Effective as of 25.05.2018
This Privacy Notice describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access, use and interaction with our Promotional Campaigns (“Campaigns” or “Promotional Events”). For the purposes of this Privacy Notice, Campaigns means any activity, undertaken by us, in order to popularise or otherwise promote our services, by organising and processing personal data of participants and/or visitors of any public event, campaign, competition, promotion, seminar, webinar, show, expo, open days or similar hosted in real or online.
When this notice mentions “we,” “us,” or “our,” it refers to myPOS Services OOD, Bulgaria, bearing registration number 204713889, registered address Business Park Varna No. B1, Varna, Bulgaria (the “Data Controller”).
We give utmost importance to the protection of personal data of our customers. In the following Privacy Notice, we shall provide you with the information required under art. 13 and 14 of GDPR.
The ultimate liability lies with the respective Data Controller and you should address all your questions to the respective Data Controller via the contact details specified below.
You are informed that there are three general categories of information that is collected from you differentiated on grounds as defined by the Regulation 2016/679 and other applicable data protection national laws.
1.1 Information That We Collect In Order To Organize and Perform the Campaign/Promotional Event for you.
We ask for and collect from you the following personal information when you interact with our Campaign.
This information is necessary for adequate communication with you and in order to comply with the Terms and Conditions of any of the Campaigns, which we may introduce. Without it, we may not be able to provide you effectively with the Campaigns in which you wish to participate or register for.
1.2 Information That We Collect With Your Consent
You may choose to provide us with additional personal information in order to obtain a better user experience when interacting with our Campaigns, or in order to participate in some parts of our events, give-aways, or similar. Where we process information based on consent, such information and the processing activities and purposes shall be explicitly outlined in the consent form.
This additional information will be processed based on your consent, only for the abovementioned.
1.3 Information We Collect from Your Participation in the Campaigns.
When you participate in our Campaigns, we may collect information, including personal information, about how you interact and how you use them. This information is necessary given our legitimate interest in being able to provide and improve our services, measure our advertising and publicize our Campaigns.
Please be advised that when you participate in our Campaigns, we automatically collect some of the personal information described in the sections above.
We use, store, and process information, including personal information, about you to provide, understand, improve, and develop our Campaigns, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.
Processing may entail one or more of the following activities:
We process this information given our legitimate interest in improving our Campaigns, protecting our Campaigns, to measure the adequate performance of the terms and conditions of our Campaigns, comply with applicable laws, and where it is necessary for the adequate performance of a relationship with you or where applicable, given your consent.
Where the processing is based on consent, you have the right to opt-out from processing your personal information for those purposes by withdrawing your consent at any time and free of charge.
3.1. With other members of myPOS corporate family: We may share your Personal Data with members of the myPOS Group of companies or within our extended family of companies that are related by common ownership or control, so that we may provide the services you have requested or authorised or to manage the risk, or to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of Campaigns.
3.2. With third party service providers: We may share personal information with third party service providers that support us in providing our Campaigns with functions at our decision and on our behalf.
These third-party service providers may for example:
These providers have limited access only to your information necessary to perform the tasks for which they were contracted for on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Notice.
3.3. With other third parties for our legitimate interest or as permitted or required by law: We may share information about you with other parties for our legitimate interest or as permitted or required by law, including:
With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.
In addition, we may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why users have interacted with our Campaigns. This data will not personally identify you or provide information about your use of our Campaigns. We do not share your Personal Data with third parties for their marketing purposes without your consent.
3.4. Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
We may monitor or record emails, web chat or other communications with you for regulatory, security, customer services or training purposes.
3.6 Business Transfers.
If any of the companies that support the Campaigns is involved in any merger, acquisition, reorganization, sale of assets, transfer of portfolio, bankruptcy, or insolvency event, then we may sell, transfer or share some or all our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred to a different legal person and/or becomes subject to a different privacy notice.
You may exercise any of the rights described in this section before the respective Data Controller by sending an email. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.
4.1 Managing Your Information.
You have the right to obtain the following:
4.2 Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to our Campaigns).
4.3 Data Access and Portability.
You have the right to:
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.
4.4 Data Retention and Erasure.
We generally retain your personal information for as long as is necessary for the performance of the our relationship with us, for the purposes of our legitimate interests, and to comply with our regulatory obligations. If you no longer want us to use your information, you can request that we erase your personal information. Please note that if you request the erasure of your personal information:
4.5 Withdrawing Consent and Restriction of Processing.
Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.
4.6 Objection to Processing.
In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact e-mails below.
4.7 Lodging Complaints.
4.7.1. You should in first place try to resolve the matter by sending an e-mail to:
Data Protection Officer (DPO):
myPOS Services OOD,
Business Park Varna No B1, Varna 9023, Bulgaria
4.7.2 Competent Regulator. In case you are not satisfied with the reply or resolution of the respective Data Controller, you have the right to lodge complaints about the data processing activities carried out by us before the competent data protection supervisory authorities as described below.
To facilitate our global operations, we may be required to transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Notice. Where we transfer store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.
6.1 EU-US & Swiss-US Privacy Shield.
Where we disclose any of your collected personal information outside EEA to USA (if applicable), we shall comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework and any other adequacy decision.
6.2 Other Means to Ensure an Adequate Level of Data Protection.
In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in absence of an adequacy decision, we have - prior to sharing your information with such corporate affiliate or third-party service provider – established the necessary means to ensure an adequate level of data protection. We will provide further information on the means to ensure an adequate level of data protection on request.
We take the responsibility to ensure that your personal information is secure, kept in an encrypted from on servers, collocated in Special data centres in Class A jurisdictions in Europe. To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard non-public personal information. Once you are logged into your Account, all internet communication is secured using Secure Socket Layer (SSL) technology with High-grade security Encryption (AES-256, 256 bit keys, certified by StartCom Ltd). We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.
Our Campaigns, unless explicitly stated in the Terms and Conditions, are not designed to individuals under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to participate in our Campaigns. If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.
We reserve the right to modify this Privacy Notice at any time in accordance with this provision. If we make changes to this Privacy Notice, we will post the revised Privacy Notice on our Campaigns page or premise. If you disagree with the revised Privacy Notice, you may inform us at the contact details specified herein above.
If you have any questions or complaints about this Privacy Notice or our information handling practices, you may email us from your registered e-mail for the Services to the e-mails stated above in Section 4.