PRIVACY POLICY FOR HAVELOCK JSC.,

1.GENERAL

1.1Havelock JSC, a company, registered and existing under the laws of Republic of Bulgaria, having its registered company number 205602831, having its registered seat and address at Republic of Bulgaria, city of Sofia, 54 “Iskar str.”, hereinafter referred to as “Havelock JSC” provides its Customers (hereinafter “You”) the Havelock Product(s). This privacy policy explains Havelock JSC practices regarding its collection, use and disclosure of certain information, including Your personal information when we provide Havelock Product(s) to You. It serves to inform You about our processing of Your personal information and ensure You that Your personal information is treated with respect and in accordance with the applicable data protection legislation when using the Havelock Product(s).

1.2You should always feel safe when sharing Your personal information with Havelock JSC. Havelock JSC has taken the technical and organizational security measures that are required to ensure that Your personal information is protected from unauthorized access, use, modification and deletion.

2.PERSONAL DATA CONTROLLER

2.1Havelock JSC is the data controller for the processing of Your personal information handled by Havelock JSC. Information on how to contact us can be found in section 11.

3.WHEN DOES HAVELOCK JSC COLLECT PERSONAL DATA?

Havelock JSC collects personal information about You when:

  • You enter into contractual relation with Havelock JSC in order to use the Havelock Product(s);
  • You provide us with your CV, as well as with other information/documentation on your professional experience, educational status, health condition;
  • You voluntarily fill in the online forms or tests, provided by us;
  • You answer a survey, including but not limited to questionnaires or marketing surveys or reply to communication from Havelock JSC, or
  • It is otherwise necessary to manage the relationship between You and Havelock JSC.

4.WHAT PERSONAL DATA DOES HAVELOCK JSC COLLECT?

4.1When You enter into contractual relations with Havelock JSC, it collects personal information about You. Basic data that Havelock JSC collects includes Your full name, address, email address, phone number, and other personal data, included in the Order form that You would voluntarily provide to us. When using Havelock Product(s) and when visiting Havelock JSC’s website, Havelock JSC may also collect data concerning usage, viewing and technical data, including Your IP address, browser version and operating system.

4.2Further Havelock JSC may also collect and process Information that You provide in public forums on Havelock JSC’s website or to Havelock JSC when You use Havelock JSC sites on third-party platforms such as social networking sites.

5.HOW LONG IS THE DATA KEPT?

Havelock JSC will keep personal information regarding You only as long as it is necessary, having regard to the purpose of the processing. This means that personal information collected and processed for marketing purposes will be stored for as long as You have an account and deleted twelve (12) months after Your contract is terminated, unless You have given Havelock JSC Your voluntary consent to continue to process such data. Havelock JSC may store data for longer if required by law or if required in order to monitor Havelock JSC legal interests, for example if there are ongoing legal proceedings.

6.WHY DOES HAVELOCK JSC PROCESS INFORMATION ABOUT YOU?

6.1Havelock JSC processes Your personal information for various purposes. Primarily, Havelock JSC processes Your personal information in order to provide, manage, develop and customize Havelock Product(s) and its features, to manage the Cuсtomer relationship with You and to meet security and other statutory regulatory requirements. Your personal information may also provide the basis for market and Customer analyses, market research, statistics, business monitoring and business and methodological development for Havelock JSC.

6.2Havelock JSC also processes Your personal information to provide better and more personalized offers and services. Personal information may, for example, be processed, linked, segmented and analyzed in order, by means of targeted marketing, to provide information, offers or recommendations on Havelock JSC products or services, which are tailored to Your preferences, behaviors, needs or lifestyle.

6.3In addition to the above, Havelock JSC processes Your personal information to prevent, detect and investigate potential prohibited or illegal activities, including fraud.

7.WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

7.1A majority of the personal information that Havelock JSC processes about You are processed in order for Havelock JSC to be able to provide and administer the Havelock Product(s) and their features. Such is the case when Havelock JSC processes, inter alia, Your contact information such as Your email address or Your phone number.

7.2Some of the personal information which Havelock JSC processes are processed based on a balance of interest, i.e. Havelock JSC’s interest of processing the data outweighs the impact and risk the processing may have on Your integrity.

7.3To the extent that processing is carried out on the basis of a consent, it is voluntarily for You to give such a consent and You may at any time, wholly or partly, withdraw Your consent. If You choose to withdraw Your consent, and Havelock JSC’s processing is such that it requires Your consent, the processing will be carried out in accordance with Your most recently given consent.

8.DATA SECURITY AND INTEGRITY

The security, integrity and confidentiality of Your personal information is all important to us. We have implemented technical, administrative and physical security measures that are designed to protect Your personal information from unauthorized disclosure, use and modification. From time to time, we review our security procedures in order to assess the need to implement additional measures or to make technical upgrades to existing procedures. Please be aware that, despite our best efforts, few security measures are impenetrable, and we therefore kindly ask that You inform us immediately of any suspicious activities that You notice in the Service.

9.WHO DOES HAVELOCK JSC GIVE THE DATA TO?

9.1Depending on the service that you entered a contractual relation for, Havelock JSC may disclose Your personal information to potential employers, potential employees, our external consultants, business partners and other third parties in order to fulfil the agreement with You or to fulfill agreements with Havelock JSC’s suppliers and partners.

9.2Havelock JSC may also disclose personal information to companies that process personal information on our behalf, such as our IT system providers, Customer service companies and affiliates. If personal information is disclosed to such companies that process data on Havelock JSC’s behalf, Havelock JSC enters into data processing agreements with such parties in order to ensure that a high level of security for Your personal information is maintained.

9.3Personal information may also be disclosed, if needed, to comply with statutory legal requirements or requirements from regulatory authorities, to safeguard Havelock JSC’s legal interests or to detect, prevent, or pay attention to fraud and other security or technical issues.

9.4Your personal information may be transferred to or stored in a country outside the EU/EEA. If Your personal information is transferred or stored outside the EU / EEA, special safety measures will be taken, e.g. ensure that such transfer is carried out in accordance with this privacy policy and as permitted by the applicable laws on data protection, for example through the use of data transfer agreements that include standardized EU-model clauses for transfer of data adopted by the EU Commission and that are available on the EU Commission’s website.

10.CHANGES TO THE PRIVACY POLICY

This privacy policy may be revised from time to time. If Havelock JSC makes any significant changes to the privacy policy, Havelock JSC will inform You in an appropriate way before the changes take effect. The privacy policy will also be published on Havelock JSC’s website. If any change requires Your consent, Havelock JSC will obtain a new consent from You.

11.RIGHT TO REQUEST INFORMATION AND CORRECTIONS ETC.

11.1You have the right to be given free information about, inter alia, the personal information that Havelock JSC processes on You and for what purpose Havelock JSC is processing Your personal information (so-called record extract). Any such request for a record extract must be made in writing and be signed by You.

11.2You are also entitled to have inaccurate, misleading or incomplete data corrected, anonymized or deleted. You are also entitled to request Havelock JSC to restrict the processing of Your personal information and to object to the processing. Furthermore You may exercise Your right to data portability, which means that You have the right to receive the personal information processed about You in a structured, commonly used and machine-readable format.

11.3Please note that some of the rights above only may be exercised in certain situations, e.g. the right to data portability, which only applies when the processing is carried out on the basis of an agreement or a consent and if the processing is carried out by automated means. In case You have any questions regarding how Havelock JSC processes Your personal information, want to exercise any of Your rights or want to know more about the rights, You may contact us as indicated below.

E-mail address: info@havelock.app

Address: Republic of Bulgaria, city of Sofia, 1000 “Oborishte” Region, No: 54 “Iskar” str.,  contact person Marin Kojuharov, Executive Director of Havelock JSC Ltd

You are also entitled to lodge a complaint with a supervisory authority if You consider that Your personal information has been processed in contradiction with applicable data protection legislation.

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Approved by the Executive Director of Havelock JSC Ltd. on date September 25-th, 2019