Privacy Policy
Policy for protection, confidentiality and privacy of personal data on www.goemotion.eu
I. INTRODUCTION
On May 25, 2018, the General Data Protection Regulation (GDPR) came into effect in all EU member states. It is directly applicable in Bulgaria like any national law and covers the rights and obligations of controllers, processors and data subjects; some of the details are additionally regulated by the Bulgarian Personal Data Protection Act. All visitors to our website are data subjects and have various rights in this regard. This policy aims to inform you about the principles of protection and the personal data of visitors to our site, about our obligations as a data controller and about the measures we have taken to prevent your data from being used without you knowing by whom and for what purposes or without you having the opportunity to object or withdraw your consent to their processing.
The policy will not remain the same for the entire time our website exists; As digitalization progresses and the regulation of relationships related to the processing of personal data evolves, we will strive to constantly improve and adapt our practices to this development, which in turn will be reflected in the policy. Our intention is to publish a short message in the “news” section of www.goemotion.eu with the most important highlights each time we make a change to the policy for the protection, confidentiality and inviolability of personal data (“Policy” or “this policy”).
• This policy covers all activities related to the processing of personal data within the framework of digital assets – property of “GREEN E-MOTION” OOD is a company registered under the Commercial Code of the Republic of Bulgaria with UIC 206783092, with its registered office and management address in Varna, 28 Hristo Popovich Street, email address telephone +359897999425, hereinafter referred to as GO e-motion;
• in case of any ambiguities related to the application of this policy or the exercise of your rights, you can contact us at E-mail: office@goemotion.eu or at the above address: city of Varna, ul. “Hristo Popovich” № 28.
II. SOME TERMS OF IMPORTANCE FOR A BETTER UNDERSTANDING OF THIS POLICY
“Personal data” – this is any information that relates to you – the visitor/user of our website and which alone or in combination with other information can help us to establish your identity or to link your user behavior to a specific device from which you access our website, for example.
“Personal data subject” – this is you, the visitor of our site. What is written in this policy applies only to people, natural persons, unless otherwise expressly stated.
“Processing of personal data” – this is any action that we perform or may perform with your personal data, including, but not limited to, their collection, analysis or destruction.
“Administrator of personal data” – in relation to our website, this is us, GO e-motion – “GREEN E-MOTION” Ltd. We determine the purpose of the processing of your data, on one of the grounds provided for by law; in general, we also determine the means by which this processing is carried out – for example, the technical infrastructure and applications with which the processing is carried out. Obligations regarding the security and protection of your personal data arise for us. For some processing of personal data, we may act jointly with another administrator.
“Joint administrators” – administrators who jointly determine the purposes and means of the processing. This may be an agency for implementing GO e-motion’s marketing strategies, with whom we jointly determine the purposes and means for this.
“Personal data processor” – this is GO e-motion or a third party that processes your personal data on our behalf, where GO e-motion has strictly defined the purpose of the processing, the means by which it occurs and has verified whether the person meets the requirements of the GDPR. Such a processor could be, for example, an agency that is responsible for a GO e-motion marketing campaign on a social network and creates reports on its success.
A “cookie” is a small amount of text or data that is sent to your device (computer, laptop, tablet, phone) for storage and can be requested back from the domain from which they are “attached” to the device. The function of a cookie can be very diverse: from keeping you “logged in” while you fill out a certain registration form, to remembering your language preferences for browsing our website, to tracking your browsing behavior on the Internet, sometimes for an extended period of time and regardless of the device used: in the latter case, as in all other similar cases, such a cookie cannot be used without your prior consent based on detailed information received.
GDPR introduces or strengthens significant legal mechanisms for the benefit of data subjects. Below we have listed some of them that are relevant to the processing of personal data in connection with the use of digital assets.
“Digital assets” – the website www.goemotion.eu and the Facebook page of GO e-motion; the website consists of two sections – in one you can find corporate information about GO e-motion and information about the products offered there, and the other section is an online store from which the visitor can remotely purchase products offered in the GO e-motion online store.
“User session” – The time between the user’s authorization and the moment of its exit or expiration due to inactivity. During this time, the GO e-motion system uniquely recognizes the client.
“Plug-in” – third-party software implemented in a GO e-motion digital asset and related to tracking user behavior and/or ensuring the operation of a certain functionality by switching to the third party’s domain.
“Information Society Services” are services that are usually provided for a fee and at a distance through the use of electronic means. The recipient of such a service must have explicitly requested it. E-commerce is also a type of such service.
III. COLLECTION AND USE OF PERSONAL DATA
GO e-motion strives to protect the privacy and guarantee the security of the personal data of visitors and users of its digital assets. When you visit our website, the web servers of third parties that we have allowed on our site (for example, Google) will temporarily store data about the connection of your device to our website, as well as the pages you have visited on our site, identification data about the type of your browser and operating system, as well as about the website from which you were referred to www.goemotion.eu. We do not collect or process other personal data about you – for example, your name, address, telephone number or e-mail address, unless you provide them in connection with your specific information request, when filling out a registration form for applying for a job or for a given service or in order to create an account in our online store or apply for a GO e-motion club card. By creating an account, you receive additional conveniences when shopping online, which requires registration on our website and an access password for the purpose of easier identification and protection of your personal data.
Before your personal data is processed through the website, we will notify you of this in accordance with the requirements of Art. 13 of the GDPR. Thus, when processing occurs, you will know who the controller is, on what grounds and for what purposes they process your data, how they store it, etc.
IV. FOR WHAT PURPOSES AND ON WHAT BASIS DO WE USE YOUR PERSONAL INFORMATION
1. Processing purposes
GO e-motion collects and uses your personal data through the website for the following purposes:
• Providing services requested by you
Almost all personal data that you fill in the registration forms or your profile are necessary to respond to your need or a service requested by you that GO e-motion provides. In order to provide our services online and offline in a quality manner, we need your identification data, the scope of which varies depending on the type of service requested and the legal requirements applicable to it.
In many cases, you use the registration forms prepared by us to ask a clarifying question in relation to the services provided, to express dissatisfaction or satisfaction, to file a complaint, grievance or claim.
• Selection of employees who have applied for job advertisements
We offer a convenient opportunity through our website to familiarize yourself with advertised job positions at GO e-motion and to apply for an advertisement of your choice. Thus, through the website you can submit your documents, and for the purposes of the selection we will identify you and process the information you have sent and your personal data.
• Marketing activity
The personal data provided by you for the purposes of creating a profile for using the e-shop, for example, as well as in other registration forms, may be used to inform you about new services provided by GO e-motion, available discounts on existing services or some service facilities that we have created for you. The messages we send will be in accordance with the applicable Bulgarian and EU legislation.
In order to offer you discounts and promotional products, we also process your data when issuing a club card in the course of the GO e-motion Loyalty Program and when you make a request for consultation via the website.
You can also express your desire to subscribe to our newsletter on our website by providing us with your email address.
You can object in an easy and convenient way to the use of your data for marketing when the basis for processing is legitimate interest, and we will terminate it immediately; information on how to withdraw consent once given or object when receiving an unwanted marketing message will always be placed prominently in the message.
For the purposes of marketing activities, we perform traffic analysis and tracking of user behavior on the website through codes from third-party domains, in which we process your personal data using cookies. You can read more about them in Section VI of this policy.
2. Grounds for processing
When we process personal data for the purposes of providing services that you have requested via our website, we most often process your personal data on a contractual basis pursuant to Art. 6, paragraph 1, letter “b” of the GDPR. When you contact us via our contact form, the basis on which we process your data is the consent you provide to us – Art. 6, paragraph 1, letter “a” of the GDPR.
In case you apply for a position advertised by GO e-motion via the website, we collect the data for the purposes of the selection on the basis of your consent provided for this in accordance with Art. 6, paragraph 1, letter “a” of the GDPR.
For the purposes of marketing activities, we process your personal data because we have a legitimate interest within the meaning of Art. 6, paragraph 1, letter “f” of the GDPR or because you have provided us with your consent for this on the basis of Art. 6, paragraph 1, letter “a” of the GDPR.
V. WHAT TYPES OF PERSONAL DATA DO WE PROCESS
1. When providing services requested by you
• To purchase products from our online store – name, surname, phone number, city, postal code, address and e-mail address;
• In case you choose the option for online payment for the product, we do not process the data for the transaction, but only refer you to the secure environment of the payment system (“Borika”).
• To contact us – the contact form requires you to provide us with your name and e-mail address in order to identify you and be able to respond to your inquiry, request, etc.
2. When applying for a job advertisement
When you apply for a job advertisement in GO e-motion, you provide us with the following data: names, data about your education, qualifications, professional experience, motivation, etc., included in your CV or cover letter.
3. When carrying out marketing activities
• To apply for a card from the GO e-motion Club loyalty program and card verification – name, surname, phone number, city, postal code, address and e-mail address, date of birth, gender. When verifying your card via the website, you need to be a registered user of GO e-motion in the mobile application.
• To subscribe to our newsletter, you voluntarily provide us with your e-mail address, to which we send you news.
• For the purposes of marketing activities, we also use cookies, and you can learn more about your personal data processed through them from our Cookie Policy.
VII. DISCLOSURE OF YOUR PERSONAL DATA
In order to be fully informed about which third parties and for what purpose may gain access to your personal data collected in connection with your visit/use of our website, we ask you to familiarize yourself with the following.
Recipients of your personal data are agencies for conducting GO e-motion marketing campaigns. These companies receive your data when setting cookie settings and conducting other marketing activities related to our website and our Facebook page.
Processors of your personal data are also all third parties that attach codes and cookies to your device when you visit our website, such as Google and Facebook.
Personal data processors and in this capacity recipients may be companies that provide web hosting for our website.
Recipients of your personal data for marketing purposes may be companies that conduct e-mail marketing by sending you advertising e-mail messages and attaching codes when you open them.
Companies that provide IT support to our information systems, in which we store your data submitted through the website, may also have access to your personal data. Their access to the data in the systems is intended to ensure the normal and secure functioning of the systems, and thus the protection of the data processed.
VIII. PROTECTION OF PERSONAL DATA
GO e-motion takes precautions, including administrative, technical and physical measures, to protect your personal information from loss, theft and misuse, as well as from unauthorized access, disclosure, alteration or destruction.
All employees of GO e-motion are obliged to protect the confidentiality of your information, as well as to comply with the applicable organizational and technical protection measures. Access to your data is limited to the principle of necessity for the performance of the duties of the relevant employee/contractor accessing it.
IX. STORAGE OF PERSONAL DATA
Personal data obtained through the forms on the website are stored in our information system, for the functioning of which technical and organizational security measures have been taken, including the use of a separate high-end server with limited access, on which only this website is located; use of an encrypted connection to access the server; use of SSL and DDoS protection, HTTP/2, “smart” Firewall and fail2ban.
Personal data collected through cookies are kept for the periods specified in the cookie table above.
CVs, photos and contact details sent through the website are collected with your consent and are subject to strict confidentiality; data for candidates who are not selected to conclude a contract with GO e-motion are destroyed immediately after the selection procedure is completed, but not more than 6 months; data for successful job candidates become part of their employment files.
X. YOUR RIGHTS AS A SUBJECT OF PERSONAL DATA
1. Right to information
You have the right to receive information about important characteristics of the processing of your personal data, including, but not limited to its purpose, term and basis, about the recipients and categories of recipients of personal data and others. Depending on the way in which the information was initially collected, we will display the most important information in this regard in an appropriate and easily visible manner each time.
2. Right of access
You have the right to access your personal data collected directly by GO e-motion by logging into your GO e-motion account or by contacting us at the following e-mail address: office@goemotion.eu
3. Right to portability
We are obliged to provide you with all personal data processed by us, provided to us in order to provide a service at your request or collected from you with your consent, upon request, in a machine-readable format. The request should be made by sending an inquiry to us at the following e-mail address: office@goemotion.eu. When you make a request for portability, we must comply with it within 20 business days of receiving it via the electronic communication channel specified by you. The deadline may not be exactly 20 business days when the cookies through which your personal data are processed are set by external domains with your consent; in our response to your request to exercise the right to portability, we will indicate the deadline within which we will be able to comply with your request.
If you so wish, we may forward the file to another online store. In the event that requests are made to us by the same data subject more than twice a year, we may charge a fee for this service in a reasonably justified amount.
4. Right to rectification
You have the right to request that we correct incorrectly recorded or stored personal data about you that you have provided to us through our website and we must do so within 15 business days of receiving your request. You can send your request to us by email: office@goemotion.eu
5. Right to request restriction of processing of your personal data
You have the right to request that we temporarily suspend the processing of your personal data (without erasure) in the event of your objection to specific processing or in the event of legal claims or a complaint filed by you with the Personal Data Protection Commission. You can address the request to us by email: office@goemotion.eu
6. Processing based on the legitimate interest of GO e-motion or a third party and objection to such processing
When your consent has not been requested and given for the purposes of specific processing, or it is not directly necessary for the performance of a service requested by you, we most likely have a legitimate interest of ours or a third party, which we have assessed will not harm or would only slightly affect your right to privacy of personal data. Such an assessment will always be documented by us and will follow certain criteria and reasoning. You have the right to familiarize yourself with the main points of it upon request, as well as to raise an objection that, given the peculiarities of your specific situation, the relevant processing affects your right to privacy and/or protection of personal data in a more significant way than provided for in the justification. In such cases, we must consider your objection and issue a reasoned opinion on its acceptance or rejection within 20 working days. By submitting an objection to this processing, you can also exercise your right under point 5 above. You can address the objection to us by email: office@goemotion.eu
7. Withdrawing your consent
In cases where we have requested your consent for a given processing of your personal data, you can always withdraw it. If you are not sure on what basis we process your personal data, you can always ask us about this, as well as about the exact way in which you gave your consent – you can send your inquiry to us at office@goemotion.eu. We will respond to you within 15 business days. We maintain an up-to-date database of consents for the processing of personal data, which we can consult at any time. The withdrawal of consent is done in the same way as you gave it and we will provide you with information or an email where you can do this easily and conveniently in the response to your inquiry.
8. Right to complain to the Personal Data Protection Commission
Whenever you consider that your rights under the GDPR have been violated, you can file a complaint with the Personal Data Protection Commission. However, it could be very constructive if you first contact us at the e-mail address office@goemotion.eu to discuss the issue. We are obliged to respond to you within 15 working days of receiving your complaint or question.
EXERCISE OF RIGHTS IN RELATION TO PERSONAL DATA
To submit a request regarding the rights of a personal data subject at www.goemotion.eu,
Fill out and send a specific request to office@goemotion.eu
