May 25th 2018
constitutes the confidentiality statement of the company named Baris Software Ltd., based in Tsar Boris III-th 39, 2850 Petrich, Blagoevgrad,
Bulgaria, hereinafter referred to as " COMPANY".
Contact with the company
A place of contact with the COMPANY, for any purpose, is the
headquarters of the COMPANY headquarters and / or
This information is addressed to natural persons who visit our
website or conduct any transaction with the COMPANY, such as, for
example: to clients who have a permanent relationship with the COMPANY
or by passing and / or prospective clients, to the legal representatives
on a case-by-case basis and / and their representatives and their
special or universal successors, representatives of legal persons,
suppliers and their representatives, and generally any natural person
who, in any capacity, has a deal As communication with the company.
sharing and processing of your personal information by COMPANY,
its subsidiaries and affiliates, in connection with the use of COMPANY's
website, electronic applications for PCs and mobile devices, social
with the Company, such as, for example, during personal meetings
or in EDF events Or under other sales and marketing activities.
of your personal data by COMPANY and your rights as a subject of
processing. It also describes the options we provide for accessing,
updating, or controlling your personal information, and explains
the options that you have with these editing activities.
The processing of personal data consists in collecting, registering,
organizing, structuring, storing, changing, retrieving, retrieving,
using, transmitting, restricting or deleting personal data that
have come to or come to the attention of the COMPANY either within
the of any kind of relationship with you or in the context of information
received by COMPANY by a third party, natural or legal person or
public sector entity in the exercise of your legal right or the
COMPANY itself. When you visit our sites, you have the ability to
connect to sites, services, social networks, applications or other
non-COMPANY features. Activating these features will lead to other
parts of the internet where COMPANY has no control over the characteristics
of these other parties.
We encourage you to review these parties' privacy policies before
using these features.
Who is responsible for processing the data?
THE COMPANY acts as a "Process Manager" and in cases such as
"Performing Processing" of personal data under the General Data
Protection Regulation (EU) 2016/679, hereafter referred to as the
"EPC", of the European Parliament and of the Council of 27 April
2016 on the protection of individuals with regard to the processing
of personal data and on the free movement of such data and repealing
Directive 95/46 / EC.
Which personal data we process and where we collect it
The Company processes your personal data that is provided by
you and comes from our relationships, such as: during personal meetings,
interviews, participation in events, conferences, workshops or meetings,
data you have submitted or are about to to submit to you or your
legal representatives all necessary for the initiation, maintenance
and execution of all your transactions with the Company, existing
or future, depending on the product or service provided and each
ote current procedures and policies.
Your personal data that you provide to COMPANY must be complete
and accurate and up-to-date with your care, in every case of change
or whenever deemed necessary by COMPANY to maintain our relations
or to fulfill a COMPANY's obligation resulting from the law and
the applicable regulations.
THE COMPANY also processes personal data which it receives or
comes to know from a third party, whether natural or legal or public,
and which is necessary either for the achievement of the legitimate
interests of the COMPANY or of a third party itself or for the performance
of duties (eg Tax and Insurance Institutions).
COMPANY may also process personal data you collect from third-party
publicly accessible sources (eg, General Secretariat of Information
Systems, Commercial Registers, Internet) if such data are necessary
for processing purposes.
For the conclusion of a service agreement, it is necessary to
complete the "Project Application", where COMPANY collects and processes
the following minimum personal data: Tax and contact information,
such as mailing address, e-mail address, telephone (fixed and /
or mobile), address of your website as well as signature (physical
or electronic signature).
Additional information may be requested on a case-by-case basis
if such information is a prerequisite for starting or maintaining
a particular service. Depending on the product or service provided
by the COMPANY, COMPANY may collect and further process the following
data, as an indication but not limited to: financial data (eg tax
returns, tax returns, ENFA), insurance policies as well as additional
information in the context of the application of the applicable
provisions and obligations of the COMPANY.
Your objection to the provision or processing of your personal
data may lead to the inability to start or continue your cooperation
with the COMPANY (eg refusal to process and use the e-mail address
makes it impossible to use or continue providing our services through
the COMPANY website, refusal to process and use the mobile number
makes it impossible to provide your information service through
short SMS messages for matters that concern you directly).
Why and how we use your personal information
We use your personal data for the following purposes:
- When communicating to answer your inquiries and questions
- If you contact us (such as submitting a request to contact
our sites, your participation in company events or other occasions,
sending an e-mail, by telephone, by visiting your social networking
platforms), we process information about you to contact you
and respond to your requests.
- When you ask for technical advice, or contact us by phone
or to conduct a transaction you have requested, we will ask
you questions about your personal information whenever we need
information for identification purposes. The personal information
we collect and process may include a name, title, company or
organization, working email, working phone, work address or
home, information about your job, information about your company.
- We can also process personal information to interact with
you through social networks.
- For the functionality of our web sites and for their technical
and functional management
- When you choose to sign up for a service through our sites,
we need to process the personal information you provide to create
and manage a personal account for you. This personal information
allows us to manage your account, for example changing your
password or correcting personal information when you request
- To conclude and manage contracts for the sale of goods or
- To promote our products and services and tailor your marketing
and sales activities to suit your interests.
- THE COMPANY can use information about you to inform
you about new product releases and service developments,
events, notifications, updates, prices, terms, special offers
and related campaigns and promotions (including newsletters).
- THE COMPANY may also use personal information to inform
its affiliates, distributors, or resellers of products or
services that you have expressed your interest in.
- If you are attending an event, COMPANY must process the
information gathered in relation to the event and share information
about your participation in the event
- The COMPANY can also allow designated event partners
or conference sponsors to send you up to two announcements
about your participation in the event.
- Please note that our associates or conference sponsors
can promptly request information about you in conference
rooms or presentations, and the use of the information you
provide them will be subject to their own privacy policies.
- We may also process your personal information to post your
opinion of our services on our sites, but after we have received
your positive consent for that purpose.
- For our transactions with customers, suppliers and affiliates
processing orders for products and services of the COMPANY
- If you request any of our products or services, or if you
provide products or services to COMPANY, our employees, our
customers or our partners as a supplier or business partner,
COMPANY processes information about you for the involvement
and management of related transactions such as invoices and
payments, or assistance and assistance to complete the order.
- To analyze, develop, improve and optimize the use, functionality
and performance of our site (s), our products and services.
- We can process personal information to analyze, develop,
improve and optimize the use, functionality and performance
of our sites, products and services as well as our marketing
and sales campaigns.
- In the event that our sites allow you to engage in interactive
discussions, create profiles, post comments, opportunities or
other content, or communicate directly with another user or
participate in networking activities, COMPANY may process personal
data during review of these activities.
- To manage the security of our sites, networks, and systems.
- We can also process personal information to monitor the
performance and operation of our business, such as conducting
internal audits and investigations, or for purposes of financial
and accounting archiving and insurance.
Processing special categories of personal data
COMPANY does not process personal data unless:
- You have explicitly given your consent to this for a specific
- These data have been disclosed to the COMPANY by you or
a third natural or legal person as part of the documentation
and safeguarding of your legal interests and / or the COMPANY
as a controller (eg information about the position of the person
in legal aid).
- Processing is necessary to protect your vital interests
or other natural person.
- The data is clearly made public by you.
- Processing is necessary to establish, exercise or support
both your own legal claims and the COMPANY as a controller.
- Processing is necessary for reasons of substantial public
interest such as the investigation of a criminal offense under
the Law on the Prevention and Suppression of Money Laundering
and Terrorist Financing.
THE COMPANY has in any case taken
all reasonable technical and organizational measures for the safe
keeping and processing of your personal data belonging to the above
Data relating to minors
All of our services are aimed at adults. COMPANY focuses on serving
business needs, our websites are not targeted at minors, and COMPANY
does not promote or market its services to minors.
If you believe that we have collected a person's inaccurate or
unintentional personal information without proper consent, please
let us know so we can immediately delete this information and make
any other necessary corrections.
Baris Software Ltd. is a site with a non-specialized audience
and does not deliberately collect any personal items from children.
It is forbidden to send data to Baris Software Ltd. through
this site from people considered minor by local legal authorities.
If you are NOT an adult or you are younger than your legal age in
your country, you should consult your parents or guardians before
sending any information to Baris Software Ltd., except for these
actions to are permitted by law in your country.
How do we secure your personal data?
THE COMPANY, in compliance with the current legislative framework,
has taken the necessary actions by reasonably applying technical
and organizational measures for the lawful maintenance, processing
and safe storage of the personal data file, committed to ensuring
and protecting in any way the processing of the your personal data
from loss or leakage, alteration, transmission, or otherwise fraudulent
What is the legal basis for processing your personal data
THE COMPANY is lawfully processing personal data as processing
a) is necessary to serve, support and monitor your transactions
with the COMPANY and the proper performance of our contracts and
insurance mediation; b) it is necessary for the COMPANY's compliance
with its legal obligation or for the pursuit of its legal interests
arising out of your relations with the Company or other rights deriving
from the law; c) it is necessary for the fulfillment of a duty ithin
the operated in the public interest under the relevant existing
legislative and regulatory framework and d) based on your prior
express consent if the treatment is not based on any of the above
mentioned legal processing bases.
In particular, but not limited to:
- In order to communicate with you and respond adequately
to your requests, we need to process information about you and
therefore we have a legal obligation to process this information.
- In order to service, support and monitor transactions with
customers, suppliers and affiliates and to execute your orders
for purchases of our products and services, we must process
information about you as necessary to enter into or execute
a contract with us.
- We process personal information about marketing and sales
activities based on your consent when this is stated at the
time your personal information was collected or alongside our
legitimate interest in promoting our products and services
- We rely on the legal obligation to analyze, develop, improve
and optimize our sites, products and services and to maintain
the safety of our websites, networks and systems.
- We process personal information when processing is necessary
for the fulfillment of a COMPANY duty performed in the public
interest under the applicable legal and regulatory framework,
such as compliance with a summons or other legal process or
service of requests for withdrawal of your consent. submit to
- We process personal information during your visit to the
COMPANY premises, if we have your positive consent.
Withdrawal of consent
You have the right to withdraw in writing at any time your consent,
as required and given without prejudice to the lawfulness of the
processing based on it, up to the day of its revocation.
The withdrawal of your consent may be filed in writing at the
registered office of the COMPANY's headquarters or at the email
address mentioned under "Contacting the Company".
The processing of your personal data concerns:
- The service, support and monitoring of your relations with
the Company, the proper execution of the contracts between us,
the consideration of requests for the provision of products
and services of the COMPANY, the fulfillment of the obligations
of the COMPANY as responsible or carrying out the processing
and the exercise of the legal and its contractual rights.
- Performing audits provided by the current legislative and
- The registration, recording and filing of all your orders
to COMPANY, which are provided either in writing, either electronically
or by telephone, for the preparation of contracts, the provision
of information, our communication and our active assistance
in providing advice and services.
- Upgrading the products and services provided by the COMPANY
and promoting the products and services of the COMPANY and the
companies cooperating with the COMPANY, subject to your prior
- The satisfaction of all kinds of requests addressed to the
COMPANY or the examination of your complaints regarding the
products and services offered by the COMPANY.
- The fulfillment of legal obligations of the COMPANY arising
from the current legislative and regulatory framework (eg anti-terrorism
legislation, tax and insurance provisions).
- Defending the legal interests of the COMPANY which are indicative
of: a) the claim of its legal claims before the competent judicial
authorities or other bodies of extrajudicial or alternative
dispute resolution; b) the prevention of fraud and other criminal
prosecution; c) and optimization of security procedures and
information systems, d) management of operational and / or credit
risks of the COMPANY, e) physical security and protection of
persons and property (eg video surveillance).
- During your visit to COMPANY's premises, receiving, processing
and maintaining your identity data and your time at the COMPANY's
premises is done to meet the sole purpose of protecting and
protecting both the persons who are located (eg employees, visitors)
and of the Company's equipment (for example, building, electronic,
Automated decision making and profile training
THE COMPANY does not make decisions based solely on automated
procedures for the processing of personal data.
However, it may lawfully take such decisions, including profiling,
for the purpose of monitoring and preventing fraud against the COMPANY
or third party and for the safeguarding and reliability of the services
provided by COMPANY, or where such processing is necessary for the
conclusion or performance of a contract based on personal data obtained
directly from you or from a search in the database of public bodies.
Data retention time
The information we collect for the conclusion of contracts with
our customers, suppliers and associates will be retained for the
entire duration of the transaction or for the periods of service
and for as long as possible, from the applicable legal and regulatory
framework and in any case for a period of twenty (20) years from
the last calendar day of the year of your respective transaction
with the COMPANY.
In the event that any request for your cooperation with the COMPANY
is not accepted and the contract is not completed the data will
be kept for a period of five (5) years.
In the event of litigation, your personal data will be respected
in any case until the end of the lis pendens even if the above twenty
(20) years are exceeded.
If you are subscribed to our members' domains, COMPANY will retain
your account information as long as you maintain an active account.
Your accounts and account details will be deleted if you do not
log in for 24 consecutive months. COMPANY does not keep records
of this deletion.
If you have subscribed to receive newsletters, your registration
details will be retained as long as you are registered in our distribution
Contact details, such as your email address or phone number,
collected electronically or live by our interactions with you and
used for direct marketing and sales activities will be maintained
as long as you have an active relationship with the COMPANY.
An active relationship is defined as your contact with the
COMPANY or the correction and updating of your contact details and
preferences made by you or on your request in the last 24 months
and if you have not submitted a deletion request.
Any chat recorded information will be retained for 90 days after
the end of the conversation.
During your visit to the COMPANY premises and for the fulfillment
of the purpose of the processing that concerns the security and
protection of both the persons who are at COMPANY's premises (eg
employees, visitors) and of the Company's equipment in general (indicatively
building , e-mail, etc.), we consider reasonable and necessary time
to maintain your relevant data within 15 days (15) days.
After fifteen (15) days from your time of entry to the COMPANY
premises, the relevant envelope containing all your data is deleted.
The personal information required to exercise your rights and
record your preferences remains for 20 years and / or more if this
is necessary for our COMPANY compliance, in accordance with applicable
laws or regulations.
Who are the recipients of personal data?
Employees of the COMPANY are authorized to access personal information
only to the extent necessary to serve the applicable purposes and
the performance of their duties, as well as the respective auditors
of the COMPANY.
THE COMPANY does not transmit or disclose your personal data
to third parties unless it is:
- Associated enterprises as indicative:
- Companies providing services related to the professional
orientation of the COMPANY, in the context of servicing
the Company's professional relations.
- Businesses (internal and external) to which it has delegated,
in whole or in part, the execution of the processing of
your personal data on behalf of the company and which have
undertaken to confidentiality with the COMPANY either (a)
in the context of a contractual relationship, the purpose,
the duration of the processing, the type of personal data
processed and the rights of the COMPANY, or (b) in the context
of their statutory obligation to confidentiality such
- Transmission required for starting an employment
relationship or executing a contract or for collecting
the claims of the COMPANY in the event of non-performance
of your contractual obligations that you have entered
into with the COMPANY (eg forwarding to associate lawyers
, law firms and bailiffs, notaries, engineers and appraisers)
- Accountants and accountants to comply with the Company's
statutory obligations (eg payroll and taxation).
- Digitization and management (storage, destruction)
of physical records. Issuing and sending
- Courier and forwarding companies and SMS service
providers via mobile telephony.
- Collaborating companies to participate in programs
or to promote products and services of the COMPANY.
THE COMPANY has legally ensured that the processors
on its behalf fulfill the conditions and provide reasonable
assurance that the appropriate technical and organizational
measures will be in place to ensure that your personal
data is processed to protect the rights.
- Affiliated companies or companies.
- Transmission or disclosure required by the applicable regulatory,
regulatory, and regulatory framework or judicial decision (such
as transmission to judicial authorities, tax authorities, supervisors,
THE COMPANY does not transmit your
personal data directly to third countries or international organizations
unless the transmission is required by the applicable regulatory
or legislative framework.
As a data subject, you retain the following rights:
- In any case, where we rely on legitimate interests in the
processing of your information, you have the right to refuse
or restrict the processing of your information by us.
- Right of access to your personal data and subject to processing
by the COMPANY as the controller, the purposes of the processing,
the categories of data and the recipients or categories of recipients
(Article 15 of the CPC).
- Right to correct inaccurate data and fill in incomplete
data (Article 16 of the CIS).
- Right to delete your personal data without prejudice to
the Company's obligations and legal rights to retain it in accordance
with the applicable laws and regulations (Article 17 of the
- Right to restrict the processing of your personal data if
either the accuracy of those data is questioned or the processing
is unlawful or the purpose of the processing was forfeited and
provided that there is no legitimate reason to hold them (Article
18 of the CIS).
- Right to transfer your personal data to another controller,
provided that the processing is based on your consent and is
done by automated means.
- Satisfaction of this right is without prejudice to the
Company's legal rights and obligations to hold the data
and fulfill its duty in the public interest (Article 20
- Right of objection for reasons relating to your particular
circumstances if your personal data is processed for the performance
of a duty performed in the public interest or in the exercise
of public authority assigned to the COMPANY or for the purposes
of the legitimate interests it seeks the COMPANY or a third
COMPANY is committed to providing you
with all possible assistance and assistance to exercise these
How to exercise your rights and submit a complaint
All your requests regarding your personal data and the exercise
of your rights must be addressed in writing to the registered office
of the COMPANY's registered office or to the e-mail address "Contacting
A special form for the exercise of the right of access
is available at the headquarters of the COMPANY's headquarters.
COMPANY's denial or unjustified delay in meeting your claims
when exercising your rights entitles you to appeal to the Personal
Data Protection Authority as the competent supervisory authority
for implementing CIS. In any case, you reserve the right to submit
a complaint to the competent supervisory authority if you believe
that your personal data is being processed in violation of the applicable
For more information you can visit the website of the competent
supervisory authority at http://www.cpdp.bg/en/
Using our web sites
We inform you that COMPANY uses on its "cookies" websites to
improve your online experience.
For details on cookies, you can get information from
the COMPANY website
The Company may review or modify this information on the basis
of its current data protection policy and within the current legal
and regulatory framework in order to comply with legal requirements
or respond to changing business needs.
The most up-to-date version can be found on COMPANY's website
In the event that there is any significant change to this
(for example, through an Emerging Alert or a statement of changes
to our site).