RAYTRON PRIVACY POLICY


1.Introduction

 Raytron Group Ltd. respects the privacy of its customers and ensures the maximum protection of their personal data. This Privacy and Data Protection Policy (hereinafter referred to as "Privacy Policy") has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection.

This Privacy Policy governs the processing of personal data of individuals or representatives of legal entities of our customers or prospective customers and users of our websites:www.raytron.eu, www.hotellobg.eu и www.smartisimo.eu , referred to as (the "Site"), in connection with the services provided by Raytron Group, including those provided through and accessible on the Site.

This Privacy Policy, together with the Site Terms of Use and Cookie Policy and any other documents referred to on the Site, sets out the rules that the Raytron Group will follow when processing personal data that we collect from or about you, or that you provide to us. This Privacy Policy does not affect, restrict or derogate from your rights under the Personal Data Protection Act ("PDPA") or other relevant legislation.

If you have any questions or comments about this Privacy Policy, please contact us at: info@raytron.eu

Please read this Policy carefully before using the Site or providing your Personal Data, whether electronically on the Site or on paper, as by providing your Personal Data you agree to its terms. If you do not want us to process your Personal Data in the manner described in this Privacy Policy, please do not provide it to us. Your provision of Personal Data is voluntary in order to use certain services provided by us and to use and/or access the Site. Please note that in some cases we will not be able to provide you with the service or goods you have requested if you do not provide us with the required information.

 II. II. Who processes and is responsible for your personal data?

Raytron Group Ltd ("Raytron Group", "we") is the commercial company registered in the Commercial Register of the Registry Agency with UIC 131186415, which collects, processes and stores your personal data under the terms of this Privacy Policy. Raytron Group is a personal data controller within the meaning and the Personal Data Protection Act (PDPA). You can contact us at any of the following contact details:

 Office: 1527, Sofia, Str. Hristo Kovachev №3

 Phones: 02 /492 8885; 0899188819

 e-mail: info@raytron.eu

  II. Categories of personal data processed by Raytron

 1. Raytron Group may process publicly available personal data and/or personal data provided by you. The main types of personal data processed are:

  • Personal identification information (including name, ID number, residence, nationality, language of communication, etc.);
  • Information about the field of activity (including education, educational institution, workplace, position held, etc.);
  • Contact details (including postal and e-mail addresses, telephone and fax numbers, etc.);
  • Financial information (bank account, etc.);
  • Information about a representative (legal representative or proxy of such) of a legal entity client;
  • Data from communication between us and you, your habits, preferences, satisfaction with our services (activity in using the services, complaints, requests, etc.);
  • Information regarding visits to and use of the Site, including Site operations and usage history;
  • Data obtained in the performance of obligations arising from regulations (i.e. data arising from inquiries, regulations, investigative authorities, notary, tax services, court, bailiff);
  • The data obtained in the performance of the contractual obligations (including name, PIN, address, telephone and/or e-mail address, etc.).

  • Data when creating an account on the Site (name, email address, phone number, address).

2. Raytron Group may process data prepared and generated by Raytron in the process of providing the Services:

  • Details of the terminal electronic communications device used, type of device, operating system used, IP address, location;
  • ​Details of your preferred goods and services.

3.  In order to ensure the proper performance of services and obligations arising from customer contracts, Raytron is entitled to process any information available in public records (including public databases and data published on the Internet) as well as information obtained from third parties in connection with the implementation of legal provisions concerning customers.

4. Raytron Group has the right and obligation to verify the accuracy of the personal data recorded in the database, requiring you to verify the data and, if necessary, to correct or confirm the accuracy of your data.

5. The different types of personal data may be processed individually or in combination.

 IV. Purposes and legal grounds for processing personal data 

1.  Processing of personal data which is necessary for entering into or performance of contracts with us or in connection with preparation for entering into contracts with us.


Raytron Group processes your data for the following purposes:

  • Identification of a client when: concluding a new or amending an existing contract with us; clarification of the services used; performance of a concluded contract.
  • Preparation of contract proposals, submission of pre-contract information and draft contract;
  • Data obtained from you in the performance of obligations arising from contracts concluded with you or a company represented by you, the exercise of rights and the enforcement of contracts by our customers;
  • Handling and responding to customer complaints/inquiries/complaints/complaints;
  • Technical assistance in creating account(s) and recovering forgotten password(s) for access to our Site, for electronic invoicing.
  • Technical support and troubleshooting of faults and any technical issues - on site and through remote access to your equipment.
  • Payment of debts, rescheduling of amounts due;
  • ​Warranty and service.

2. In compliance with legal obligations, Raytron Group processes your data for the following purposes: 

  • Issuing invoices;
  • For tax and social security control by the competent authorities;
  • Obligations stipulated in the Accounting Act and the Tax and Social Security Procedural Code and other related legal acts in relation to keeping proper and lawful accounting.

3. The Raytron Group processes the relevant data provided with the customer's explicit written consent for their processing for the following purposes:

  • Data when creating an account on the Site;
  • For direct marketing of products and services;
  • E-newsletter;
  • ​Data provided by you when participating in sweepstakes, surveys, games, etc.

4. The processing is necessary for the purposes of the legitimate interests of the Raytron Group.

  • Evaluate and establish consumer satisfaction as well as advertising effectiveness;
  • ​Analysis of purchase history data, customer preferences and behaviour.

V. Categories of third parties who access and process your personal data

  1. Transport/courier companies, postal operators in order to fulfil our contractual obligations, send correspondence and communications in connection with the contract between us;
  2. Persons who, on behalf of Raytron Group, maintain equipment and software used to process your personal data;
  3. Debt collection service providers, notary, lawyer, bailiff or other third party if the customer has breached an obligation arising from a contract with us;
  4. The banks handling payments made by you;
  5. Persons to whom the Raytron Group has outsourced the performance of part of the activities or obligations related to a specific service we owe to you;
  6. Persons providing consultancy services in various fields - lawyers, accountants, etc.;
  7. ​Bodies, institutions and persons to whom we are obliged to provide personal data under applicable law.

VI. For how long is your personal data stored?

The duration of storage of your personal data depends on the purposes of the processing for which it was collected:

 1. Personal data processed for the purpose of concluding/amending and executing contracts between Raytron Group and you or a company represented by you - for the duration of the contract and until final settlement of all financial relations between the parties. Raytron may also store some of your personal data for a longer period until the expiry of the relevant statute of limitations in order to protect itself in the event of any customer claims in connection with the performance/termination of contracts with us, as well as for a longer period in the event of a legal dispute that has already arisen until its final resolution by a final court/arbitration decision.

2.   Personal data processed for the purpose of issuing accounting/financial documents for tax and social security control, such as, but not limited to, invoices, debit and credit notes, acceptance protocols, contracts for the provision of services/goods shall be kept for at least 11 years after the expiry of the limitation period for the repayment of the public claim, unless the applicable legislation provides for a longer period.

3. Personal data processed for direct marketing purposes - until the explicit withdrawal of the consent given for direct marketing or receipt of an objection to the processing of personal data for direct marketing.

4. Personal data when creating a profile on the Site - until the explicit withdrawal of consent or receipt of an objection to the processing of personal data from the profile on the Site.

5. Photography and/or video data provided by you when participating in sweepstakes, surveys, games, etc. - until you explicitly withdraw your consent or receive an objection to the processing of personal data.  

VII. Your Rights in Relation to the Processing of Your Personal Data 

1.General rights 

in relation to the processing of personal data, you have the following rights, which you can exercise at any time while we are storing or processing your personal data, by sending an application to the Raytron Group address listed above, or by email to: info@raytron.eu


You have the right to ask us:

  • A copy of your personal data and access to it at any time;
  • To correct, without undue delay, your inaccurate personal data as well as data that is no longer up to date;
  • Your personal data in a form convenient for transfer to another data controller, or request that we do so without being prevented from doing so by us (right to portability);
  • Your personal data will be deleted without undue delay if any of the legal grounds for doing so exists;
  • To restrict the processing of your personal data, in which case your data will only be stored but not processed. Our refusal to restrict will only be expressly in writing, and we are obliged to justify it with the lawful reason.


You are entitled too:

  • To withdraw your consent to the processing of your personal data at any time by a separate request addressed to the Raytron Group, in the case of consent-based processing;
  • To object to the processing of your personal data;
  • To object to automated processing, including profiling;
  • ​Not be subject to a decision based solely on automated processing, including profiling.

2. You have the right to complain to the supervisory authority

You have the right to lodge a complaint directly with the supervisory authority, the competent authority being the Commission for Personal Data Protection, address. The authority responsible for the protection of personal data is. "1595 Prof. 2 (www.cpdp.bg).

In case you wish to lodge a complaint regarding the processing of your personal data by the Raytron Group, you may do so at the contact details of the Controller (at the contact details above).

3. Automated decision making

The controller does not use your personal data for automated decision-making. In the event that we intend to use your personal data for automated decision-making, you have the right to be informed of this and to receive information about the logic of any automated processing of personal data relating to you.

4. Objection to use for direct marketing. You have the right to object to future processing of your personal data for the purposes of direct marketing and advertising, as well as to their disclosure to third parties and their use on their behalf for the purposes of direct marketing and advertising, by withdrawing your consent at any time. For this purpose, you can send an e-mail with the corresponding request to stop using your data for direct marketing purposes to: info@raytron.eu 

5. Can you refuse to provide personal data to Raytron Group and what are the consequences of doing so? In order to enter into a contract with you and/or to provide you with the requested products and/or services and/or to deliver the ordered goods in accordance with our statutory and subsequently contractual obligations, Raytron needs certain data to identify the contracting party, its proxy, contact details, payment details. Failure to provide such data prevents us from concluding a contract with you. 

VIII. How we protect your data

Raytron Group implements organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and the monitoring of the processing of personal data.Among other things, such security measures include the following activities:

  • The Raytron Group has established rules for the processing, registration and storage of personal data with internal procedures, compliance with which is constantly monitored;
  • The access of employees of the Raytron Group to personal data and the authorization to process personal data in the database of the Raytron Group is limited, depending on their duties;
  • Access to Raytron Group office equipment and each employee's computers is restricted and is subject to identification;
  • We implement with all necessary organizational and technical measures provided for in the Data Protection Act as well as best practices of international standards;
  • ​In order to maximize the security of the processing, transmission and storage of your data, we may use additional protection mechanisms such as encryption, anonymization, etc.


The security measures we apply are subject to constant improvement and adaptation to the latest technologies.

IX. Link to other sites

Sometimes the Site may contain links/references (hyperlinks) to other sites. We do not operate the linked sites and do not endorse the content, services and products of those sites. We encourage you to use the linked sites with care and with due regard to their content and terms of use. Raytron Group is not responsible for the privacy policies or the content of these sites and we encourage you to review their privacy policies. However, as soon as Raytron Group receives information regarding illegal activities or illegal information on such websites, we will take immediate steps to remove electronic references (links) to them.

X. Cookies Policy 

To familiarize yourself with the Cookie Policy, please visit the page ​
​

XI. Personal data on children 

We do not knowingly collect personal information from children under the age of 16. If we learn that we have collected personal information from a child under the age of 16, we will take steps to delete the information as soon as possible or obtain the consent of the person with parental responsibility for the child.

XII. Amendments to the Privacy Policy

We may update our Privacy Policy from time to time. In the event of a change to this policy, a notice will be posted on our website as well as the updated Privacy Policy. Any changes or additions to the Privacy Policy will be implemented only after the updated Privacy Policy is posted and available through our Site.