Privacy policy
Beluga IT Ltd with registered office and address of management: Sofia, Ovcha Kupel district, residential complex Ovcha Kupel 2, bl. 8-a, ap. 405, UIC 204333666, represented by Svetoslav Mihailov Todorov, in his capacity as controller of personal data is responsible for processing your personal information on this website. In this Privacy Policy, “we” or “us” refers to Beluga IT Ltd.
Please read this Privacy Policy carefully, which describes how we collect, store and use information about those who visit this website (“Personal Data”), how we use your Personal Data and provides information about our actions to respect your rights in relation to your personal data.
Please note that we may periodically change, amend, supplement, shorten or otherwise update this Privacy Policy, and the relevant new version will be published on this website.
When processing personal data, the Administrator complies with the laws and regulations applicable in Bulgaria in connection with the protection of personal data, including, but not limited to, Regulation (EU) 2016/679 (“Regulation”).
Grounds and purposes of personal data processing:
Your personal data will be processed and stored by the Administrator on the following grounds: your explicit consent to the processing of your personal data for the purposes and within the time limits specified in these rules, communication with our team and/or receiving a monthly/weekly bulletin.
Your personal data will be used by the Administrator on the territory of the Republic of Bulgaria and the same will not be transferred to third parties, except on automated marketing platform, which is used when sending the newsletter; the companies running the respective plugin or social network that you decide to use yourself; as well as Google for web analytics. The latter is provided with information only about IP address and log, in order to perform the analysis.
Your personal data will be stored in accordance with the legal requirements for personal data protection in electronic format in the following electronic register maintained by the Administrator: “Electronic Bulletin Register” for no more than the minimum required for this purpose or until your unsubscribe.
Purpose: Legitimate interest:
These are goals related to the legitimate interests of, such as: ensuring the proper functioning and use of the site by you and other users; maintenance and administration of the Services; resolving disputes; detection and prevention of malicious actions; detection and resolution of technical or functionality issues; development and improvement of the Services; communicating with you, including electronically, on important issues related to the Services; realization and protection of the rights and legal interests of Beluga IT Ltd, including in court. For these purposes, it may be necessary to process some or all of the above categories.
Purpose: Legal obligations:
The objectives related to the observance of the legal obligations of Beluga IT Ltd include fulfilment of obligations provided by law for preservation or provision of information upon receipt of a relevant order by competent state or judicial authorities; providing an opportunity to exercise the control powers of the competent state authorities in fulfilling the legal obligations of Beluga IT Ltd to notify you of various circumstances related to your rights, the Services provided, the protection of your data, etc.
The period for which your data will be processed is not more than the minimum required for this purpose after the completion of all activities for the execution of your order. In order to ensure the reliability of the services and prevent data loss for technical reasons, the Site applies a policy of data backup (backup). The maximum update period (including data deletion) of all backups is 60 days
Your personal data will be processed entirely on the territory of the Republic of Bulgaria and will not be provided to third parties, unless: you have requested delivery of the goods ordered by you outside the territory of the Republic of Bulgaria; for web analytics performed by Google; if you use plugins or social networks, under the conditions set out below.
Other cases in which your personal data may be disclosed to third parties are: only when provided by law; if duly requested by a competent state or judicial authority; when we have received your explicit consent to this; when this is necessary for the protection of the rights and legitimate interests of Beluga IT Ltd.
What Personal Data do we process and for what purposes?
Most of our services do not require any form of registration, which allows you to visit our site without informing us who you are. However, for some services, you may need to provide us with Personal Information, such as your name, email address or telephone number. We may collect and use Personal Data to provide you with products or services, to invoice products and services you want, to offer products and services that we believe may be of interest to you (when the legal requirements for this), or to communicate with you for any other purpose that is apparent from the circumstances or that we inform you of when collecting Personal Data from you. The grounds on which we most often process your personal data are your consent, the performance of a contract to which you are a party, the performance of a legal obligation or for the purposes of the legitimate interests of Beluga IT Ltd or other related parties of Beluga IT Ltd.
Your rights regarding the processing of your personal data by us.
You can receive information from the Administrator about your personal data stored at any time and you have the right to access them.
You can request that your personal data be corrected at any time in the event of inaccuracies and/or inconsistencies.
You can request the deletion of your personal data or ask the Administrator to restrict processing.
You have the right to object and complain in connection with the processing and storage of your personal data before the Commission for Personal Data Protection, address: Sofia, Prof. Tsvetan Lazarov ”№ 2., which is a supervisory body in the Republic of Bulgaria.
You have the right at any time and on grounds related to a specific situation to object to the processing of personal data on the basis of a legitimate interest.
In the event of a breach of the security of your personal data, if the breach is likely to pose a high risk to your rights and freedoms, according to the internal rules of the Administrator, you will be notified.
You have the right to request to receive your personal data, which you have provided and which relate to you, in a structured, popular machine-readable format, as well as to use this data for another administrator at your discretion.
In the event that we process your personal data due to your consent when subscribing to receive a newsletter, then you can withdraw the same at any time.
You can learn how we protect your personal information by visiting the page related to ” Protection of personal data”.
To exercise each of these rights it is necessary to send a request by e-mail, formulated in free text and addressed to the Data Protection Officer – Beluga IT Ltd. The communication channels are listed at the bottom of this document in the “Contact Us” section.
Use of your cookies
To make the visit to our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted at the end of the browser session, ie. after you close it (so-called session cookies). Other cookies remain on your device and allow us or our partner companies to recognize your browser the next time you visit (so-called persistent cookies). Cookies can neither be used to access other files on your computer nor to learn your email address. The legal basis for the processing of personal data when using cookies is Art. 6 paragraph 1 para. 1 point (f) of the GDPR.
Cookies are stored on your device and you can fully control their use. By changing your Internet browser settings, you can disable or restrict the use of cookies. Already saved cookies can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, you may not be able to use all features in their full range.
Cookie control in the browser
If you subsequently do not wish us to collect and analyze information about your visit, you can opt-out at any time.
For the technical implementation of this failure in your browser, the corresponding marker is set to Off. This cookie is only used to register your refusal. Please note that for technical reasons, cookies can only be used for the browser from which they are set. If you delete cookies or use another browser or device, you must reset the selection you want.
To learn more about how we work in connection with the use of cookies, you can visit our Cookie Use Policy
Transfer of personal data to third parties
Web analysis with Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses the so-called cookies, i.e. text files stored on your computer to allow an analysis of your use of the website. The information collected through cookies about your use of this website is usually transmitted to a Google server in the United States and stored there.
Our site uses Google Analytics with the “anonymized IP” extension. This means that in the Member States of the European Union or in other countries that are parties to the European Economic Area agreement, your IP address collected by Google-Analytics cookies will be cut off by Google before its transmission to the United States. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and truncated there. When you visit our site, Google uses this information to evaluate your use of the website, to compile reports on website activity and to provide website operators with additional services relating to your use of the website and the Internet. The IP address sent by your browser in the context of Google Analytics will not be merged with other data from Google.
You can prevent the saving of cookies by setting it in the software of your browser; please note that in this case, you may not be able to use all the features offered by this website. You can prevent the collection and processing of data obtained through cookies and related to your use of the website (including your IP address) by downloading and installing a browser plugin from the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Detailed information on terms of use and data protection can be found at http://www.google.com/intl/en/analytics/privacyoverview.html.
Legal basis for the processing of personal data when using cookies is Art. 6 paragraph 1 para. 1 point (f) of the GDPR.
Use the Google Inc. feature remarketing or “Similar target groups”
Our website uses the remarketing or “Similar Target Groups” feature of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Through this feature, we can purposefully display customized advertising to website visitors. When they visit other websites in the Google Display Network, Google uses so-called cookies to perform an analysis of website usage, which forms the basis for creating advertising messages based on interests, for which purpose Google stores a small file with a sequence of numbers. This includes logging website visits as well as anonymized website usage data.This does not store personal data of website visitors.If you then visit another website on the Google Display Network, you will You will be shown inserted advertising messages, which I will most likely be taking into account the previously visited product and information sections. Additional information about Google remarketing, as well as the Google Data Protection Statement, can be found at:
http://www.google.com/privacy/ads/.
You can permanently disable the use of cookies by Google by following the link below and downloading and installing the plugin provided there: https://www.google.com/settings/ads/plugin.
Alternatively, you can disable the use of third-party cookies with Network Advertising Initiative deactivation page at http://www.networkadvertising.org/choices/ and enclosing additional opt-out information.
Legal basis for the processing of personal data when using cookies is Art. 6 paragraph 1 para. 1 point (f) of the GDPR.
Doubleclick from Google
Doubleclick by Google is a service of Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”). Google’s Doubleclick uses cookies to provide you with important advertising messages. In doing so, your browser receives a pseudonymous identification number (ID) to verify which advertising messages are included in your browser and which are called up. Cookies do not contain personal information. The use of DoubleClick cookies enables Google and its affiliate websites to display advertising messages based on previous visits to our or other websites on the Internet. The information collected through cookies is transmitted by Google for evaluation to a server in the United States and stored there. Transmission of data through Google to third parties is carried out only on the basis of legal provisions or within the framework of a data processing order. Google will in no way combine your data with other data collected by Google.
You can prevent the storage of cookies by setting the browser software accordingly; We would like to draw your attention to the fact that in this case you may not be able to use all the features offered by our website. More information about DoubleClick’s data protection can be found here: https://policies.google.com/?hl=en. You can prevent the collection and processing of data obtained through cookies by https://support.google.com/ads/answer/7395996?hl=en downloading and installing the browser plugin available there under the setting of advertising messages, extension for disable DoubleClick.
Legal basis for the processing of personal data when using cookies is Art. 6 paragraph 1 para. 1 point (f) of the GDPR.
Social networks and social plugins
Through our pages in social networks we offer you comprehensive personal assistance. If you send us an inquiry through one of these social networks, we forward it to the competent department. The data is used only to answer your request and is not forwarded to third parties. The legal basis for the processing of personal data within the processing of your request is Art. 6 paragraph 1 para. 1 point (f) of the GDPR. To be able to contact us through social networks, you must be registered in them. To this end, the companies behind each of them process personal data as needed. We do not influence the type, scope and processing of this data.
Using Facebook plugins
Our website uses the social plugin (s) of the social network Facebook, as the Facebook administrator of the personal data of EU persons is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland, and the processor is Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). Information about Facebook plugins and what they look like can be found here: https://developers.facebook.com/docs/plugins.
When you link to a page on our website that contains such a plugin, your browser will establish a direct connection to Facebook’s servers. Plugins transmit their Facebook content directly to your browser and integrate it with the web page. Through this integration, Facebook receives information that your browser has called up the relevant page from our website, even if you do not have a Facebook account or if you are not currently logged in to Facebook. This information (including your IP address) is transmitted from your browser directly to a Facebook server in the United States and stored there. If you are logged in to Facebook, Facebook may link your visit to our website directly to your Facebook account. When you interact with plugins, for example, write a comment, this information is also transmitted directly to a Facebook server and stored there. In addition, the information is published in your Facebook profile and displayed to your Facebook friends. Please note that as a provider of the website, we do not receive information about the content of the transmitted data, as well as their use by Facebook. Information on the purpose and scope of this data collection, the further processing and use of this data by Facebook, as well as your respective rights and settings for the protection of your privacy, can be found in the data protection guidelines of Facebook: https://facebook.com/policy.php
If you do not want Facebook to link the data collected through our website directly to your Facebook profile, you must log out of Facebook before visiting our website. You can also completely prevent the loading of Facebook plugins with Add-Ons for your browser, e.g. with “Facebook Blocker” http://webgraph.com/resources/facebookblocker/
As far as the above-described data are concerned with personal data, the legal basis for their processing is Art. 6 paragraph 1 para. 1 point (f) of the GDPR.
Using YouTube Plugins
Our website uses a YouTube plugin. Services are owned by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).
When you link to a page on our website that contains such a plugin, your browser will establish a direct connection to Google’s servers. Plugins transmit their content from Google directly to your browser and integrate it with the web page. Through this integration, Google receives information that your browser has called up the relevant page from our website, even if you do not have a YouTube account or if you are not currently signed in to YouTube. This information (including your IP address) is transmitted from your browser directly to a Google server in the United States and stored there.
If you are signed in to YouTube, Google may associate a visit to our website directly with your account. Please note that as a provider of the website, we do not receive information about the content of the transmitted data, as well as their use by Google. Information about the purpose and scope of this data collection and the further processing and use of this data by Google, as well as your respective rights and options for the protection of your privacy, can be found in the data protection guidelines of Google: http://www.google.com/intl/en/policies/privacy/.
If you do not want Google to link the data collected through our website directly to your YouTube account, you must sign out of YouTube before visiting our website. You can also completely prevent Google plugins from loading with Add-Ons for your browser.
The legal basis for the processing of personal data when using plugins is Art. 6 paragraph 1 para. 1 (b) or (f) of the GDPR.
Using Twitter plugins
Our website uses the social plugins (plugins) of the Twitter microblogging service, which is owned by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”). Information about Twitter plugins and what they look like will find here: https://twitter.com/about/resources/buttons.
When you link to a page on our website that contains such a plugin, your browser will establish a direct connection to the Twitter servers. Plugins transmit their Twitter content directly to your browser and integrate it with the web page. Through this integration, Twitter receives information that your browser has called up the relevant page from our website, even if you do not have a Twitter account or if you are not currently logged in to Twitter. This information (including your IP address) is transmitted from your browser directly to a Twitter server in the United States and stored there.
If you are logged in to Twitter, then Twitter may link your visit to our website directly to your Twitter account. In addition, the information is published in your Twitter account and displayed there to your contacts. Please note that as a provider of the website, we do not receive information about the content of the transmitted data, as well as their use by Twitter. Information about the purpose and scope of this data collection, the further processing and use of this data by Twitter, as well as your respective rights and opportunities for a privacy setting, you can find it on Twitter’s privacy policy: https://twitter.com/privacy
If you do not want Twitter to link the data collected through our website directly to your Twitter account, you must sign out of Twitter before visiting our website. You can also completely prevent the loading of Twitter plugins with Add-Ons for your browser.
Legal basis for the processing of personal data when using plugins is Art. 6 paragraph 1 para. 1 (b) or (f) of the GDPR.
Using Instagram plugins
Our website uses the so-called social plug-ins (plug-ins) of Instagram, which are owned by Instagram LLC., 1601 Willow Road, Menlo Park, CA 94025, USA (“Instagram”). Plugins are marked with an Instagram logo e.g. in the form of an Instagram camera. Information about Instagram plugins and what they look like can be found here
http://blog.instagram.com/post/36222022872/introducing-instagram-badges
When you link to a page on our website that contains such a plugin, your browser will establish a direct connection to Instagram’s servers. Plugins transmit their Instagram content directly to your browser and integrate it with the web page. Through this integration, Instagram receives information that your browser has called up the relevant page from our website, even if you do not have an Instagram account or if you are not currently logged in to Instagram. This information (including your IP address) is transmitted from your browser directly to an Instagram server in the United States and stored there.
If you are logged in to Instagram, then Instagram can link your visit to our website directly to your Instagram account. When you interact with plugins, such as activating the Instagram button, this information is also transmitted directly to an Instagram server and stored there. Besides, the information is published in your Instagram account and displayed there to your contacts.
Information about the purpose and scope of this data collection and the further processing and use of this data by Instagram, as well as your respective rights and configuration options to protect your privacy, can be found in Instagram’s privacy policy:
https://help.instagram.com/155833707900388/
If you do not want Instagram to link the data collected through our website directly to your Instagram account, you must sign out of Instagram before visiting our website. You can also completely prevent the loading of Instagram plugins with Add-Ons for your browser.
Legal basis for the processing of personal data when using plugins is Art. 6 paragraph 1 para. 1 (b) or (f) of the GDPR.
Technical protection measures
We make every effort to protect our customers, as well as the subscribers of our e-newsletters, from unauthorized access or unauthorized alteration, disclosure or destruction of their data. To this end, we take some technical and organizational measures, such as:
We use secure websites through which we collect your data;
We collect your data by confirming in two steps (entering data on our website and confirming the subscription, respectively your personal data, via a link sent to the email address specified by you);
We review our practices for the collection, storage and processing of personal data, including physical security measures, to prevent unauthorized access to the systems we use;
Access to your data within our organization has only persons whose job functions require access to the data to carry out the activities for which the data were collected; the data are processed or transmitted to third parties to whom you are informed and who adhere to the highest standards of information security and personal data security, demonstrated both by the availability of appropriate certifications and by the ability to perform regular audits of compliance;
We include contractual confidentiality clauses in all contracts we enter into with employees and third parties to whom we assign the processing of your data;
Contact us
If you wish to contact us about the way we use your Personal Data, or wish to exercise your rights related to the privacy of Personal Data, write to us at: info@beluga.software or at the following physical address:
Beluga IT Ltd
Tsar Simeon Street №280
Sofia, PC: 1000
To receive a response as soon as possible, we expect you to provide us with the following information:
1) Name of the website to which your question relates;
2) What is your relationship with us and how did you interact with us;
3) Description of the information you would like to receive from us.
The privacy policy was adopted by a decision of the General Meeting of Beluga IT Ltd and will enter into force on 21.12.2020
