.

CHILDREN

We do not collect data from children under the age fourteen. If we find that we have collected personal data for a child under the age of fourteen, we will take steps to delete the data immediately. If parents and/or legal representatives of children find out that children under their tutelage have submitted their data to “HL-TopMix”, please contact us to the addresses indicated in the present policy. We will delete the information promptly.

POLICY VALIDITY AND UPDATE

It is possible that we periodically update our Personal Data Protection Policy. In case of changes in the present policy, a notification will be published on our website, as well as the updated Personal Data Protection Policy.

CONTACT US

IF YOU AFE WILLING TO CONTACT US ON MATTERS CONNECTED TO THE PRESENT POLICY OR THE PERSONAL DATA PROTECTION AT “HL-TOPMIX”, PLEASE DO NOT HESITATE TO CONTACT US USING THE FOLLOWING  METHODS:

At email address: sales@hl-topmix.com

By post: “HL-TopMix” OOD (Ltd), 8881 Kaloyanovo, Sliven district, Bulgaria, for the attention of the personal data protection officer.

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