Privacy Policy & Cookie Policy
At Willow2021 OOD, accessible on www.switch2bg.com one of our main priorities is the privacy of our visitors. This information is intended to inform you about all aspects of the processing of your personal data by Willow2021 OOD (“We” or “Company”) and the rights you have in relation to the processing.
If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us through email at office@switch2bg.com
Who are we?
Willow2021 OODis а company registered and operating under Bulgarian legislation, with registered address: 5A Triaditsa, fl. 5, 1000 Sofia city, Bulgaria, registered in the Commercial register of the Registry Agency under UIC 207903089.
We are a Data Controller of the collected personal data according to the General Data Protection Regulation (GDPR) and we adhere to the provision of the European and the Bulgarian legislation.
When using the term “personal information” or “Personal Information”, we refer to information relating to you, which can be used to personally identify you (either directly or indirectly), such as your name, e-mail address, company name, address, phone number, CVs, resumes, and other information about yourself or your business. Personal Information can also encompass information about you available on the internet, such as from Facebook, LinkedIn, Twitter, and Google, or publicly available information that we acquire from service providers.
Information about Children
The Website is not intended for or targeted at children under 16 years old, and we do not knowingly or intentionally collect or maintain information about children under 16 years old except when it comes to working cases and strictly complying with the Data privacy rule according to the GDPR. Additionally, we kindly ask any child under the age of 16 not to submit any personal information to us or use the Website except when mutually agreed prior according to the GDPR rules.
Why and how we collect and use your personal information
The types of information that we may collect from you, depending on how you use our Website or contact us, include:
- Your name.
- Your e-mail address.
- Your company details.
- Your CV, motivation letter, or additional supporting documentation (portfolio, project descriptions, related pictures, etc.) that you elect to provide when applying for a role at our company on our website or via e-mail.
- Any other information that you choose to provide us when filling out a contact form on our Website.
- Your IP addresses.
How do we collect information and how we use your Personal Information?
1. Visitors to our Website:
When entering our Website, we will collect information necessary for its operation and for us to comply with security and legal requirements related to its operation.We also collect information about your activities during your visit such as date and time of visits, the pages viewed, time spent at our Website, and the Website visited just before our own, as well as your IP address and your browser so that we can better address your queries and to collect statistics to help us improve your browsing experience in the future.
2. Information from the “Contact Form” section of our website:
We may collect your Personal Information, which you choose to provide when you fill in contact forms on our websites, including your name and e-mail. We may use this Personal Information to respond to your queries and/or provide the services and/or information that you have requested.
3. Information from requests via e-mail:
When you contact us via e-mail in connection with a request, such as a request for information, to order a service, to provide you with support, or to offer us a proposal, we collect information necessary to respond to your request and to be able to contact you. For instance, we collect your name and contact information and details about your request. We may use this Personal Information to respond to your queries and/or provide the services and/or information that you have requested.
We use Transport Layer Security (TLS) to encrypt and protect web and e-mail traffic. If your e-mail service does not support TLS, you should be aware that any e-mails we send or receive may not be protected in transit.
Our business purposes
We may also use your Personal Information for our business purposes such as:
- record keeping, statistical analysis, internal reporting, and research purposes;
- to ensure network and information security;
- to notify you about changes to our services;
- to investigate any complaint, you make;
- to provide evidence in any dispute or anticipated dispute between you and us;
- to customize various aspects of our Website to improve your experience;
- To provide you with updated information about new services we have to offer;
- to host, maintain, and otherwise support the operation of our Website;
- for the detection and prevention of fraud and other criminal offences and for risk management purposes;
- for business and disaster recovery (e.g., to create back-ups);
- for document retention/storage;
- for database management;
- to protect our rights, property, and/or safety, our personnel and others;
- to ensure the quality of the services we provide to our users.
Use of third-party services and Cookies
Our website utilizes standard technology called “cookies” and server logs to collect information about usage and remember your preferences. Information gathered through cookies and server logs may include the date and time of visits, pages viewed, time spent on the website, the website visited just before ours, your IP address, and browser details.
A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to our Website or browse from one page to another.
We also use the third-party service Google Analytics – a web analytics service provided by Google, Inc. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our Website. Google Analytics uses cookies to help us analyze how visitors use our Website. The information generated by the cookie about your use of the Website includes your IP address and will be transmitted to and stored by Google, on its servers. Google will use this information for the purpose of evaluating your use of the Website, creating reports on website activity and providing other services relating to Internet usage. Google may also pass this information on to third parties when required to do so by law, or when such third parties process the information on Google’s behalf. By using our Website, you consent to the processing of data about your visit by Google in the manner and for the purposes set out above. If you so choose, you can opt out by turning off cookies in the preferences settings in your browser, or by downloading and installing the Google Analytics Opt-out Browser
We use a third-party service to help maintain the security and performance of our Website. To deliver this service it processes the IP addresses of visitors to our Website.
In addition, we may use your Personal Information for further specific purposes made clear at the point of collection on particular pages of our Website.
If you choose not to provide Personal Information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information. Aside from this, your visit to our Website will remain unaffected.
Legal basis for collection and use of personal information
We process your Personal Information in relation to the use of the contact form on our Website and in cases for recruitment purposes, where we have your consent to do so. In other cases, we process your personal information where we need to do so:
- to comply with our legal and regulatory obligations;
- for our legitimate interests, not overridden by your data protection interests or fundamental rights and freedoms, in responding to your queries, providing services and/or information to you, and our internal business purposes mentioned previously.
Retention of personal information
It is our policy to retain your Personal Information for the length of time required for the specific purpose or purposes for which it was collected, which will not exceed five years. However, we may be obliged to store some Personal Information for a longer time, taking into account factors including:
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- (potential) disputes;
- guidelines issued by relevant data protection authorities.
We will securely erase your information once it is no longer needed.
We will notify you in the event that the data storage period needs to be extended in order to fulfill a legal obligation or in view of the legitimate interests of the Administrator, or otherwise.
How and when do we share information with third parties?
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is adequately protected. Details about how we share Personal Information with third parties are set out below.
Google Analytics
Our Website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics works using cookies.
Google Analytics cookies collect your IP address. We use the information collected by Google Analytics cookies to find out about how visitors use our Website.
The IP address sent by your browser in connection with Google Analytics will not be combined by Google with other data.
If you so choose, you can opt-out by turning off cookies in the preferences settings in your browser, or by downloading and installing the Google Analytics Opt-out Browser Add-on from http://tools.google.com/dlpage/gaoptout. However, please note that you may not then be able to make full use of all the Website’s functionality.
Third-party service providers
We also share your Personal Information with our third-party service providers (e.g. cloud storage) based in the European Economic Area (EEA) who we engage to provide support services in relation to our Website. These services include hosting and maintaining our Website, providing data storage, assisting us with database management, and related tasks or processes.
We may also share your Personal Information with other third parties if we are under a duty to disclose or share it in order to comply with legal obligations or to protect the rights, property, and/or safety of Willow2021 OOD, our personnel, or others. This may include sharing information with third parties following the requirements of a court, regulator, or government agency, such as complying with a search warrant, court order, or applicable law or regulation.
Your rights in the collection, processing and storage of your personal data
1. Withdrawal of consent to the processing of your personal data
If you no longer want the personal data provided by you to be processed, you can withdraw your consent at any time by sending a request in free text and emailing it to us on office@switch2bg.com. The withdrawal of consent does not affect the legality of the processing of personal data carried out by the Administrator up to this point.
2. Right of access
You have the right to request and receive confirmation from the Company whether your personal data is being processed by sending a request in free text by email. After we receive your request, we will ask for verification as a subject of the personal data to which access is requested. After carrying out the verification, we will provide you with a copy of the processed personal data related to you in electronic or other appropriate form.
3. Right to rectification or completion
You may at any time correct or complete any inaccurate or incomplete personal data relating to you by sending a free text email.
4. Right to erasure (“to be forgotten”)
You have the right to request the deletion of some or all of your personal data, and we will delete it without undue delay, where any of the following grounds apply:
- The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
- You withdraw your consent on which the data processing is based and there is no other legal basis for the processing.
- You object to the processing of your personal data, including for direct marketing purposes, and there are no overriding legal grounds for the processing.
- Personal data was processed illegally.
- Personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the Administrator.
- The personal data was collected in connection with the provision of information society services.
The administrator is not obliged to delete the personal data if it stores and processes them:
- to exercise the right to freedom of expression and the right to information;
- to comply with a legal obligation that requires processing provided for in EU law or Member State law that applies to the Administrator or for the performance of a task in the public interest or in the exercise of official powers granted to him;
- for reasons of public interest in the field of public health;
- for the purposes of archiving in the public interest, for scientific or historical research, or for statistical purposes;
- for the establishment, exercise, or defense of legal claims.
To exercise your right to be forgotten, it is necessary to send a request to delete your personal data by email or through a free-text request.
5. Right to limitation
You have the right to request us to restrict the processing of data related to you by sending us a free-text request via e-mail.
6. Right of portability
You have the right to ask us to provide you with your personal data in a readable format and to transfer it to another Administrator, or to request us to directly transfer your personal data to an administrator specified by you, where this is technically feasible.
7. Right to receive information
You can ask us to inform you about all recipients to whom the personal data, for which correction, deletion, or restriction of processing has been requested, has been disclosed. We may refuse to provide this information if it would be impossible or would require a disproportionate effort.
8. Right to object
You can object at any time to the processing of personal data by us that relates to you, including if it is processed for the purposes of profiling or direct marketing.
Breach of your rights
In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection as follows:
Name: Personal Data Protection Commission.
Headquarters and management address: 1592 Sofia, 2. Prof. Tsvetan Lazarov Boulevard
Address for correspondence: kzld@cpdp.bg
Phone: +359 2 915 3 518
Website: www.cpdp.bg