Privacy Policy
This Privacy Policy is intended to inform you about the way we use the collected data, as well as the methods by which you can modify and adjust the information we collect in connection with the websites and applications owned or controlled by “TEREM – HOLDING” EAD, and your rights pursuant to the Personal Data Protection Act and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
“TEREM – HOLDING” EAD is the administrator of your personal data within the meaning of the applicable legislation in the field of personal data protection.
І. Subject Matter
This Privacy Policy is intended to indicate what personal data we process in the course of our activities in connection with the www.terem.bg Website, for what purposes and on what grounds we carry out such processing, and to provide additional information and assistance in this regard.
If you have any questions for us regarding the protection of your personal data, you can use the contact information provided at the end of this Privacy Policy.
Please read this Policy carefully before using our services. It is important to know that:
You agree to our Terms of Use and to this Policy and confirm that you accept them by your registration on our Website.
Providing required personal data is voluntary; in relation to the use or the access of services on our Website. Your refusal to provide the required personal data to use the services on our Website would mean that you refuse to use the relevant services or the access to the Website.
ІІ. Definitions
1. Personal data – any information relating to an identified or identifiable specific natural person (individual).
2. Processing of personal data – any operation which is performed on personal data such as storage, use, recording, organization, adaptation, transmission, disclosure, combination, erasure, etc.
3. Controller of personal data – the natural or legal person which determines the purposes and means of the processing of personal data.
4. Website – www.terem.bg (including front page and subpages).
5. Legal basis for the processing of personal data (grounds) – a condition that shall be met for the lawful processing of personal data.
6. Visitor: any person who loads the Website in its web browser.
ІІІ. Types of Data Subjects; Categories of Data Processed; Purposes of Processing; Retention Period; Legal basis for Processing; Users.
Our users visit and use the Website and our services in different ways – that’s why we have identified several categories of users. For each of them, we have defined the respective volume of data that we collect and process, purposes and grounds, retention periods, etc. One and the same user may fall into more than one category.
1. Data that may be collected automatically for all users: In respect of all our users (registered and non-registered), in certain cases we automatically collect and process the following categories of personal data:
IP address: When you visit the Website, our web server automatically recognizes and collects your IP address, which is assigned by your Internet service provider but it does not personally identify you.
Summarized information: Log files providing a set of system information about the user, namely:
IP address;
ISP – Internet Service Provider;
The browser you use when you visit our Website (e.g. Google Chrome, Internet Explorer and Mozilla Firefox, etc.);
The time you have spent on the Website and the pages on the Website you have visited.
The information contained in these files includes:
Cookies: We use cookies to offer the relevant for you information and a better and more personalized service while visiting our websites, giving you the opportunity to find more easily what you are looking for. The cookies (used by our websites) allow us to store data that does not reveal personally identifiable information about you. For more information, please, see our Cookies Policy.
Web beacons: these are files that allow a website to collect information about the number of users that have visited it and to have access their cookies.
2. Data that can be collected by user category:
Online identifiers stored in local cookies on the visitor's device/browser.
Location data provided by the visitor.
Country/city data based on the IP address of the user's device, an integral part of the information received by each website. Information about actions performed by the subject on the Website.
Subject preferences on specific aspects and settings of the platform functionalities. Information on the type of browser/device used.
3. Purposes of processing:
Providing basic and auxiliary functions necessary for the correct and full functioning of the Website; counting the number of visitors on the Website;
Providing the necessary conditions for the implementation of services on marketing platforms.
4. Retention period: Until the expiration date of each cookie (up to 1 year from the moment it was saved), which carries the relevant information, or until it is deleted by the subject on whose device/browser it is stored.
5. Legal basis for the processing: Consent to the Cookies Policy.
6. Users
6.1. Registered users
A registered user is any Visitor who has registered on the Website, thereby creating his/her so-called profile or account. Registering an account on our Website enables you to use a wider range of services.
6.1.1. Categories of data of registered users that may be processed:
Required data – marked with an asterisk next to the corresponding box in the registration form. Username; E-mail; Password
Optional data – provided optionally:
Name; sex; date of birth; interests; occupation/profession.
Full name, address, UIC, telephone, fax, FLB (financially liable person).
6.1.2. Purposes of processing:
a) Providing the user with the opportunity to register an account, enabling the use of services on the Website, maintaining a user profile, interacting with other users, etc.
b) Purposes of the processing related to and/or necessary for the performance of a contract with the data subject:
Providing the information services available through the Website, including to provide various functionalities;
Communicating with registered users, including by electronic means, about the services provided through the Website.
The storage of certain log files is necessary for the provision of the services themselves.
c) Purposes for processing personal data necessary for the purposes of the legitimate interests of the Company or of third parties:
Evidence of any statements made and other actions taken by the user while creating and managing a user account and using the services of www.terem.bg (including by collecting and storing log files).
Ensuring the proper functioning and use of the Website;
Protection of the rights and legitimate interests of the Company and its business partners/other third parties against claims.
6.1.3. Retention period: until the receipt of registered account deletion request, sent by the User to the e-mail: terem@terem.bg
6.1.4. Legal basis for the processing of mandatory data: consent to the Terms of Use of the services available at www.terem.bg (the execution of a contract with the data subject) and in view of the legitimate interests of the Company or of third parties (in accordance with the above-mentioned purposes of processing).
6.1.5. Legal basis for the processing of optional data: Consent of the user (provided optionally).
ІV. Posting, modifying and deleting user content on the Website.
The Website publishes user content of registered users. The user content may contain personal data and the respective User is fully responsible for the lawful processing of the data contained in the user content uploaded by him/her, and will be liable to indemnify the Company in the event of damages (pecuniary penalties or damages) suffered by the latter in connection with the personal data contained in the user content.
In this regard, the categories of data that may be processed are:
а) Identification data:
username
e-mail address, password and other optional data specified by the user.
б) Miscellaneous:
any other information contained in the posted user content
IP address and its activity (resources visited from the Website), activity history (behavioral interests) – which addresses were visited, how much time was spent on them.
Purposes of processing necessary for compliance with legal obligations:
Taking measures to prevent/remove illegal user content;
Compliance with requests for information from public authorities;
Compliance with other legal obligations.
Purposes of the processing related to and/or necessary for the performance of a contract with the data subject:
Provision of the information services available through the Website
Purposes for processing personal data necessary for the purposes of the legitimate interests of the Company or of third parties:
Evidence of any statements made and other actions taken by the user while creating and managing a user account and using the services of www.terem.bg;
Ensuring the proper functioning and use of the Website;
Protection of the rights and legitimate interests of the Company and its partners/other third parties against claims;
Business planning, including analysis and evaluation of the Website's performance and planning of its development.
Retention period: 5 years from the date of removal of the content from the Website.
Legal basis for the processing of data: consent to the Terms of Use of the services at www.terem.bg (performance of a contract with the data subject) and in view of the legitimate interests of the Company or of third parties (in accordance with the above-mentioned purposes of processing).
V. On what basis we process your personal data
We process the data that is required to register an account on our Website on the basis of our contractual relationship governed by our Terms of Use, under which we provide you with a range of services.
We use this data:
for the purposes of registration and maintenance of your account;
to provide specific services that are available only after registration, including: writing comments and posting materials on the pages of terem.bg;
to resolve disputes and troubleshoot problems; to communicate with you.
We process the data you provide to us when you register, which is not mandatory for the purpose of registration, on the basis of your consent.
Your data may be used for the purpose of direct marketing of our services and services of our partners, as well as for the provision of other additional services, only with your consent.
We process the data we collect from log files, cookies and web beacons for the following purposes:
to provide you access to our Website;
to customize ads for our products and our partners' products;
to measure and track statistical dependencies in order to improve the quality of our services and therefore the interest in them.
IP address recognition and collection is carried out for the following purposes:
to disclose the identity of users of the Website, in compliance with the law and regulations, to protect our rights and legitimate interests;
to analyze traffic to our Website and to prevent malicious attacks;
to display ads and information related to your location, service information.
We carry out these actions on the basis of our legitimate interests to develop our business and to protect our rights and legitimate interests in the event of disputes, as well as in certain cases on the basis of the mandatory orders of the law.
Under certain circumstances, we may use your personal data to protect our rights and legitimate interests, as well as the rights and legitimate interests of third parties, for example in the event of litigation or out-of-court dispute.
VІ. Who has access to your personal data and how we protect your personal data
Maintaining confidentiality and security of your personal data is of the utmost importance to us. In this regard, access to your personal data is only granted to the following categories of persons to the extent necessary to fulfill the above-mentioned purposes for which we process your personal data:
Our employees and persons engaged under a non-labor contract – to carry out certain work.
Persons providing hosting services (servers) for our websites and other technical services for the maintenance of our systems (including their employees and subcontractors), for which purpose we have entered into a contract with the data processor as required by applicable law;
Professional consultants (lawyers, accountants, etc.) as necessary to implement and protect our rights and legal interests.
State authorities, at their request, in connection with the exercise of their public powers conferred on them by Bulgarian law, as well as when taking action to protect our rights and legitimate interests.
To ensure the security of our Website, the personal data you provide to us is protected by SSL (Secure Socket Layer) technology, a method for encrypting personal data. The password you provide when registering on our Website is encrypted to ensure protection against unauthorized access to your personal data.
While we make every effort to protect your personal information, you should be aware that the transmission of information over the Internet can never be completely secure.
VІІ. Periods of retention of your personal data
We retain your personal data for as long as necessary to ensure the effective operation of our Website, the performance of our contracts and the realization of our legitimate interests. The specific retention periods for certain categories of data are set out in the relevant points in this Policy.
In the general case of registered users personal data processing, we keep the personal data as long as your profile exists on the Website or until you expressly request that your personal data be deleted.
It is important to know that at any time you can opt out of using our services, as well as withdraw the explicit consents provided for the use of your personal data – where the consent is the basis for processing. In these cases, we will cease to use your data and to provide our services to you, as far as possible.
In certain cases, even if the use of your personal data has been discontinued due to the deletion of the account due to inactivity or due to the explicit withdrawal of consents provided by you, we may retain an archive of your personal data, to the extent necessary to protect our rights and legitimate interests, for a period until the expiration of limitation periods provided for in applicable law. Generally, these periods are 5 years, but may be shorter or longer under certain circumstances.
You should be aware that your IP address is automatically collected whenever you visit our Website, regardless of whether you have opted out of our services. In these cases, if you do not want us to have access to your IP address, you should not visit our Website.
VІІІ. Your rights in relation to your personal data
As a person whose personal data we process, the applicable data protection legislation provides you with certain rights that you can exercise effectively in the cases provided by the legislation.
In brief, your rights are:
Right of access. You have the right to ask us to confirm whether we are processing your personal data and, if so, to obtain that data and further information;
Right to rectification. If you find out that your personal data that we process is incomplete or inaccurate, you may request its correction or completion.
Right to erasure (right to be forgotten). Under certain circumstances – such as if your personal data has been unlawfully processed, you can request that we erase all personal data about you. In certain cases, this right is also linked to your right to withdraw the consent provided to us (if the processing of personal data is based on consent) and there is no basis for processing your personal data.
Right to restriction of processing. Under certain circumstances – such as if you doubt the accuracy of your personal data or have objected to our legitimate purpose for processing your personal data, you may request that we restrict the processing of your personal data, in which case active use of the data should cease, but without the data being permanently deleted/destroyed.
Right to data portability. Where we process your personal data on the basis of your consent or on a contractual basis and the processing of your personal data is carried out in an automated manner, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to transfer it to another controller or to request that we transfer it to another controller.
Right to object. Under certain circumstances – such as if you doubt our legitimate interest in processing your personal data, you could object to the processing of your personal data on grounds relating to your particular situation and where we are doing so on the basis of a legitimate interest or in the performance of a task carried out in the public interest.
You can exercise these rights by submitting an application that meets the requirements of the Data Protection Act. More information on the content and conditions under which you can exercise the above rights can be found in the applicable data protection legislation. If necessary, you can also contact us for assistance.
Our contact details tel.: +359 2 806 27 55, e-mail: terem@terem.bg, website: www.terem.bg.
In the event that you consider that we violate your rights in relation to the protection of your personal data, you have the right to file a complaint with the competent supervisory authority in the Republic of Bulgaria – the Commission for Personal Data Protection, or with the court.
