Mandatory Information on the Rights of Individuals to Protection of Personal Data (Privacy notice)


Summary

On 25 May 2018 a new General Data Protection Regulation of the European Union (Regulation (EU) 2016/679, GDPR) shall enter into force. The regulation aims to ensure the protection of data of individuals from all EU Member States and to harmonize regulations for processing.


As a provider of software as a service "Browswave" AD (hereinafter the "Company" or "Browswave") meets all requirements of the new regulation by collecting only data of individuals insofar as necessary to provide the service. Browswave keeps the data responsibly and lawfully.


"Browswave" AD operates in accordance with the Personal Data Protection Act.and 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.


Information on the Controller

  1. Name: Browswave AD

  2. Company ID: 204458374

  3. Headquarters: Bulgaria, Sofia 1225, ul. Taiga 14

  4. Address of business: Bulgaria, Sofia 1225, ul. Taiga 14

  5. Address for correspondence: Bulgaria, Sofia 1225, ul. Taiga 14

  6. Email for correspondence on matters relating to your personal data rights: accounting@browswave.com

  7. Website: www.browswave.com


Information on the Competent Supervisory Authority

  1. Name: Commission for Personal Data Protection

  2. Headquarters: Bulgaria, Sofia 1592, bul. Prof. Tsvetan Lazarov 2

  3. Address for correspondence: Bulgaria, Sofia 1592, bul. Prof. Tsvetan Lazarov 2

  4. Email: kzld@government.bg, kzld@cpdp.bg

  5. Telephone: +359 2915 35 18

  6. Website: www.cpdp.bg



Basis for the Collection, Processing and Storage of Your Personal Data

Art. 1. (1) Browswave collects and processes your personal data in relation to the provision of specialized software and services for market research in application of an agreement between your company / your employer and Browswave and in relation to achieving and concluding such an agreement on the basis of Article 6, paragraph 1, Regulation (EU) 2016/679, and in particular on the following basis:

(2) Browswave is a data controller in respect to your data as a user of our services. In respect to the data that you process using our services Browswave acts as a data processor.




Purposes and Principles of the Collection, Processing and Storage of Your Personal Data

Art. 2. (1) Browswave collects and processes your personal data your company / your employer is providing in connection with the use of the services agreed between the two parties as well as in connection with concluding an agreement between the two parties, including for the following purposes:

(2)Browswave observes the following principles in the processing of your personal data:

(3) When processing and storing personal data Browswave can process and store personal data in order to protect its legitimate interests as follows:



Types of personal data collected, processed and stored Browswave

Art. 3. (1) Browswave performs the following operations with personal data for the following purposes:

(2) Browswave processes the following categories of personal data and information for the following purposes and for the following reasons:

(3) Browswave does not collect and process personal data that relates to the following:

(4) Personal data is collected by Browswave from the persons to whom it relates.

(5) The Company does not engage in automated decision-making based on personal data.



Storage period for personal data

Art. 4. (1) Browswave stores your personal data for a period not longer than the existence of your profile. After this period Browswave due cares to delete and destroy all your data without undue delay.

(2) Browswave notifies you in the event that the period for which your personal data is stored needs to be extended in view of the fulfilment of the purpose, implementation of the agreement with your company / your employer, with a view of the legitimate interests of Browswave or otherwise.

(3) Browswave stores personal data that it is required to keep under applicable law for the period which may not exceed the period of existence of your profile.



Transmission of your personal data processing

Art. 5. (1) Browswave may at its own discretion transfer part or all of your personal information to personal data processors in fulfilment of the purposes of processing in strict compliance with the requirements of Regulation (EU) 2016/679.

(2) Browswave notifies you in case of an intention to transfer part or all of your personal data to third countries or international organizations.



Your rights in relation to the collection, processing and storage of your personal data


Withdrawal of consent to the processing of your personal data

Art. 6. (1) If you do not want all or part of your personal data you have given consent to be processed for a specific purpose or purposes continue to be processed by Browswave for this purpose or purposes you can at any time withdraw your consent to processing via the form for giving and withdrawal of consent or via free text written request to Browswave.

(2) Browswave may ask you to certify your personal identity and the identity between you and the person to whom the data relate.



Right of access

Art. 7. (1) You have the right to request and to obtain from Browswave confirmation as to whether or not personal data concerning you are being processed.

(2) You have the right to access to personal data related to you and the information relating to the collection, processing and storage of your personal data.

(3) Upon request, Browswave shall provide to you a copy in electronic or other appropriate form of your personal data undergoing processing.

(4) Providing access to data is free, but Browswave reserves the right to charge an administrative fee in case of recurrence or excessiveness of requests.



Right to rectification or completion

Art. 8. You may rectify or complete inaccurate or incomplete personal data relating to you via free text written request to Browswave at the address or email for correspondence as listed in section "Information on the Controller".



Right to erasure (“right to be forgotten”)

Art. 9. (1) You have the right to request from Browswave the erasure personal data related to you and Browswave has the obligation to erase them without undue delay where one of the following grounds applies:

(2) Browswave is not obliged to erase the personal data if they are stored and processed:

(3) To exercise Your “right to be forgotten” you must submit a written request to Browswave to the address or email for correspondence as listed in section "Information on the Controller", and certify to Browswave your personal identity and the identity between you and the person to whom the data relate, and, for purposes of certification, present your identity document (ID card or passport) and, if necessary, enter your login credentials in the user profile of the person to whom the data relate.

(4) Browswave does not delete the data which it has a legal obligation to keep, including for the purpose of defence of legal claims against the controller or proof of the controller’s rights.



Right to restriction of processing

Art. 10. You have the right to obtain from Browswave restriction of processing where one of the following applies:



Right to data portability

Art. 11. (1) You may at any time download the personal data concerning You, which are stored and processed in connection with the use of the services of Browswave, with a request by email.

(2) You may request from Browswave to transmit Your personal data directly to another controller, where technically feasible.



Right to obtain information

Art. 12. You may request from Browswave to inform you about all recipients to whom the personal data have been disclosed for which rectification or erasure of personal data or restriction of processing has been requested. You must submit a written request to Browswave to the address or email for correspondence as listed in section "Information on the Controller". Browswave may refuse to provide this information if this proves impossible or involves disproportionate effort.



Right to object

Art. 13. You may at any time object to processing by Browswave of personal data concerning you, including if processing for the purposes of profiling and direct marketing.



Your rights in the case of a personal data breach

Art. 14. (1) If Browswave detects a personal data breach which is likely to result in a high risk to Your rights and freedoms, Browswave shall communicate to You without undue delay the nature of the personal data breach and the measures taken or to be taken .


(2) Browswave is not required to notify you if:



Persons to whom your personal data is provided

Art. 15. Following a request filed by your company / your employer and in application of the agreement between the two sides Browswave transmits the necessary information to the relevant Processor who processes your data for the purpose of providing the agreed services and administration of the agreement.


Art. 16. Browswave does not transfer of your data and to third countries. Exception is the case when your company / your employer has requested the creation of user profiles of individuals situated in a third country – in this case your personal data is visible to those individuals within your company / your employer.



Other provisions

Art. 17. In case of violation of your rights under the above policy or under applicable data protection laws, you have the right to file a complaint with the Commission for Personal Data Protection as follows:

  1. Name: Commission for Personal Data Protection

  2. Headquarters: Bulgaria, Sofia 1592, bul. Prof. Tsvetan Lazarov 2

  3. Address for correspondence: Bulgaria, Sofia 1592, bul. Prof. Tsvetan Lazarov 2

  4. Email: kzld@government.bg, kzld@cpdp.bg

  5. Telephone: +359 2915 35 18

  6. Website: www.cpdp.bg


Art. 18. You may exercise any of the rights relating to the protection of your personal data through the dedicated forms provided by Browswave or by filing a free form written requests stating you claim and identifying you as the data holder. Your claims may be forwarded to the Browswave address or email address for correspondence:

  1. Name: Browswave AD

  2. Company ID: 204458374

  3. Headquarters: Bulgaria, Sofia 1225, ul. Taiga 14

  4. Address of business: Bulgaria, Sofia 1225, ul. Taiga 14

  5. Address for correspondence: Bulgaria, Sofia 1225, ul. Taiga 14

  6. Email for correspondence on matters relating to your personal data rights: accounting@browswave.com

  7. Website: www.browswave.com



Art. 19. If the consent concerns a transfer, the Controller shall describe the possible risks of such transfers of data to third countries due to the absence of an adequacy decision and appropriate safeguards.


Art. 20. (1) When you or your company / your employer instructs Browswave to process personal data of a third party for the purpose of using the service, Browswave acts as Processor.

(2) In the cases referred in paragraph 1, Browswave only acts on your instruction as the user of the service and in so fas as it can have oversight on the personal data you are processing. Browswave has no control over the content and data that you, as the user of the service, choose to upload to the service (including whether or not this data includes personal data). In this case, Browswave has no role in the decision process as to whether the user is using the service to process personal data, for what purposes and whether they are protected. Accordingly, Browswave's liability in this case is limited to 1) compliance with the user's instructions under the agreement and the terms and conditions, and 2) provision of information about the service and the functionalities via its interface.




Cookie Policy


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Basis for the Collection, Processing and Storage of Your Personal Data


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Security measures taken by Browswave with regard to the security of the personal data you store on our infrastructure?


Browswave treats very seriously the measures it takes to ensure the security of all types of information, including personal data, on its infrastructure. These measures include but are not limited to encryption, strict control of electronic data access, strict control of physical access to the servers on which the data are stored, thorough verification of the identity of the persons to whom such access is granted.