PRIVACY POLICY

At Antipodes, we pay special attention to the confidentiality of the personal data which we process.

This Policy contains information about the personal data which we collect; the purposes for which we use it; and the rights you have with respect to your personal data which we process.

Please read this Policy carefully, since it applies when you access and use the Website and the Service. If you do not want your personal data to be processed in the manner described in the Policy, please do not submit it to us, do not access the Website and its content, and do not use the services accessible through it.

I. General

This Service is provided and the Website is registered, managed and maintained by Antipodes EOOD, UIC 130168396, located at the following headquarters and management address: Sofia, Dianabad Region, "G.M. Dimitrov" Boulevard No. 60, ap. 84 (hereinafter referred to for brevity as "Antipodes" or "we").

The purposes and means by which the data of users of the Website and the Service are processed, are defined by Antipodes and as such we are the administrator of the relevant personal data. This Policy is applicable together with other documents available on the Website, such as the General Conditions for Use, which may also contain separate grounds or conditions for the processing of your personal data.

The terms; Website; Service; Prim; Client; Client domain; User; Profile; Client profile; Public content on the Website shall have the meaning ascribed to them in the General Conditions for Use.

This policy, together with any other documents governing the relationship between you and Antipodes, do not limit or invalidate any rights relating to the processing of your personal data which may arise from the applicable law.

In the event of any discrepancy between the Policy and any legal provisions or consent to the processing of your personal data, we will as a priority observe the relevant provisions of the law or your consent.

All matters concerning the application of this Policy and the exercising of your rights relating to the processing of your personal data by Antipodes may at any time be addressed to us at the above Antipodes address or e-mail at: info@prim.bg. We will endeavour to respond without undue delay and ask you that you designate your request in the following manner: "personal data" or "confidentiality".

This Policy shall not apply to the processing of personal data by Antipodes as Data Processor on behalf of any other Data Administrator as client within the meaning of the General Conditions for Use, governed by a Data Processing Agreement except in those cases where the agreement refers back to this Policy.

II. Personal data which we collect and process

Our aim is to collect and process only the requisite personal data which will enable us to provide you with those services which will afford you the best possible result.

We can collect your personal data in a number of different ways. The most frequent way is when you provide us with your own data. For example, in such cases when pursuant to the General Conditions for Use, you subscribe to the Website in order to use the Service, or when you submit your personal information to us when exercising the rights referred to below. In such cases, you are entitled to choose whether to provide us with your personal data. Should we request that you provide us with your personal data regardless of the manner in which this it is requested, you shall be entitled to refuse. However, should the data be required for the establishment of a relationship with Antipodes, the use of a service or functionality, this relationship may not be established or you may be unable to use the service or functionality.

Express consent is not always a requisite or mandatory condition for the processing of your personal data, if we have another legal basis envisaged by law for example. We may also process such personal data which has not been submitted by you. One such case may be, for example, when a client of the Service has submitted your personal data as a user of the Service in order to create a client profile on your behalf in Prim.bg, and such data has been legally submitted to us by third parties or is available from public sources. Regardless of the data source, we will always apply this Policy and your legal rights will not be affected.

The data which we collect depends on the purpose for which it is processed and the relationship for which it is collected.

The personal data which we process may include the following:

  • names, postal address, email address, telephone number or other similar contact details;
  • usernames; access passwords; other data which might permit your identification as a user of the Service (for example, access to a client domain or in order to be able to work with Prim). This might also include other data, for example a role within role Prim and personal settings which defining restrictions and rights when you use the Service as a user;
  • other personal data you may have submitted to us at your discretion, for example in connection with notifications, requests or all manner of other inquiries addressed to us.

We may also use other data which may not identify you directly but which may be connected with you in conjunction with other data or which may serve to identify you via third parties, for example an IP address. This data is submitted to us when you visit the Website as part of the automated communication process between our servers and your web browser. This may include: the type of browser you use; the date and time you visited the Website; the Website pages visited; the link used to visit the Website, etc. This list of information is indicative and does not necessarily have to be collected in its entirety during each visit to the Website. We only use this information as necessary for security of access to a client domain.

Antipodes does not process special ("sensitive") categories of personal data which may reveal: racial or ethnic origin; political opinions; religious or philosophical beliefs; membership of trade unions; genetic data; biometrics; health data; data relating to sexuality or sexual orientation; judicial convictions or related security measures. Nor do we process other categories of personal information which we believe may pose an increased risk, such as information about your financial status or about which payment instruments you use. We therefore ask you not to provide us with any such data from these categories. If, for the purposes of the relationship established with you, we consider it necessary, you may receive an explicit request (the relevant Website functionality may incorporate a request) to provide data from the relevant data category.

On the date of adoption of this Policy, the Website does not use "cookies". However, the need to collect and process data by the means of cookies may occur, or may already have occurred by the time you agree to the Policy. If this is the case, the use of cookies will be clearly designated on the Website. By accepting the Policy, you agree to the use of cookies. Section VIII below provides a brief description of cookies.

III. Personal data processing purposes

We may process your data for any of the following purposes:

1. To establish and maintain the relationships necessary for the performance of the services provided by Antipodes. In particular:

  • to identify our clients and/or their representatives with regard to establishing contractual relations;
  • to activate the use of the Service and/or other services which we provide;
  • to identify users who are entitled to access a client domain and use the Service;
  • when it is necessary for the performance of our obligations or your obligations arising from the Service and/or other services, as well as any other actions or activities necessary for the provision of the Service pursuant to the General Conditions for Use;
  • to communicate with clients pursuant to the manner of the General Conditions for Use;
  • to send information or notifications of a promotional nature concerning the Service or other services provided by Antipodes;
  • to verify, if necessary, the personal data provided from independent sources.

2. To improve the quality of the Service or to create new Antipodes products and services. In particular:

  • to correct errors in Prim or other products connected with the Service;
  • to develop new functionalities or optimize existing functionalities in Prim or other products, software and hardware systems connected with the Service;
  • to analyze the performance of the Service and the other services which we provide.

3. To perform our duties and communicate with you when exercising the rights set out in this Policy.

4. To protect the legitimate interests of Antipodes or a third party including but not limited to the performance and implementation of:

  • preventive measures to ensure the security and confidentiality of all manner of data (including your personal or third party) which we process;
  • follow-up measures and actions designed to remedy any harmful consequences of unlawful actions against the security of the products, services or data processed by us. Should this be the case, the use of cookies will be clearly indicated on the Website and by accepting the Policy you demonstrate your agreement that your data will be collected through them .
  • actions necessary to compensate for material or non-material damage arising from the non-fulfilment of obligations pursuant to contractual relations with regard to our services or to resolve legal disputes of any nature arising from the services we provide.;
  • actions necessary in the event of any violations of the mandatory imperative requirements of applicable legislation.

5. To comply with our statutory obligations, including with regard to accounting or reporting activities or the performance of instructions issued by the competent authorities;

6. To market and advertise the products and services offered by Antipodes or third parties. We process your personal data for this purpose only with your consent, which you may withdraw at any time during the exercising of the rights specified below.

7. When using the public content of the Website or when subscribing and creating a profile on the Website or when accessing a client domain:

  • to personalize your visits to the Website and/or client domain, so that we can provide you with the maximum benefit of the services we provide;
  • to provide access to the individual modules or functionalities of the Website, as well as information and other resources requiring subscription to and/or the creation of a profile on the Website.

IV. Provision of personal data to third parties (recipients)

We will disclose your personal data to third parties only in cases permitted by law and required for the purposes referred to above. In particular, data may be provided, including to other countries, when: a) you have agreed to this; (b) it is necessary for compliance with our statutory obligation or another basis is set out in law; or (c) this is necessary for the exercising of rights or the performance of obligations arising from a contract with Antipodes to which you are a party or a counterpart.

We will not trade your personal data in any way or for any reason.

By accepting this Policy, you agree that for the reasons set out herein, your personal data may be disclosed to the following categories of persons: state and municipal authorities and institutions; persons with whom we have a contractual relationship to provide on our behalf a given part of the Service or other services which you may use; persons who provide technical support or other specialized services such as Data Centres, persons who are specialised in checking, analyzing and assessing risks to the applicable security and data protection measures, hardware or software systems and infrastructure, as well as identifying and preventing unlawful acts; persons specialised in the provision of marketing services; and other persons with relation to whom you have agreed that the data be disclosed or to whom the disclosure of data is necessary for the provision of the Service or other services you use.

At the time of adoption of the Policy by Antipodes, we do not transmit or intend to transmit any personal data to third countries or international organizations. Notwithstanding, in accordance with the above-mentioned aims and purposes, such a need may occur or may have occurred by the time you agree to the Policy. In such cases, if there is no legal basis requiring the recipient to implement data security measures in accordance with applicable EU law, we will bind said third party with data privacy clauses aimed at ensuring that your data is sufficiently protected.

V. To protect information which identifies you.

The security of your personal data is of key importance to Antipodes. For the entire time during which we dispose of your data, we shall apply a set of suitable organizational and technical measures, in order to guarantee ensure a level of security which takes into account the possible risks.

In particular, we reduce to a minimum the personal data we collect and process by means of imposing limits on the types of data collected and the instruments and forms of processing.

Notwithstanding whether you have subscribed to the Website pursuant to the General Conditions for Use or subsequently when using the Service via a Client Domain, the connection between your browser and us will be through a Secure Sockets Layer (SSL) cryptographic protocol. The databases which store data are organized and reliably protected against unauthorized access. We use the Data Centre collocation services and our servers are stored with a supplier duly certified pursuant to our quality management and information security management system. Our personnel are trained to perform their data processing duties in office/s at a guaranteed high level of security of access.

VI. Periods of time during which we process data

We will process your data as and when necessary: (a) to provide the Service or other services; (b) to comply with statutory obligations; (c) to protect the legitimate interests referred to in Section III, point 4; d) or when we have your consent to data processing.

As a result of the diversity of data types, as well as the purpose and the requirement for their processing, it is difficult to define in advance the requisite processing time. Antipodes shall periodically review the grounds for such processing.

VII. Your rights

We would like to draw your attention to the fact that services which we provide are intended for individuals engaged in commercial or professional activity. Your personal data may have been submitted to us by your Employer, for example, to enable you to use the Service as a user. In such cases, the lawfulness of the processing and security of your personal data may also be subject to the confidentiality policies of this other person, who needs to evaluate the lawfulness of said processing, as well as the requirement to provide us with the data. Antipodes shall not bear responsibility for complying with the privacy policies of such persons (clients); they shall independently evaluate the need and legitimate grounds for providing us with the data. In such cases, when exercising rights in relation to your personal data, we may seek the assistance or consent of the person who provided them or we may recommend that you direct your request towards such a person.

If you are a user, the information relating to a large part of the personal data processed by us can be found within Prim. Depending on your role, you can familiarise yourself with such data and either delete it or correct it by yourself or with the assistance of the client. This also applies to such data as username and password for access to the client domain and Prim which you can manage independently.

Notwithstanding the foregoing, as a data subject you have the following rights:

  • to receive information about your personal data which is processed by us, including confirmation that your data is being processed;
  • the correction of inaccurate personal data, the deletion of personal data (the right "to be forgotten");
  • limitation of processing;
  • the portability of data to another data controller;
  • to object to the processing of your personal data, and to refuse to be subject to a decision based solely on automated processing, including profiling;
  • to be notified of a security violation of your personal data;

You can exercise your rights arising from your relationship with Antipodes by sending us the appropriate request to the above email address. We would ask you to designate the message with a reference to "personal data" or "confidentiality" and clearly state the nature of the request (the rights being exercised). At your discretion and pursuant to the above manner, you may opt out of any authorisation which you have already granted to us for the use of your personal data for a particular purpose. For example, if you do not want your contact details to be used for advertising and other marketing messages, you may opt-out by deleting it through the Subscription Management function on our Subscription Site.

Antipodes makes every effort to process personal data in a conscientious and transparent manner. For this purpose, we treat each request for the exercising of the above rights on an individual basis, and our internal rules set out the formal procedures for the way in which this is done. Whether your claim is justified or not, you will receive the relevant response without undue delay and within the time limits provided for in the applicable legislation.

We also notify you that as of the date on which this Policy was adopted, Antipodes is considered an administrator of personal data as registered by the Personal Data Protection Commission, at the following website www.cpdp.bg. If you believe that your rights as enshrined in the applicable legislation have been violated, you are entitled to appeal to the designated supervisory body.

VIII Use of cookies

Most of the sites you visit use "cookies" to improve user experience. Cookies can fulfil many different roles; they allow you to navigate efficiently between pages; store your preferences, and in general terms improve the use of a given website.

Cookies are small text files which the relevant site may store on your computer or mobile device when you visit a given page or website. They allow the server to restore or read the contents of the cookie. Each cookie is unique and contains anonymous information such as a unique identifier, site name, digits, or letters. It allows a site to save your navigation preferences. Other files or technologies with similar features exist (such as web beacons). The term "cookie" in this Policy is used to refer to all files that use information in this way.

Some sites may use cookies to send targeted advertising or marketing messages based on your location and/or your internet navigation habits, for example. Cookies may come from a site you have visited (first-party cookies) or they may be positioned on other sites which provide content on the page you are viewing (third-party cookies).

There are different types of cookies. "Session cookies" are stored temporarily during the browsing session and then removed from your device when you close your browser. Such cookies are typically used to facilitate the proper functioning of the site and to maintain a stable session. Another type are "permanent cookies" which are not deleted from your computer when you close your browser. They remain on your computer until their validity expires or you delete them. "Permanent cookies" designate your computer, to allow the server to recognise it the next time you visit the site.

More information about the way in which cookies are used is available on www.allaboutcookies.org.

If you do not want to receive cookies, the most common method is to change your browser settings to reject them or to notify you when a cookie has been stored on your computer. You are not obliged to accept our cookies. However, if you change your browser settings to reject them, you may not be able to use all the functionalities of the Web site.

IX. Changes to the Policy

The current version of this Policy is available at www.prim.bg. This Policy may be unilaterally amended and supplemented by Antipodes pursuant to the manner set out in the General Conditions for Use.