) describes how Ton Op DOO EOOD, a limited liability company
having its seat and registered address at 8 Borba Str., Plovdiv, Bulgaria, 4021, registered with the Bulgarian Commercial Register under Company registration No. 206196853 (“We”, “Us”, “Our” or “Ton Op”
), may use, process, store and disclose Personal Information that We may collect about individuals, including if you register with Us at https://tonop.bg/my-account. The types of data We collect are described in the section below ‘Your Personal Information and how We collect it.’
We act as a controller under the meaning of 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 (“General Data Protection Regulation” or “GDPR”
) and We are responsible for the Personal Information We process. This Policy informs you how We protect your Personal Information and informs you of your privacy rights.
This website is not intended for use by legal minors and We do not knowingly collect data relating to legal minors.1. Your Personal Information and how We collect it
When you use or register on this website We may ask for certain Personal Information including your name and contact information (email, home address and phone number). Depending on the nature of your enquiry or activities on Our website, We may also ask for and/or collect:
2. Our clients and suppliers
- information you provide including in emails, letters or during telephone calls
- technical data including 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 website. We may also receive technical data about you, if you visit other websites employing Our cookies;
- profile data including your username and password, your interests, preferences, feedback and customer survey responses;
- usage data including information about how you use Our website and services;
- marketing and communications data including your marketing and communication preferences.
If you are a client or supplier of goods and services, We will collect and process information about individuals in your organization to enable Us to communicate with them and to provide Our services or receive goods and services. We may also find the details of corporate contacts published on other websites and social media. We may enter the individual’s name and business email address into Our database as a designated corporate point of contact for that client or supplier, together with the individual’s other business contact data.3. How We use your Personal Information
We use, process, store and disclose your Personal Information and other data We collect including during registration process, for the purposes of performing the services requested and functionalities offered by the site and to provide you with services through this website and by email.
We use, process, store and disclose your Personal Information and other data We collect when you apply for a services at Ton Op (including emails, letters and during telephone calls and conversations) for the purposes described in this Policy including: (a) processing and updating your Personal Information; (b) business planning, reporting and forecasting; (c) safety and security issues; (d) responding to your enquiries and complaints; and (e) to fulfil legal and statutory obligations.
We will also process your Personal Information for other legitimate business purposes, such as producing statistics, analysing how successful Our marketing campaigns are, the number of visitors to Our website and complying with other contractual, legal and regulatory obligations and duties.
We will only use your Personal Information for the purposes for which We have 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 We need to use your Personal Information for an unrelated purpose, We will notify you and We will explain the legal basis, which allows Us to do so.
We may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.4. Disclosing your Personal Information to 3rd Parties
To the extent necessary or appropriate and without notifying you, Ton Op may disclose your Personal Information to external 3rd Parties in the following circumstances:
- to companies and individuals, We appoint to perform business functions and services on Our behalf;
- to comply with applicable laws, the service of legal process, or if We reasonably believe that such action is necessary to: (a) comply with the law requiring such disclosure; (b) protect the rights or property of Ton Op; (c) prevent a crime, protect national security or for fraud detection or prevention; or (d) protect the personal safety of individuals using Our website or members of the public.
- to 3rd parties to whom We may choose to sell, transfer, or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, We will let you know.
- to IT consultants carrying out testing and development work on Our IT systems, service providers who We may appoint as data processors and to other service providers.
Where applicable, We will impose appropriate contractual, security, confidentiality and other obligations on to 3rd party service providers and processors We have appointed, based on the nature of the services they provide to Us. We will only permit them to process your Personal Information in accordance with the law and Our instructions. We do not allow them to use your Personal information for their own purposes and when Our relationship ends, We will ensure your Personal Information is securely returned or destroyed.5. Keeping your Personal Information secure
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We have put in place procedures to deal with any suspected Personal Information breaches and We will notify you and the applicable supervisory authority of a breach where We are legally required to do so.6. How long We retain your Personal Information
Ton Op will retain your Personal Information for as long as necessary to fulfil the purposes that We collected it for. This means We will keep your Personal Information throughout the period of your relationship with Us.
If you no longer wish to receive Our services, We will continue to retain your Personal Information after Our relationship ends only if you give Us your consent to keep it further.
We are required by law to keep basic information about Our associates, clients and customers (including contracts, evidence of identity, financial and transaction data) for up to 5 years from when Our relationship ends, for legal, compliance and tax purposes.
Where there is no retention period stated in law, We determine the appropriate retention period for Personal Information by considering the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which We process it and whether We can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances We may anonymize your Personal Information (so that it can no longer be associated with you and We cannot identify you). We do this for research or statistical purposes in which case We may use this anonymized data indefinitely without further notice to you.7. Your Legal Rights
You have the right to:
Make a Data Subject Access Request
to access your Personal Information at any time. This enables you to receive a copy of the Personal Information We hold about you and to check that We are lawfully processing it.Request correction
of the Personal Information that We hold about you. This enables you to have any incomplete or inaccurate Personal Information We hold about you corrected, although We may need to verify the accuracy of the new data you provide to Us.Request erasure / deletion / removal
of your Personal Information. This enables you to ask Us to delete or remove your Personal Information where We do not have a valid reason to continue to process it. You also have the right to ask Us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where We may have processed your information unlawfully or where We are required to erase your Personal Information to comply with local law. Please Note: We may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.Object to processing
of your Personal Information where We are relying on a legitimate interest (or those of a 3rd party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your Personal Information for direct marketing
purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms.Request restriction of processing
of your Personal Information. This enables you to ask Us to suspend the processing of your Personal Information in the following scenarios: (a) if you want Us to establish the data’s accuracy; (b) where Our use of the data is unlawful but you do not want Us to erase it; (c) where you need Us to hold the data even if We no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to process it.Data Portability / Request the transfer
of your Personal Information to you or directly to another controller. This right only applies to automated information which you initially provided consent for Us to use or where We used the Personal Information to perform a contract with you. We will (unless there is an exemption) assist you by securely transferring your Personal Information directly to another controller where technically feasible or by providing you with a copy in a structured commonly used machine-readable format.Withdraw consent at any time
where We are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
We want to ensure We keep your Personal Information accurate and up to date. In addition to your legal rights, you may ask Us to make changes or request a copy of your Personal Information informally, by contacting Us at email@example.com
.8. Additional information, response times and fees
We may need to request specific information from you to help Us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights or when you make an informal request). This is a security measure to ensure that Personal Information is not disclosed to any person other than the individual who has the right to receive it. We may also contact you to ask you for further information in relation to your request to help Us locate your data and to speed up Our response.
We try to respond to all legitimate requests within one month. It may take Us longer than a month if your request is particularly complex or you have made a number of requests. In this case, We will notify you and keep you updated.
You will not have to pay a fee to exercise any of these rights. However, We may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, We may refuse to comply with your request in these circumstances.9. The legal basis for processing your Personal Information
We have set out a short description of main ways We will collect, store, process, share and disclose your Personal Information and the legal bases We rely on to do so. We have also identified what Our legitimate interests are, where appropriate.
We will only use your Personal information when the law allows Us to. Most commonly, We will use your Personal information in the following circumstances:
- To fulfil a contract, We are about to enter into or have entered into with you;
- Where it is in Our legitimate interests;
- When it is Our legal or regulatory duty;
- When you consent.
A legitimate interest is when We have a business or commercial reason to use your information in conducting and managing Our business. We will consider and balance any potential impact on you and your legal rights when We process your Personal Information for Our legitimate interests. We do not use your Personal Information for activities where Our interests are overridden by the impact on you (unless We have your consent or are otherwise required for compliance with a legal or regulatory obligation or permitted to by law).10. Cookies