Privacy Policy
Effective Date: August 5, 2024
If this Policy is translated into any language other than English, in the event of a conflict, the English language version shall govern to the fullest extent permitted by applicable laws.
Introduction
„Com Sy 54 – Vasil Zashev and Associates“ Ltd (“we“, “us”, “our”) are committed to protecting and respecting your privacy.
This privacy policy (“Privacy Policy”) in accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (“GDPR”) and any other applicable local laws, as amended or replaced (collectively, “applicable privacy laws”), sets out the basis on which we collect and process your personal data as a data controller when you use our website or services.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting comsyworld.com, you are accepting and consenting to the practices described in this Privacy Policy.
Who is the data controller and data protection officer?
„Com Sy 54 – Vasil Zashev and Associates“ Ltd is the data controller. We are a software company based in Sofia, Bulgaria. Our address is: 2A, “Frederic Joliot-Curie” Str., 1113. Our VAT number is BG131205011.
For any requests about how we use your personal data, you can email us at: mobile@comsyworld.com.
What data do we collect?
We may collect and process personal data about you. We will only use your personal data when the law allows us to. Personal data, or personally identifiable information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data). We collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site or the Services.
Usage Data: Includes information about how you use our Site and Services, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site and Services (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Aggregated Data: We also collect, use, and share statistical or demographic data for any purpose. This Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Special Category Data: We do not collect, store, or use special category data about you. This means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
How is personal data collected?
We use different methods to collect data from and about you including via:
1. Automated Technologies or Interactions: As you interact with our Services, Sites, or emails, we automatically collect Technical Information about your device, browsing actions, patterns, Location Data, and Usage Data. We collect this personal data by using cookies, server logs, web beacons, pixels, and similar technologies about your device and your use of our Site and Services. We may also receive Technical Data and Location Data about you if you visit other websites that employ our cookies. Please see the Cookie section below for further details.
2. Technical Data: From analytics providers, advertising networks, and search information providers such as Google, Hotjar.
3. Communications and Contact Data: This includes data from messages that you send to us.
4. Cookies: We use cookies on our Website. This helps us to provide you with a good experience when you browse it and also allows us to improve it permanently.
What are cookies?
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the Site. Cookies can be “persistent” or “session” cookies. We use persistent cookies and session cookies.
Persistent Cookies: A persistent cookie is stored on a user’s device between browser sessions which allows the preferences or actions of a user across the Site (or in some cases across different websites) to be remembered. We use persistent cookies to save your login information for future logins to the Site or Services.
Session Cookies: A session cookie allows the Site or Services to link your actions during a browser session. We use session cookies to enable certain features of the Site or Services, to better understand how you interact with the Site or Services, and to monitor aggregate usage by users and web traffic routing on the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site or Services and then close your browser.
For the details of the cookies that we use, please view our cookies policy here. You can set up your browser options to stop your computer from accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use the whole of the Site or all functionality of the Services. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.
How do we use your data?
We will not sell or rent your personal data to anyone. We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
How do we respond to legal requests for your data?
We will not disclose your personal data to law enforcement or other governmental authorities unless we believe it is required to comply with warrants, court orders, subpoenas, or other lawful government requests. This may include responding to legal requests from jurisdictions outside of Italy where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards of due process. We narrowly interpret all information requests, and we only disclose content in your account that is specifically responsive to a government warrant or where you have provided your explicit consent. In accordance with our Information for Law Enforcement Authorities page, we will notify you if we believe we are compelled to comply with a third party’s legal demand for your information, and we routinely push back on government orders to delay user notice that we view as overly broad. In addition, in rare cases, we may share your personal data as necessary to investigate or take action regarding illegal activities, suspected fraud, or potential threats against persons, property or the systems on which we operate the Website, or as otherwise necessary to comply with our legal obligations.
How can you manage the data we store?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. For example, all information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavor to protect your data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access. We recognize security standards, with our information security management system relating to confidential data independently certified as meeting the requirements of ISO/IEC 27001:2013. We have various privacy and security policies and procedures in place. We regularly review the appropriateness of the measures we put in place to keep data secure from unauthorized access, use, or disclosure.
How long do we store your data?
Our retention of your personal data is based upon several factors, including the length of time necessary to fulfill the purposes outlined in this Privacy Policy, to make the Website available to you, to demonstrate that we have fulfilled our business and legal duties and obligations and contractual commitments, or as instructed by you, unless a longer period is required or permitted by law. Upon the expiry of the data retention period, the data is either deleted or anonymized.
What happens if you want to stop using the Website?
You can stop using the Website at any time.
Changes to Privacy Policy
Any changes we may make to our Privacy Policy in the future will be posted on the Website. Please check back frequently to see any updates or changes to our Privacy Policy
Other Information
Are children allowed to use the Website?
The Website is designed for adults; we do not intend to collect personal identification data from anyone under the age of 16. If you believe we might have any information from or about a child under 16, please contact us at: mobile@comsyworld.com
How do we respond to Do Not Track signals?
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not currently respond to or otherwise take action in response to web browser “Do Not Track” signals. For information about Do Not Track, visit: https://en.wikipedia.org/wiki/Do_Not_Track.
How can you contact us?
We welcome your feedback regarding this Privacy Policy. If you have questions, comments, or concerns about this Policy, please contact us by email at mobile@comsyworld.com