TSD PRIVACY AND DATA POLICY

TSD Group Ltd. (“TSD”, “TSD Group” or “we”) manages the Website www.tsd.com. This page informs you of our policies regarding the collection, use, and disclosure of personal information we receive from visitors of the Website. By using the Website, you agree to the collection and use of information in accordance with this policy (“Privacy and Data Policy” or “policy”).

As you review our policy, keep in mind that it applies to all TSD Group brands, products, and services that do not have a separate privacy policy.

TSD Group truly respects the privacy of its users and is fully committed to protecting their personal information and using it properly.

In this Privacy and Data Policy, we use the term “User/s” or “user/s” to include any individual who accesses and uses our Website.

PERSONAL DATA

What Is Personal Data

Personal Data is any information that relates to an identified or identifiable living individual. Different pieces of information, which, collected together, can lead to the identification of a particular person, also constitute personal data.

Personal Data We May Collect

We collect the following information that you provide us through the contact forms on our Website:

  • First and last name
  • E-mail address
  • Company name
  • Job Position
  • Country and City
  • CV that may contain:
    • Picture
    • Date of birth
    • Address
    • Telephone number
    • Education
    • Professional qualification

Information that we may collect from third parties:

We receive information about you from other sources.

We collect the following information using a third-party B2B software – VisitorQueue:

  • First and last name of representatives of a company that visits the Website
  • Company name
  • Job Position
  • Business email
  • Telephone number

We may add this information to the information we have already collected from you through our services for analytic and reporting purposes and/or to improve our services.

Links to the privacy policies of third parties – service providers, used by the Website:

VisitorQueue

MailChimp

Zoho CRM

We collect the following information that you provide us when participating in marketing campaigns and games organized by TSD on Facebook, Instagram, and LinkedIn:

  • physical identity data: first and last name; gender; e-mail address;
  • data relating to participation in the relevant campaign/game: data contained in photos and/or videos, comments, and other social media posts.

How We May Use Personal Data

To the extent permitted by applicable law, we may use Personal Data:

  • to respond to your inquiries
  • for recruitment purposes
  • as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain.
  • for analytics and reporting purposes
  • for direct marketing – upon your explicit consent
  • We use the data collected in marketing campaigns/games for: the administration of the relevant campaign/game; the purposes stated in the specific campaign (e.g. promotion of TSD and its partners, recruitment, etc.), and for direct marketing.

Retention Period

We will retain your Personal Data as follows:

  • personal information, collected for contact purposes – until completion of the communication
  • personal information related to recruitment: data contained in CVs of job applicants – up to 12 months after the completion of the specific selection procedure for which they were initially collected, subject to consent, otherwise – up to 6 months after the end of the procedure.
  • personal information, collected for marketing purposes – until you revoke your consent for such collection
  • personal information, collected for analytics and reporting purposes – usually until the end of the reporting period. Such data is aggregated.

Sensitive Information

We ask that you not send us, and do not disclose, any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health or medical condition, criminal background, or trade union membership) on or through the Website or otherwise to us.

How Personal Data May Be Disclosed

To the extent permitted by applicable law, your Personal Data may be disclosed:

  • to our third-party service providers who provide services such as website hosting, data analysis, infrastructure provision, IT services, email delivery services, and other services, to enable them to provide services
  • to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
  • as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
  • Personal Data collected through marketing campaigns related to TSD clients can be disclosed to the clients mentioned in the respective campaign.

USER’S RIGHTS

Access to Your Personal Data

You have the right to view, amend, or delete the Personal Data that we hold about you. To request access please email office@tsd.com. We will provide the information free of charge and within one month, except in the event that the request is unfounded, excessive, or repetitive, in which case we reserve the right to charge a proportionate administration fee or refuse.

Rectification of Personal Data

If any of the information we hold on you is inaccurate or incomplete, you may ask us to correct or complete it at any time.

Your Right of Erasure, or to be Forgotten

You may ask us to delete your Personal Data, but only if:

– it is no longer necessary for the purposes for which it was collected; or

– you have withdrawn your consent (if the processing of the data is based solely on consent); or

– exercise a legitimate right of objection; or

– it has been unlawfully processed; or

– there is a legal obligation in this respect.

We have no obligation to honor your request for deletion of your Personal Data if processing is required:

– to fulfill a legal obligation; or

– to establish, exercise, or protect a legal claim.

There are certain other circumstances in which we are not obliged to comply with your request for data deletion, even though these are the most likely circumstances in which we may decline your claim.

To request deletion of your personal information, contact office@tsd.com using the email address we hold for you or otherwise proving your identity.

Please be aware that the process of deleting data and deleting the Website with all data and documents associated with it is an irreversible process.

Restrict Data Processing

You may ask us to restrict the processing of your Personal Data, but only if:

– its accuracy is being challenged (see Rectification of Personal Data section) to be able to verify its accuracy; or

– processing is illegal, but you do not want the data to be deleted; or

– it is no longer necessary for the purposes for which it was collected, but we still need to identify, exercise or defend a legal claim; or

– you have already exercised the right of objection and you are checking whether the dominance of our rights is still in place.

We may continue to use your Personal Data as a result of a restriction request:

– if we have your consent; or

– to establish, exercise, or defend a legal claim; or

– to protect the rights of the Website Owner or any other person or entity.

Data Portability

You may ask us to provide your Personal Data in a structured, widely used, and machine-readable format or you may request that it is directly transferred to another data operator, but only if:

– the processing is based on your agreement or the conclusion of a contract with you; and

– processing is carried out automatically.

Right of Objection

You may object at any time, for reasons related to your particular situation, to the processing of your Personal Data based on our legitimate interests if you believe that your fundamental rights and freedoms dominate these interests.

You may also object at any time to processing your data for direct marketing purposes by following the instructions on the email we send you or by sending an email to office@tsd.com.

Making Automated Decisions

You can ask us not to be the subject of a decision based solely on automatic processing, but only when that decision:

– has legal consequences for you; or

– affects you in a similar way and to a great extent.

This right is inapplicable if the decision made after the automatic decision has been made:

– is needed for execution and fulfillment of a contract with you;

– is permitted by law and there are adequate safeguards for your rights and freedoms; or

– is based on your explicit consent.

Your Right to File a Complaint with the Supervisory Body

If you believe that TSD processes your personal data in the wrong way, you can contact office@tsd.com.

You have the right to complain to the local authority about the processing of your Personal Data.

In Bulgaria, the contact details of the supervisory authority for the protection of Personal Data are as follows:

Commission for Personal Data Protection

2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria

Phone: + 359 2 915 35 18

E-mail: kzld@cpdp.bg

COLLECTION AND USE OF NON-PERSONALLY-IDENTIFIABLE INFORMATION

Our web server logs collect network information of visitors to our Website automatically (such as IP address or device identifier). We also collect, using VisitorQueue, information about companies that visit our Website, such as: company name, address, website, telephone numbers and company description, date, time, duration and location of the visit.

This information is used to measure the number of visits, average time spent on our Website, specific pages viewed, and Website usage information and to improve the content of our site. This information is not collected in a way that allows the identification of any of our visitors. We may, however, collect this information in a way that allows the identification of our visitors by using cookies, as explained below and by using VisitorQueue as explained above. Please, note that all personal information collected using VisitorQueue is related to companies’ representatives and their business details and it is collected from publicly available sources.

THIRD-PARTY SITES AND SOFTWARE

This Privacy and Data Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site to which these sites contain a link. The inclusion of a link on this Website does not imply endorsement of the linked site by us.

We are also not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including in connection with any Personal Data you disclose to other organizations through or in connection with our social media pages.

Some of the third-party providers that we use for different purposes are:

VisitorQueue – for identification, in real time, of the companies that visit our Website. Through it we receive more specific information such as name, address, website, telephone numbers and description of the company, date, time, duration and location of the visit, as well as contact details of representatives of the company, including name, position, business email and telephone number of the specific employee.

MailChimp – email marketing and contact list management platform which collects information such as first, last name and business email.

Zoho CRM – a software connected to the Website through the contact form which transfers the Personal Data collected through the contact forms on the Website to the CRM software of TSD.

COOKIES POLICY

What are cookies?

Cookies are small files that a site transfers to your computer’s hard drive through your web browser (if you allow) that enable it to recognize your browser and capture and remember certain information. A cookie cannot read data from your hard drive or read cookie files created by other sites. Cookies may do things such as allowing you to navigate faster through the Website, remembering your preferences and passwords, and generally improving the user experience. You can turn off the ability to receive cookies by adjusting your browser settings — please note that if you do so, this may affect the functionality of the Website and the information you can access through it.

What cookies do we use?

We use a combination of session cookies and persistent cookies in order to track how you use and experience our Website, build anonymous statistical data about how our Website is performing, and power the personalization of Website content to you.

In addition, we may use third-party analytics or tracking services such as Google Analytics that collect, monitor, and analyze web traffic. These services enable TSD Group to collect aggregated statistics and can be used to keep track of visitor behavior.

How do you manage cookies?

You may refuse, accept, or remove cookies from this Website at any time by activating or accessing the setting on your browser. Information about the procedure to follow in order to enable, disable, or remove cookies can be found on your Internet browser provider’s website via your help screen. You may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers. Please be aware that if cookies are disabled or removed, not all features of the Website may operate as intended.

SECURITY AND METHODS OF PROCESSING

We follow generally accepted standards to protect the personal data submitted to us, both during transmission and once we receive it.

The visitor information processing is performed in a proper manner and according to appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the information. As an ISO 27001:2013 certified company, an international standard for Information Security, we ensure a working and integrated information security management system that joins together multiple security controls, both physical and logical, with well-defined policies and procedures.

DATA CONTROLLER

The data controller for the information you provide or that we collect pursuant to this Privacy and Data Policy is: TSD Group Ltd, UIC 206078098, with seat and management address at: 51 G.S. Rakovski Street, 4th Floor, Troyan 5600, Bulgaria.

HOW TO CONTACT US

You may contact TSD directly if you have any questions regarding our privacy practices. Please send your query to office@tsd.com.

CHANGES TO THIS PRIVACY AND DATA POLICY

We may modify this Privacy and Data Policy at any time.

We agree that changes cannot be retroactive. Your continued use of the Website, after the changes of the Privacy and Data Policy have been announced on the Website, means that you are consenting to the updated terms.

Last Updated: 03.05.2022

[/fusion_text][/fusion_builder_column][/fusion_builder_row][/fusion_builder_container]