PRIVACY NOTICES OF AQUA MATRIX LTD
In relation to the new Regulation (EU) 206/679 of the European Parliament and of the Council of 27 April 2019 on the protection of natural person with regard to the processing of personal data and on the free movement of such data and considering AQUA MATRIX LTD’s aim to follow strictly its legal obligations especially considering the personal data protection rules, we would like to inform you about the following:
AQUA MATRIX LTD is a company registered under the Bulgarian legislation in the Commercial Register and the Register of the Legal Entities with Non-commercial Purpose at the Registry Agency of Republic of Bulgaria with UIC 203482454, having its registered address located in the City of Sofia, postal code 1000, 31 Ekzarh Yosif, fl.3. You could contact us through:
correspondence address: Sofia, 1000, 31 Ekzarh Yosif Str, floor 3;
telephone: +359 882871056;
e-mail: orders@aquamatrix.bg;
AQUA MATRIX’s day-to-day business activity requires processing of personal data of the following subjects:
- Employees;
- Job applicants;
- Clients and contracting parties – individuals and/or employees and company representatives;
- Visitors of the website www.aquamatrix.bg, who have provided their own personal data in order to use it, and who are not part of any other category mentioned above;
With these Privacy Notices we would like to inform you about the personal data that we process, the purposes for which we process such data and about your rights in this respect.
We would like to inform you that AQUA MATRIX LTD’s website www.aquamatrix.bg uses ‘cookies’ by which it collects information about the behavior of its visitors, including personal data. More information about the ‘cookies’, including what type of ‘cookies’ we use, etc. could be found in our Cookies Policy (click here).
1.1. Privacy Notices for Employees
AQUA MATRIX LTD processes its employees’ (current and former) personal data in its capacity of employer and as described herein below.
Employees’ personal data which we process include: names, EGN (unique personal identifier), address, ID document data, gender, physical identity data, health status data, remuneration, education, professional activity, professional qualifications, marital status, family relations, contact data (telephone, e-mail, bank account).
Your health status data are sensitive data which we process only when it’s legally required, in order to protect the vital interests of the data subject or of another natural person or when the data subject has given his/ her consent, also in the event that the processing is required for the purposes of fulfilling of obligations and/or for the execution of rights of AQUA MATRIX LTD under the labor legislation and/or social security legislation and for the purposes of the preventive or occupational medicine.
In the event that you do not provide us with the required information, including with the necessary personal data, no labor contract could be concluded between AQUA MATRIX LTD and you, and AQUA MATRIX LTD would not be able to fulfill its legal and contractual obligations resulting from its capacity of an employer.
In your capacity of AQUA MATRIX LTD’s employee we shall process your data for one or more of the following purposes:
- For the conclusion and/or execution of labor contract;
- To fulfill our legal obligations;
- For the purposes of the legitimate interests of AQUA MATRIX LTD;
When the data subject has given his/ her consent.
AQUA MATRIX LTD shall not store your data for a period longer than the required for the processing purpose. We store your data following the legally defined periods as well as considering the volume, specifics and sensitivity of the data, the processing purposes and whether we could complete them with different means.
Once the purpose for which your data have been processed are met, or once there is no legal obligation and/or legitimate interest, we shall erase or delete your data in a secure way.
AQUA MATRIX LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Occupational medicine authorities, companies providing internal audition services, suppliers of human resource management services, suppliers of accounting, legal, IT, banking, insurance, social security, social services and/or other services providers for the performance of contractual or legal obligations, as well as for the protection of the legitimate interests.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
AQUA MATRIX LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
1.2. Privacy Notices for Job Applicants
AQUA MATRIX LTD processes job applicants’ personal data within recruitment procedures and as described herein below.
The personal data of the job applicants that we process include: name, surname and family name, address, nationality, education, professional activity and professional qualification (including knowledge and practical skills), photo, contact information (telephone, e-mail, in particular cases – social media information), other data provided by the applicant.
In the event that you do not provide us with the information requested, including your personal data which is limited to that required for these purposes it will be an obstacle for you to be included in the recruitment procedure and it will negatively affect your chances of being selected for the applied position.
We shall process your data for one or more of the following purposes:
- For completion of the recruitment procedure under which you are applying;
- To fulfill or meet our legal obligations;
- For the purposes of the legitimate interest of AQUA MATRIX LTD or of a third party;
When the data subject has given his/ her consent.
AQUA MATRIX LTD stores personal data of unsuccessful applicants for no longer than 6 (six) months after the recruitment process has been completed. We shall not store your data for a period longer than the required for the processing purpose. We store your data following the legally defined periods as well as considering the volume, specifics and sensitivity of the data, the processing purposes and whether we could complete them with different means.
Once we have met the purposes for which we process your data, or when there is no legal obligation and/ or legitimate interest, we shall erase or delete your data in a secure way.
AQUA MATRIX LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Companies providing internal audition services, suppliers of human resource management services, suppliers of accounting, legal, IT, banking, insurance, social security, social services and/or other services providers for the performance of contractual or legal obligations, as well as for the protection of the legitimate interest.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
AQUA MATRIX LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
1.3. Privacy Notices for Clients and Contracting Parties
AQUA MATRIX LTD processes its clients and contracting parties’ personal data in order to perform its contractual obligations and as described herein below.
The personal data of clients and contracting parties – individuals and/or employees and legal entities representatives, which we process are: names, EGN (unique personal identifier)/ date of birth or other ID number, address, contact data (telephone, e-mail, bank account).
The provision of these data by you is voluntary and in the same time essential in order a contract between you and AQUA MATRIX LTD to be concluded. In this respect, we inform you that we could fulfill our contractual obligation only if we are provided with the respective information. In the event that you are not willing to provide your personal data, we inform you that no contract could be concluded between AQUA MATRIX LTD and you.
We shall process your data for one or more of the following purposes:
- For the conclusion or execution of a contract;
- To fulfill or meet our legal obligations;
- For the purposes of the legitimate interest of AQUA MATRIX LTD or of a third party;
When the data subject has given his/ her consent.
The personal data that you have provided will be stored by AQUA MATRIX LTD in the period of the concluded contract. After its termination your personal data will be erased or deleted in a secure way except for the cases that there is a legitimate interest and/or a legal ground that obliges AQUA MATRIX LTD to maintain its storage and/or processing and/or the subject has given his/her consent for the additional storage.
AQUA MATRIX LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Companies providing internal audition services, suppliers of marketing and advertisement services, suppliers of accounting, legal, IT, banking and/or other services providers for the performance of contractual or legal obligations, as well as for the protection of the legitimate interest.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
AQUA MATRIX LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
1.4. Privacy Notices applicable to data processing in an online environment
The herein provided rules apply in special events of data processing in an online environment. Such events are these where contact forms, provided on the website of AQUA MATRIX LTD, are used by its visitors (including such that are not specified in any of the categories in item 1.1-1.3 above), as well as the cases of online registration for creating an account at the website of www.aquamatrix.bg and/or participation in events organized by AQUA MATRIX LTD (conference, games, competitions, etc.).
1.4.1 Data Administrator
We would like to provide you with information about the way we collect and process your personal data on the website www.aquamatrix.bg. The data administrator of the site (hereinafter referred to as "We", "Us") is "AQUA MATRIX" Ltd., ID: 203482454, responsible for protecting your personal data.
It is extremely important that the information we store about you is accurate and up-to-date. Please inform us if at any point there is a change in your personal information by clicking here to update your personal data in your user profile.
Please note - by providing your personal data, you confirm that you are over 13 years old. If this is not the case, you should immediately contact us so we can take actions to erase them.
AQUA MATRIX LTD processes the following personal data of the visitors of its website www.aquamatrix.bg that have used one of the contact forms and/or forms for online registration for creating an account at the website of www.aquamatrix.bg: names, e-mail, telephone number, organization and position in the respective organization, content of the request/the message or any other statement.
We would like to inform you that AQUA MATRIX LTD’s website uses ‘cookies’ by which it collects information about the behavior of its visitors, including personal data. More information about the ‘cookies’, including what type of ‘cookies’ we use, etc. could be found in our Cookies Policy (click here).
In addition, it should be noted that there are buttons on the website of AQUA MATRIX LTD providing links to other sites, social networks, etc. that lead to profiles of AQUA MATRIX LTD in the respective social networks. In the event that you are willing to use one or more of them, you shall consider the fact that by this action we will be provided with information about your participation in the respective social media.
The mentioned personal data are voluntarily provided by you and in the event that you are not willing to provide us with them, you shall be informed that you would not be able to use the functionality of the contact forms on our website and/or forms for online registration for creating an account, as well as some of the functionalities of our website.
AQUA MATRIX LTD processes the provided personal data for the following purposes:
- To process your request/ message or any other statement as well as to reply to it;
- For the conclusion of a contract (provided that your request/ message or any other statement falls under the respective conditions);
- For the purposes of the legitimate interest of AQUA MATRIX LTD or of a third party;
When the data subject has given his/ her consent.
AQUA MATRIX LTD shall not store your data for a period longer than the required for the processing purpose. We store your data following the legally defined periods as well as considering the volume, specifics and sensitivity of the data, the processing purposes and whether we could complete them with different means.
Once the purpose for which your data have been processed are met, or once there is no legal obligation and/or legitimate interest, we shall erase or delete your data in a secure way.
AQUA MATRIX LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Suppliers of marketing and advertisement services; suppliers of legal services and to other services suppliers for the fulfillment of contractual or legal obligations, as well as for the safeguard of its legitimate interest.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
AQUA MATRIX LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
1.4.2 What data we collect about you, for what purpose and on what basis we process it
Personal data is any information that can identify an individual. Anonymous data is not included in this category. We process the following categories of personal data:
• Communication data
Includes every message you send to us, whether it's through the communication form on our website, via email, message, or social media post, or any other type of sent message. We process these data for communication with you, for documentation purposes, and for establishing, executing, or defending legal claims. The legal basis for this processing is our legitimate interests, which in this case are responding to messages sent to us, documentation, and for conducting or defending legal claims.
• Customer data
Includes data related to the purchase of goods and/or services, such as your name, billing address, delivery address, email address, other contact data (phone number), statistics about your purchases, and others. We process these data to deliver goods and/or services purchased by you and to keep records of such transactions. The legal basis for this processing is the execution of a contract between you and us and/or taking steps at your request to enter into such a contract.
• User data
Includes data about how you use our website and other online services, along with all data you post on our website or through other online services. We process these data to manage our website and ensure that we provide you with appropriate content, to guarantee its security, to maintain backups of our website and/or database, and to be able to manage and administer our website, other online services, and business. The legal basis for this processing are our legitimate interests, which in this case allow us to properly administer our website and business.
• Technical data
Includes data related to your use of our website and online services, such as your IP address, login data, details about your browser, the duration of your visit to the pages of our website, page views and navigation paths, details about the number of visits to our website, time zone settings, and other technologies on the devices you use to access our website. The source of these data is our system for tracking analytics. We process these data to analyze the use of our website and other online services, to administer and protect our business and website, to provide appropriate content and advertisements, and to understand the effectiveness of our advertisements. The legal basis for this processing are our legitimate interests, which in this case will allow us to properly administer our website and business, to develop our business, and to determine our marketing strategy.
• Marketing data
Includes data related to your preferences for receiving marketing information from us and third parties, and your preferred method of communication. We process these data so that we can include you in our promotions, such as games, prizes, and free gifts, to provide you with adequate content and advertisements, and accordingly to understand the effectiveness of these ads. The legal basis for this processing are our legitimate interests, which in this case will help us to research how customers use our products/services, to develop them, to develop our business, and to determine our marketing strategy.
We may use Customer Data, User Data, Technical Data, and Marketing Data to provide you with adequate content and advertisements (including ads on Facebook or other advertisements) and accordingly to understand the effectiveness of the provided ads. The legal basis for this processing are our legitimate interests, which are related to growing our business. We may also use these data to send you other marketing messages. The legal basis for this processing is either consent or lawful interests (namely growing our business).
• Sensitive Data
We do not collect any sensitive data about you. Sensitive data are data related to your race or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political views, trade union membership, information about your health, genetic and biometric data. We do not collect information about criminal convictions and offences.
Please note - when we are required to collect personal data by law or according to the terms of a contract between us and you do not provide these data upon request, we may not be able to execute the contract (e.g., to deliver goods or services to you). If you do not provide the requested data, we may have to cancel a product you have ordered, but if we do, we will notify you in time.
We will only use your personal data for the purpose for which they were collected or if necessary for a purpose closely related to the main one. For more information, please write to us at contactus@aquamatrix.bg. In case we need to use your data for an unrelated new purpose, we will notify you by outlining the legal reasons for our actions.
We may process your personal data without your knowledge or consent, but only within the limits allowed by law. We do not carry out automated decision-making or automated profiling.
1.4.3. Methods of collecting your personal data:
• Provided personally by you (for example, by filling out forms on our site or by sending emails);
• Automatic collection of certain data received from you when you use our website, through the use of cookies and other similar technologies. More information about what cookies are, what types we use, etc. can be obtained by reviewing our Cookie Policy, available here.
• We may receive data from third parties, such as: analytics providers (e.g., Google), based outside the EU; advertising networks (e.g., Facebook), based outside the EU; search information providers (e.g., Google), based outside the EU; providers of technical, payment, and delivery services, information brokers, or aggregators.
1.4.4. Marketing Communications
The legal basis for processing your personal data for marketing communications is: Your consent or our legitimate interests (for example - to expand our business).
According to the legal provisions for the protection of personal data and electronic communications, we may send you marketing messages if:
(A) you make a purchase, register on our site, or make an inquiry to us regarding our goods or services; or
(B) you have agreed to receive marketing messages, and in both cases, you have not explicitly refused to receive such messages. According to the legal provisions, if you are a legal entity, we may send you marketing emails without your consent. In this case, you may also refuse to receive marketing emails from us at any time.
Before we share your personal data with third parties for their marketing purposes, we will ask for your explicit consent.
You may request us to stop sending you marketing messages at any time by emailing us at the address you receive notifications from us, and select the appropriate fields/options in the email to adjust your marketing preferences contact us at email: contactus@aquamatrix.bg.
Please note - if you refuse to receive marketing messages, this refusal does not apply to personal data provided as a result of other transactions such as purchases, warranty records, etc.
1.4.5. Sharing your personal data
We may share your personal data with the following parties:
• Service providers that provide IT services and system administration;
• Professional consultants, including lawyers, bankers, auditors, and insurers;
• Government authorities that require us to report processing activities;
• Courier companies;
• Third parties who acquire or merge parts of our business or assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it according to the law. Third parties may process your personal data only for specific purposes and in accordance with our instructions.
1.4.6. Data Security
We have implemented security measures to prevent accidental loss, use, alteration, disclosure, or access to your personal data without authorization. We provide access to your personal data only to those employees and partners who have a business need to use such data. They are instructed to process your personal data according to our instructions and to comply with confidentiality rules.
We have a procedure for dealing with suspected personal data breaches and will notify you and the relevant regulators of such breaches when and where necessary.
1.4.7. Data Retention
We will keep your personal data for as long as necessary to fulfill the purposes for which we collected them, or with a view to satisfying legal, accounting, or reporting requirements.
When deciding how long to store these data, we assess their amount, nature, and sensitivity, the potential risk of unauthorized use or disclosure, and the purposes of processing, as well as whether they can be achieved through other means and legal requirements.
Please note - tax laws require us to keep basic information about our customers (such as contact, identity, financial data, and transaction data) for up to ten years after you cease to be our customers.
Under certain circumstances, we may anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without notifying you.
1.4.8. Your Rights
Under the laws for the protection of personal data, you have rights regarding your personal data, which include the right to request access, correction, deletion, restriction, transfer, object to processing, data portability, and (when the legal basis for processing is consent) to withdraw your consent.
Learn more about these rights at the following address: https://www.cpdp.bg/?p=rubric&aid=2
If you wish to exercise any of the above rights, please contact us at: contactus@aquamatrix.bg.
There is no fee for accessing your personal data (or to exercise any other rights). However, the law allows us to impose a reasonable fee if your request is clearly unfounded, repetitive, or excessive, or if it is not compatible with your request under the above circumstances.
We may need to request specific information from you to confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This security measure ensures that your personal data is not disclosed to people who do not have the right to receive it. We may also contact you to request additional information regarding your request, to expedite our response.
The deadline for responding to all legitimate requests is one month. If your request is particularly complex or you have made several requests and we cannot respond within a month, we will notify you.
If you are not satisfied with the way your data is collected and used, you have the right to lodge a complaint with the Personal Data Protection Commission (https://www.cpdp.bg). We would be grateful if, in case of an objection or complaint, you first contact us to find a way to resolve the issue.
1.4.9. Third-Party Links
This website may include links to other websites, plugins, and third-party applications. Clicking on these links or activating them may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy statements. When you leave our website, we recommend you read the privacy notice of every website you visit.
1.4.10. Cookies
You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please be aware that some parts of this website may become inaccessible or not function properly. For more information about what cookies are, the types we use, etc., you can familiarize yourself with our Cookie Policy, available here.
1.4.11. AQUA MATRIX LTD processes the following personal data of persons that have expressed their intention to participate in conferences, games, competitions, and other events organized by AQUA MATRIX LTD by an online registration: name and family name, e-mail, telephone number, organization and position in the respective organization.
The provision of these data by you is voluntary and in the same time essential in order for you to take part in the organized conferences, games, competitions or other event. In connection with that we inform you that AQUA MATRIX LTD could only fulfill its obligations if you have provided us with the respective personal data. In the event that you are not willing to provide us with these data, we inform you that AQUA MATRIX LTD could not be able to list you as a participant of the organized event (conferences, games, competitions or other).
In addition, you should bear in mind that depending on the specific case the online registration could be performed through the opportunities provided by the social networks, etc. If you are willing to use them, you shall be informed that this will provide us with information about the social networks you take part in.
We shall process your data for one or more of the following purposes:
- For the conclusion or execution of a contract (for your participation in the respective event – conferences, games, competitions, etc.);
- To fulfill or meet our legal obligations;
- For the purposes of the legitimate interest of AQUA MATRIX LTD or of a third party;
When the data subject has given his/ her consent.
The provided personal data will be stored by AQUA MATRIX LTD until it is needed for the fulfillment of the purposes for which they are collected. After that your personal data will be deleted or erased in a secured way, except for the cases when there is a legitimate interest and or legal ground that obliges AQUA MATRIX LTD to maintain their storage and/or processing and/or a consent for additional storage for fulfillment of additional purposes has been given by the subject.
Once the purpose for which your data have been processed are met, or once there is no legal obligation and/or legitimate interest, we shall erase or delete your data in a secure way.
AQUA MATRIX LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Companies providing internal audition services, suppliers of marketing and advertisement services; suppliers of accounting, IT, legal, banking and/or other services suppliers for the fulfillment of contractual or legal obligations, as well as for the safeguard of its legitimate interest.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
AQUA MATRIX LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
2. Rights of the Data Subjects
We would like to inform you that you have the right to require from AQUA MATRIX LTD access to personal data, right to rectification or erasure of personal data, restriction of the processing of the provided data, the right to object to the processing, the right of personal data portability, as well as the right not to be a subject to a decision based solely on automated processing These rights could be exercised by sending an explicit request in this respect to the following e-mail: orders@aquamatrix.bg or in writing to the following address: Sofia, 1000, 31 Ekzarh Yosif Str, fl. 3;
In those cases when processing is based on a consent, you have the right to withdraw your consent at any time. The withdraw can be done by explicit notification sent to the following e-mail: orders@aquamatrix.bg or in writing to the following address: Sofia, postal code 1000, 31 Ekzarh Yosif Str, fl.3. It shall be noted that this will not affect the validity of the processing prior to the withdrawal of consent.
In the event that you assume that AQUA MATRIX LTD violates your legal rights regarding the collecting, processing and storage of the provided personal data, you may contact the Personal Data Protection Commission or the competent courts as you have a right to file a complaint in which you can submit your complaints.
3. Changes of the Privacy Notices
This Notices of AQUA MATRIX LTD are effective as of 25 May 2018, they could be revised periodically for which you will be notified in due time through an e-mail or in another appropriate way.