SPE1.2.0.0

PRIVACY POLICY Black Screen Project


FDM


I. Introduction


1.1. Gatelink Ltd. Bulgaria, registered under company number 205513382 in Company Register of Republic of Bulgaria (“Company” or “We”) has developed the website gatelink.bg (“Website”) in order to provide online information about and/or access to its services. Some of the services provided through the Website require a client or visitor to submit personal data such as name, address, e-mail address and/or telephone number. In some occasions we require personal data, but such is provided only on contract based relations and in strict adherence to the local and European legislation. Please read carefully the following privacy policy (“Privacy policy”) to understand how our Company handles the processing of data of clients and visitors of this Website.

1.2. We are committed to safeguarding the privacy of visitors to our Website and to the privacy of our clients that access our web-based services. Therefore all personal data will be processed in accordance with the data protection principles and rules set out in the EU legislation (Personal Data Protection Directive 95/46/EC, E-Privacy Directive 2002/58 as amended by Directive 2009/136, etc.) and in accordance with the provisions of the Local legislation in the Republic of Bulgaria, that regulates the processing and protection of personal data.

1.3. The information provided applies only to the Website and does not concern any web sites that may be visited by any user via external links published on the Website.

1.4. This Privacy Policy only applies to services offered by the Website.

II. Data controller


2.1. The company is the data controller for the personal data of all individuals using the Website and Company’s web-based services. If you have any questions in relation to this policy please contact us at: legal@gatelink.bg

III. Purpose of the processing


3.1. The Company will only use the information you provide to it by using the Website in order to identify the client in order to justify whether they are entitled to the chosen service and promptly perform the client’s request.

3.2. No personal data resulting from the access to the Website or the web-based service is either communicated or disseminated to third parties. We will only disclose your information where you have given your consent or where we are required to so by law, or where it is necessary for the purpose of, or in connection with legal proceedings or in order to exercise or defend legal rights.

IV. Categories of processed personal data


4.1. In order to perform a request for a service we will need to process the following personal data you provide us by using the Website: name, address, e-mail address and/or telephone number. Sending e-mail messages containing your personal data to this Website is therefore based on your free, explicit, and voluntary consent to do so.

4.2. When you visit this Website, information systems and software procedures relied upon to operate it might acquire personal data as part of their standard functioning. This data category might include your IP addresses and/or the domain names of the computers used by any user connection with the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user’s operating system and computer environment.

4.3. Such information is not collected in order to relate it to identified data subjects, and is only used to extract anonymous statistics on Website use as well as to check its functioning; the data entries are erased immediately after being processed. The data might be used to establish liability in case computer crimes are committed against the Website; except for this circumstance, any data on the web contacts is currently retained for no longer that 7 (seven) days.

V. Cookies


5.1. By default and unless specifically agreed to, the Company does not place any cookies on your computer or mobile device. No personal data concerning users is acquired by the Website in this regard.

5.2. No cookies are used to transmit personal information, nor are so-called persistent cookies or user tracking systems implemented.

5.3. Use of the so-called session cookies – which are not stored permanently on the user’s computer and disappear upon closing the browser – might be enabled after acquiring the user’s consent, and shall be exclusively limited to the transmission of session ID’s – consisting of server generated casual numbers – as necessary to allow secure, effective navigation.

5.4. These so-called session cookies that might be used by this Website with the user’s consent make it unnecessary to implement other computer techniques that are potentially detrimental to the confidentiality of user navigation, whilst they do not allow acquiring the user’s personal identification data.

VI. Information security


6.1. Specific security measures are implemented to prevent the data from being lost, used unlawfully and/or inappropriately and accessed without authorization.

6.2. The Company employs and/or works with teams of leading experts in data security globally to protect the Website and its users from unauthorized access to, or malicious alteration, disclosure or destruction of personal information under our control.

6.3. Personal data is processed for no longer that is necessary to achieve the purposes for which it has been collected.

In particular:

VII. Data protection rights


7.1. All individuals that have access to and use the services available at the Website are entitled at any time to be informed of the type and origin of personal data we hold on them, verify their accuracy, or else request that such data be supplemented, updated, blocked from being visible or rectified. You are also entitled to request erasure, anonymisation or blocking of any data that is processed in breach of the law as well as to object in all cases, on legitimate grounds, to processing of the data. All requests should be emailed to: legal@gatelink.bg.

VIII. Compliance and Cooperation


8.1. The present Privacy Policy has been created in compliance with the relevant EU privacy and personal data protection legislation and the relevant data protection legislation in the Republic of Bulgaria. Upon receiving a formal written notice from an individual, we will strive to get in touch to resolve the issue concerned. If a plausible outcome could not be achieved directly with the individual, we will support the work of the appropriate regulatory authorities, including national data protection authorities, to resolve any complaints regarding the processing of personal data. To provide the best possible protection for the individuals, the Company will implement on regular basis the practical guides and opinions issued by relevant EU bodies and national data protection authorities.

IX. Amendments to the privacy policy


9.1. The Company reserves the right to amend at any time this Privacy Policy in order to incorporate any relevant changes in the rules and regulations affecting the privacy rights of the individuals. This page will always contain the latest version of our Privacy Policy.

X. Definitions


10.1. For the purposes of the present Privacy Policy visitor shall mean: any individual browsing through the Website without submitting any particular request for a service.

10.2. For the purposes of the present Privacy Policy client shall mean: any individual using the Website to submit a particular request for a service.

February 17 2021, Gatelink Ltd. Bulgaria