GeneralPlease first read Terms & conditions as it defines terminology used on this page and also governs your use of this website and the products and services offered by us.
We are committed to respecting and protecting the privacy of our visitors and clients, and we comply with the:
- Privacy and Electronic Communications Regulations 2003 (PECR),
- General Data Protection Regulation (GDPR 2016).
For any questions on the topics, please contact us.
Date edited: April 28, 2020.
Effective date: April 28, 2020.
Changing this policyWe may decide to change the policy and any change will be posted on the website along with date of posting and date the changes become effective.
The data controllerWe, Promo Partners, are the sole entity that will collect, process and store any personal data with respect of your interaction with our products or services.
The company is registered as personal data administrator under the Bulgarian law.
Who is operating with personal dataOnly persons under direct work contract relationship with us have access to personal data. We do not share personal data with persons or entities, under any form.
The only exception may be a rightful request by authorities. Such requests will be validated and answered in the exact limits corresponding to each request.
What personal data do we collect and whyWe collect personal data in the following ways:
- when you contact us and leave your details so we can contact you back;
- when you express interest in an upcoming product or service and leave some means to be contacted;
- when you purchase a product or service through a third part channel - the third party sends us data so we could identify you and deliver to you what you paid for, and (if applicable) to be able to further identify you for support purposes;
- when we enter in direct negotiations with you.
What personal data we do not collectWe do not collect any of the following, on the website or through any of our products and services:
- behavioral information;
- any marketing, remarketing or advertisement data;
- any payment details like credit card numbers or bank details (unless part of a signed contract).
Personal data collected by our mobile applicationsOur publicly available mobile applications:
- do not collect, store or process any personal, statistical, marketing or other data and/or information;
- do not transmit, save or export any information, personal or not, to any location or device or recipient without an explicit command from the user and as a part of the obvious functionally provided by the application and used by the user;
- absolutely respect your privacy and in no way try to breach or compromise it or facilitate such actions - what happens on your device stays on your device.
Legal basis for collecting your personal dataOur legal basis for collecting your personal data is one of the following:
- you contacted us and we’re expected to reach you back to answer your question or request;
- you have voluntarily entered with a contract with us (signed contract or simple purchase of a product or service).
Where do we store personal dataPersonal data is stored in accordance to the rules and procedures we are obliged to follow under our registration as personal data administrator under the Bulgarian law.
We store personal data in premises under our control and implementing access restriction procedures.
Due to the nature of the online business, some personal data may be stored online, on virtual or physical servers that we rent from third parties and to the data on which only we have access.
How long do we keep personal dataWe do not keep personal data longer than it’s necessary to fulfill the obligation we have to you.
Only exceptions is when the minimum retention period is defined by the law.
When we are allowed and it is allowed by the law, we’ll delete or anonymize personal data.
Your rightsUnder the law you have the following rights:
- right to know what personal data we have about you - we’ll send you all the data that we have for you, including the source of each record, free of charge;
- right to ask to correct any personal data we have about you;
- right to ask us to stop part or all processing of your data - like notifications, updates, etc.;
- right to ask us to delete all your personal data - this may lead to our inability to further provide you services.
CookiesThere are only 3 types of cookies used our website:
1. Session cookieThis is a simple string (that our website asks your browser to store on your hard disk and send to the website with each new request/click) identifying the immediate interactions between your browser and the website server and making possible simple features like logging into a password protected area.
This cookie becomes invalid when you close the browser window/tab that was accessing our website.
2. Messages cookieThis is a simple string (that works the same way as the session cookie) and it simply tells the website that you have already seen messages like “This website is using cookies…” so we don’t bother you with the same message after a new page is shown.
This cookie is valid for a couple of months.
3. Google Analytics cookie(s)We use Google Analytics to track and measure the website usage as well as to identify potential problems and improvement opportunities for the website.
Google Analytics is a tracking service - when operating normally it makes, for example, a list of the pages you visit.
More information you can find on the following link: https://www.cookiebot.com/en/google-analytics-gdpr/ (opens in a new window) or just search for more information on “Google Analytics cookies”.
We have taken all measures to make our usage of Google Analytics as anonymous for you as possible.