Privacy Policy of PALOMITA JSC (hereinafter referred to as «PALOMITA»).

PALOMITA JSC respects the confidentiality of your personal data and wants you to know that it takes all the necessary technical and organizational measures for their security and protection. The current Privacy Policy aims to describe the procedure of collection, usage and protection of your personal data that are being processed by PALOMITA JSC for marketing purposes, for recruitment purposes, for purposes of communicating with you or investigating any concerns you may have related to our products, by filling in the relevant forms available to PALOMITA’s websites.

Types of personal data and purpose for which they are processed by PALOMITA JSC

PALOMITA JSC may ask you to submit your personal data for marketing purposes, including the mailing of newsletters. With the collection and processing of your personal data, we are allowed to communicate with you via electronic correspondence. The personal data we collect for the above-mentioned purposes include your name, surname and email address.

Furthermore, we process personal data you choose to submit to the forms available to PALOMITA’s   websites in order to respond to your questions and requests and to investigate any concern you may have regarding PALOMITA’s products.

If you submit to us the personal data of third parties, it will be considered that you have the jurisdiction to do it and that you allow us to use them according to the Privacy Policy

Sensitive private data

If we do not ask for sensitive data in a clear and official way, we kindly ask you not to send nor share with us any sensitive personal data (e.g. social security number, evidence related to national origin, political beliefs, religion or philosophical beliefs, health issues, sexual life or sexual orientation, criminal record, participation in trade union, biometrical or DNA data that identify a person) through our website or through any other way.

Legislative ground for personal data usage

For marketing purposes, we collect, use and publish your personal data provided to us with your own will, only if you have given your consent.

Moreover, in order to pursue our legitimate interests, we process your personal data submitted to the forms available to our websites for recruitment purposes and in order to communicate with you, respond to your questions and examine any issue you may have related to our products.

Juveniles

This service does not correspond to people who haven’t filled the 18 years of their age, and therefore PALOMITA JSC will neither maintain, nor process the personal data of juveniles.

Personal data transmittal

PALOMITA JSC does not transmit your personal data to third parties, however PALOMITA JSC external collaborators will have access to them. As external collaborators are considered the providers of advertising and marketing services, who act on behalf of PALOMITA JSC within the framework of the above mentioned aim, and offer services like: hosting and coordination of websites, hosting of application for mobile devices, data analysis, payments processing, proceeding with your orders, IT services, customer service, email and postal correspondence, audits and other services, in order to be able to offer their services. These third parties are processing your personal data, as executors of this process within the framework of offering the above mentioned services as well as of the special confidentiality and data protection agreement that PALOMITA JSC has signed with them, according to which they are obliged to comply with all the relative legislation regarding personal data protection.

Moreover, we transmit your personal data to third parties to which we are obliged by legal provision to do so.

Furthermore, it is possible to use and share your data with other ways, only after we acquire your consent.

Your rights

Regarding your personal data, you have the following rights:

Access and revision of your personal data or restriction of their processing or objection to the processing, as well as the right to data portability

Complaint submission to the responsible supervisory authority and

Deposition of your consent for the processing of your data for the purpose of the current Policy.

How can you exercise your rights?

In case you wish to exercise your rights regarding your personal data protection, you can address your question or request either to the postal address of the Company (PALOMITA JSC, Sofia 1729, 1 Anna Ahmatova str.), or to the electronic address (info@palomita.com) with title “Exercise of the right to access/editing/deleting/restriction/objection”.

How do we reply to your request?

We respond to your request without any charge or delay, and in any case within one (1) month from the time we will have received your request. If, however, your Request is complex or there is a big number of Requests, we will inform you within the month if it is necessary to take an extension of two (2) more months and during which you will receive a reply.

If your requests are clearly unfounded or excessive especially due to their repetitive character the Company may proceed to the submission of a reasonable charge, taking into consideration the administrative expenses for the provision of information or the implementation of the requested action, or deny proceeding the Request further.

Duration of keeping the personal data

Your personal data will be kept for as long as it is allowed or imposed according to the current legislation. In case we process your personal data according to your consent, we will keep processing them until you withdraw it.

Cookies policy

PALOMITA JSC and the service providers with which it collaborates may automatically collect some data, as you surf to the website.

Like most websites, we use “cookies” on our websites to help us serve you better on future visits, and to help us analyze web traffic for our websites and evaluate and improve the content or functions of our websites.  A cookie is a small text file which is sent by a website, accepted by a web browser and then placed on your hard drive.  The information collected from cookies sent by PALOMITA JSC and approved third parties assisting us with our websites lets us know that you visited our websites in the past, and helps you avoid having to re-enter information on each visit in order to use some of our products or services.  Cookies also help us analyze use of our websites, and better aggregate useful information when users provide feedback about our websites or products. You may be able to set your browser to refuse all cookies from this and other websites that you visit.  This will provide you with more control over the acceptance of cookies on your hard drive.  However, it is possible that some portions of the websites will not function properly or may perform more slowly if you choose to reject cookies.  By using our websites and not disabling cookies, you consent to allowing their use for the described purposes. Remember also that disabling cookies is browser specific.  If you log on using Internet Explorer, you must also disable cookies in Safari if you use that browser at a different time. We may also collect information about your method of access such as your operating system (Windows 7, Windows 8, Mac, Linux, etc.) and your browser (Internet Explorer, Google Chrome, Safari, etc.). 

We may use third-party web analytics services on our websites, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies to help us analyze how visitors use the websites. The information collected through these technologies (including IP address) is disclosed to these analytics providers, who use the information to evaluate use of the websites. To learn more about Google Analytics and how to opt out, please visit www.google.com/analytics/learn/privacy.html.

Do Not Track (DNT) is a privacy preference that users can set in their web browsers.  Our websites do not support DNT codes.  However, except in the case of analytic cookies and social networking platforms described herein, our websites limit tracking to the internal uses described above and does not enable the tracking of our users across multiple websites.  Except in the case of analytics cookies and social networking platforms described herein, our website does not track your use across multiple websites, however, other websites to which we link may.  Please review their privacy policies to understand how you may be tracked.

Security

We put every possible effort, by implementing the appropriate technical and organizational measures for your personal data protection from any possible loss, amendment, leakage, destroy or unauthorized access to them by third parties.

Amendments to Personal Data Protection Policy

PALOMITA JSC can revise at any moment the current Privacy Policy, so you will be accordingly informed in our website.

Websites and third parties’ services

The current Privacy Policy does not concern, nor include websites and third parties’ services and does not entail approval, or burden us with any responsibility for the confidentiality, the data or third parties’ other practices, including the third parties who manage a website or electronic service, connected with our website.

Communication

In case you have any question regarding the current Policy or wish to exercise your rights regarding the protection of your personal data, you may address the question or request either to the postal address of the Company (PALOMITA JSC, Sofia 1729, 1 Anna Ahmatova str.), or to the electronic address (info@palomita.com).

Last update: 11 April 2019