PRIVACY POLICY

We, at TERMOMOST OOD („TERMOMOST“ or „“we“, “us”) take seriously the collection of personal data from our end-users and we are committed to protecting the privacy of every individual in accordance with 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 (“GDPR”), the Personal Data Protection Act and the current privacy policy for the use of our website https://termomost.bg/(the “Site”).

By using the Site, you agree to the collection and use of information in accordance with this policy (“Privacy policy“ or „Policy“).

PERSONAL DATA

What is Personal Data

Personal Data is any information that relates to an identified or an identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.

Personal Data We May Collect

Information that you provide us

We collect the following information that you provide us through:

  1. The contact form on our Site, email or phone:
  • Name
  • E-mail address
  • Phone number, when contacting us over the phone
  • Any other information you may decide to provide when contacting us.

Information that we may collect from third parties

We may receive information about you from other sources. We may add this information to the information we have already collected from you through our services to improve it.

Links to the privacy policies of third parties – service providers, used by the Site:

Google Analytics

Google Maps

FOR WHAT PURPOSES WE USE YOUR PERSONAL DATA AND ON WHAT GROUNDS
  • To respond to your inquiries

We collect the data you provide to us when you make an inquiry in order to respond to you and we collect it on the basis of your consent.

  • Improving our services

We would always like to offer you the best experience using the Site. For that purpose, we may use certain information about your user behaviour, invite you to complete satisfaction surveys directly or through partners, market research and other research, and send you educational emails. Educational emails contain instructions, tips or perhaps information about the advanced features of the Site. The purpose of these communications is to streamline the work of the end user. Educational emails never include marketing messages.

We base these activities on our legitimate interests in the conduct of our business and always ensure that your fundamental rights and freedoms are not affected.

  • For direct marketing

We require your prior consent to send you various marketing messages, e.g. newsletters, polls. You can change your mind and withdraw your consent at any time by:

- using the “Unsubscribe” link in the messages you receive from us; or

- contacting us using the contact details below.

  • Protection of our legitimate interest

There may be cases in which we use or transmit information to protect our rights and our business. These may include:

  • measures to protect the Site and users of the Site against cyber-attacks;
  • measures to prevent and detect attempted fraud, including the transmission of information to the competent public authorities;
  • measures to manage various other risks.

The main ground for these types of processing is our legitimate interests in protecting our business by stipulating that we ensure that all measures we take ensure a balance between our interests and your fundamental rights and freedoms.

On our Site we may process information through cookies and similar technologies in accordance with our Cookie Policy.

HOW LONG DO WE RETAIN YOUR PERSONAL DATA

Personal data collected only for the purpose of making contact shall be stored until the completion of the relevant communication, unless applicable law requires otherwise.

SENSITIVE INFORMATION

We do not collect sensitive Personal Data.

We ask that you not send us, and you do not disclose, any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background or trade union membership) on or through the Site or otherwise to us.

HOW PERSONAL DATA MAY BE DISCLOSED

To the extent permitted by applicable law, and for fulfilling the purposes for which it is collected, Personal Data may be disclosed:

  • to our third-party service providers who provide services such as accounting, website hosting, data analysis, infrastructure provision, IT services, email delivery services and other services, to enable them to provide their services;
  • to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
  • as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
USER’S RIGHTS

Access to your Personal Data

You have the right to view, amend, or delete the Personal Data that we hold about you. To request access please email office@termomost.bg. We will provide the information free of charge and within one month, except in the event that the request is unfounded, excessive or repetitive, in which case we reserve the right to charge a proportionate administration fee or refuse.

Rectification of Personal Data

If any of the information we hold on you is inaccurate or incomplete, you may ask us to correct or complete it at any time.

Your right of erasure, or to be forgotten

You may ask us to delete your Personal Data, but only if:

  • it is no longer necessary for the purposes for which it was collected; or
  • you have withdrawn your consent (if the processing of the data is based solely on consent); or
  • exercise a legitimate right of objection; or
  • it has been unlawfully processed; or
  • there is a legal obligation in this respect.

We have no obligation to honour your request for deletion of your Personal Data if processing is required:

  • to fulfil a legal obligation; or
  • to establish, exercise or protect a legal claim.

There are certain other circumstances in which we are not obliged to comply with your request for data deletion, even though these are the most likely circumstances in which we may decline your claim.

To request deletion of your personal information, contact office office@termomost.bgusing the email address we hold for you or otherwise proving your identity.

Please note that the data deletion process with all data and documents associated with it is irreversible.

Restriction of data processing

You may ask us to restrict the processing of your Personal Data, but only if:

  • its accuracy is being challenged (see Rectification of Personal Data section) to be able to verify its accuracy; or
  • processing is illegal, but you do not want the data to be deleted; or
  • it is no longer necessary for the purposes for which it was collected, but we still need to identify, exercise or defend a legal claim; or
  • you have already exercised the right of objection and you are checking whether the dominance of our rights is still in place.

We may continue to use your Personal Data as a result of a restriction request:

  • if we have your consent; or
  • to establish, exercise or defend a legal claim; or
  • to protect the rights of the Site owner or any other person or entity.

Data portability

You may ask us to provide your Personal Data in a structured, widely used and machine-readable format, or you may request that it is directly transferred to another data operator, but only if:

  • the processing is based on your agreement or the conclusion of a contract with you; and
  • processing is carried out automatically.

Right to objection

You may object at any time, for reasons related to your particular situation, to the processing of your Personal Data based on our legitimate interests if you believe that your fundamental rights and freedoms dominate these interests.

You may also object at any time to processing your data for direct marketing purposes by following the instructions on the email we send you or by sending an email to office@termomost.bg.

Making automated decisions

TERMOMOST does not conduct profiling or automated individual decision-making.

Your right to file a complaint with the Supervisory Body

If you believe that TERMOMOST process your Personal Data in the wrong way, you can contact office@termomost.bg.

You have the right to complain to your jurisdiction’s local authority on the processing of your Personal Data.

In Bulgaria, the contact details for the supervisory authority for the protection of personal data are as follows:

Commission for the Protection of Personal Data

2, Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria,

Phone: + 359 2 915 35 18

E-mail: kzld@cpdp.bg

OTHER INFORMATION

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity, such as:

  • browser and device information, carrier, internet connectivity
  • server log file information and application usage logs
  • information collected through cookies, pixel tags and other technologies
  • demographic information and other information provided by you
  • location information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Data under applicable law, then we may use and disclose Other Information for all the purposes for which we use and disclose Personal Data.

DATA SECURITY METHODS

For the purpose of protecting User data against unauthorized or accidental disclosure, we use reasonable and appropriate technical and organizational measures. Technical measures consist in the application of technologies that prevent unauthorized access to the User's data by third parties. For the purpose of maximum security, we use encryption of user and end user data, communication on the Site and all data stored on servers. The organizational measures include a set of rules for the conduct of our employees and are included in our internal regulations, which are, however, considered confidential for security reasons. TERMOMOST undertakes to ensure that in the case of hosting servers in a data center managed by a third party, similar technical and organizational measures are also implemented by such third party.

All data is placed only on servers located within the European Union.

TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATION

TERMOMOST We do not transfer Personal Data to third countries outside the EU.

THIRD PARTY SITES

The Site may contain links to other websites, mobile applications and other online services operated by third parties. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of third parties, including third parties operating any site to which such sites link. The inclusion of a link to the site does not imply endorsement of the linked site by us.

We are also not responsible for the collection, use and disclosure policies and practices (including data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft or any other application developer, application provider, social media platform provider media, operating system provider, wireless service provider or device manufacturer, including in relation to Personal Data you disclose to other organizations through or in connection with our social media pages.

 

COOKIES POLICY

You can access our Cookie Policy here.

DATA CONTROLLER

The Personal Data Controller for the information you provide or we collect under this Privacy Policy is: TERMOMOST OOD, UIC 206704554, seat and management address: 111, Tsarigradsko shose, Sofia Tech Park, Laboratories Building, ground floor.

HOW TO CONTACT US

You can contact us directly if you have any questions regarding our Personal Data processing practices. Please send your inquiry to office@termomost.bg, or to: 111, Tsarigradsko shose, Sofia Tech Park, Laboratories Building, ground floor or by calling:  0899 29 3999.

CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy at any time. The current version of the Privacy Policy is always be available on the Site. If a significant change occurs within this policy in regard to the manners of handling Personal Data, we will inform you by publishing a notification in a visible manner prior to the implementation of such changes. We agree that changes cannot be retroactive. We recommend checking the Privacy policy from time to time when utilizing the Site.

Your continued use of the Site after changes to the Privacy Policy are communicated to you constitutes your acceptance of the updated terms.

Last Updated: 13.10.2022