Privacy
Policy
The security of the data you have entrusted to us is very important to us. It is of great importance to the success of our business and to our public image. That is why we protect your data by applying all appropriate technical and organizational means at our disposal to prevent unauthorized access, unauthorized or malicious use, loss or premature deletion of information.
We collect and process personal data only in compliance with the requirements of local and European legislation. We are aware that the processing of your data is related to a specific reason and cannot be carried out without limitation.
These Terms of Use govern your use and participation in the LIFTKOM AD loyalty program. When you join the LIFTKOM AD loyalty program or take advantage of the benefits of the program, you agree to these terms.
Data that identify the administrator and contact details: The administrator of the personal data provided by the client is:
LIFTKOM AD, EIK: BG 202155371, with registered office and management address: Bulgaria, Sofia 1000, Lozenets district, ul. Kr. Sarafov " No. 45 office 1, phone: 02 49 50 493, with headquarters of the elevator factory LIFTKOM AD: Shumen, Rishki Prohod Blvd. No. 219, phone: 054 831 855, e-mail: office@liftkom.com
1. Personal data
According to the Regulation, personal data is any information that relates to you and by which you can be identified. Processing of personal data (“Processing”) is any action or set of actions that may be performed with respect to personal data by automatic or other means.
In connection with the Services provided, the Program Organizer processes information regarding the following categories of data:
• Name and surname;
• Phone number;
• e-mail address;
2. Processed data in connection with the provision of the Services
2.1. Information You Provide
You decide whether and how to use the Services provided through participation in the Program. In the forms through which personal data is entered, the Organizer clearly indicates the mandatory or voluntary nature of providing the data. The data, the filling of which is mandatory, are those without which it is impossible to provide the relevant Service or part of it.
a/ Registration - The use of the privileges described in "Levels in the Program" of the General Terms and Conditions of the Program is possible after registration. To register in the Program, you need to enter: first name, last name, email address and phone number.
b/ Data stored in your account - The privileges that you will be able to benefit from as a participant in the Program require the storage in your account of information about your purchases in the Organizer's stores. The organizer stores and processes this information, as well as the result of this processing.
c/ Correspondence, complaints and alerts - In order to resolve submitted complaints, alerts, disputes, inquiries, requests or other issues addressed in communication to the Organizer, received through electronic forms on the Site, through calls to the Organizer's telephone exchange, by sending via regular or e-mail, the Organizer stores and processes this information, as well as the result of this processing.
d/ Special categories of (sensitive) data - The Organizer's services and privileges, as a participant in the Program, are not intended for the storage and processing of special categories of data within the meaning of Art. 9 and Art. 10 of the Regulation.
e/ Other data – The Organizer may also process other data relating to a participant in the program, in cases where the participant voluntarily provides such data by filling in relevant electronic forms on the Site or answering surveys, etc.
3. Purposes for processing personal data
The Organizer collects, uses and processes the information described above for the purposes provided for in this Policy and in the Terms, which may be:
3.1 Loyalty Program Registration
These are the purposes necessary for the steps of concluding and executing the contract between the Participant and the Program Organizer, including the data processing necessary for this when registering, creating an account and the activities related to the provision and use of special privileges of the Program, also available through The site. In addition, these purposes include communicating with the Participant, including by e-mail and SMS, necessary in connection with the provision of the Services and/or notifying the Participant of changes in the Services provided. For this purpose, it may be necessary to process some or all of the above categories of data.
3.2 Legitimate Interest
These are goals related to legitimate interests of the Organizer and/or third parties, such as other users, etc. These goals include:
• Ensuring the normal functioning and use of the Site by a participant in the Program and by other users, maintenance and administration of the Services, resolution of disputes, detection and prevention of malicious actions.
• Detecting and resolving technical or functionality issues, developing and improving the Services.
• Communicating with the Participant, including electronically, on important matters related to the Services.
• Receiving and processing received signals, complaints, requests and other correspondence;
• Implementation and protection of the rights and legal interests of the Organizer, including by court order, and assistance in the implementation and protection of the rights and legal interests of other participants in the Program and users of the site and/or affected third parties.
For these purposes, it may be necessary to process some or all of the above categories.
3.3 Legal Obligations
The objectives related to compliance with the Organizer's legal obligations include the fulfillment of obligations provided for in the law to preserve or provide information upon receipt of a relevant order from competent state or judicial authorities, providing an opportunity to exercise the control powers of the competent state authorities, in fulfilling the legal obligations of the Organizer to notify the participants of various circumstances related to their rights, the Services provided or the protection of the data of the participants, etc. under. For these purposes, it may be necessary to process some or all of the above categories.
3.4 Express Consent
The data of the participants in the Program can be processed on the basis of their express consent, and the processing in this case is specific and to the extent and scope provided for in the relevant consent.
• Electronic newsletter subscriptions – Receives at the e-mail address specified by the participant notifications about new goods/services, promotions, current offers, marketing research and sending advertising materials;
• Subscriptions for text messages (SMS) – Receiving to the phone number specified by the participant notifications about new goods/services, promotions, current offers, marketing surveys and sending advertising materials;
• Preparation of proposals for products/services of the Organizer suitable for the participant;
• Preparation of proposals for products/services from the Organizer's partners suitable for the participant.
The legal basis for the processing of personal data is Art. 6, paragraph 1, letter a) of Regulation (EU) 2016/679, namely - the data subject has given consent to the processing of his data for the purposes expressly indicated;
The processing of personal data provided by a person registered in the Program by filling out a registration coupon for registering in the Program includes the following activities: collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, distribution or other way in which the data is made available, arranged or combined, restricted, deleted or destroyed by automatic or other means.
4. Provision of information
Access to your personal data is limited to what is necessary.
4.1. Suppliers and subcontractors
The organizer uses subcontractors and service providers such as specialized data centers for reliable and secure collocation of server and network equipment, etc. When working with subcontractors and suppliers, the Organizer requires them to strictly follow our instructions, in accordance with the present Policy and Terms. Participants' personal information may be sent to and stored in countries outside the country that are also outside the European Economic Area and the United Kingdom.
4.2. Third parties
The personal data of the participant of the program can be provided to third parties only in the following cases: when this is provided by law; if duly requested by a competent government or judicial authority; when the Organizer received the participant's express consent for this; when this is required to protect the rights and legal interests of the Organizer and/or other users of the Services.
4.3. Ownership and change of ownership
The owners of the Organizer, when exercising their ownership rights, can familiarize themselves to the necessary extent with the personal data communicated by a participant in the Program; In the event of a merger, acquisition or sale of assets affecting the processing of personal data, you will be notified in advance.
5. Storage period
The storage and processing of the data of a participant in the Program applies for the duration of the client program. Upon termination of the client program, the Organizer destroys the personal data or anonymizes them within a period of no longer than thirty days in compliance with the current regulatory requirements in this regard;
In the event of a legal dispute or proceeding requiring the retention of data and/or a request from a competent state authority, it is possible to retain data for longer than the specified periods until the final conclusion of the arising dispute or proceeding before all instances. The stated terms may be changed in the event that a different requirement for the retention of information is established under current legislation.
6. Rights in relation to personal data
The Regulation provides for the following rights:
6.1. Right to information.
This Policy aims to inform Program participants in detail about the processing of their personal data in connection with the Services provided.
6.2. Right of access.
The participant in the program has the right to request and receive confirmation from the Organizer whether his personal data is being processed, access to them and information about their processing and the rights of the participant in the program in connection with this, according to the procedure and under the conditions described in art. 15 of Regulation (EU) 2016/679;
6.3. Right to rectification.
The participant in the program has the right to demand from the administrator to correct the personal data processed by him, in case they are incomplete or inaccurate, according to the procedure and under the conditions described in Art. 16 of Regulation (EU) 2016/679;
6.4. Right to erasure.
The participant in the program has the right to request the deletion of data, except in cases where there is a substantial reason and/or legal obligation for their processing, according to the procedure and under the conditions described in Art. 17 of Regulation (EU) 2016/679;
If he wishes, the participant in the program has the opportunity to close his account at any time, in the commercial network of the Organizer or by mail, at the address: office@liftkom.com.
Upon opting out of the Program, the Participant's account, along with all of its data and accumulated amounts, will be deleted within 10 business days of sending the opt-out.
• In order to resolve possible disputes that arose or became known after the termination of the agreement for the use of the Services, for a period of 1 /one/ year after the termination of the account, information about its conclusion is stored. See section "Storage period".
6.5. Right to restriction in connection with data processing, if there are grounds for this provided for in the Regulation.
6.6. Right to data portability.
The Participant in the Program has the right to receive the personal data he/she has provided that relates to him/her in a structured, popular, machine-readable format, and to use such data for another controller at the Participant's discretion.
Important: Responsibility for the storage of exported data, as well as for all consequences of providing it to other administrators, rests entirely with the program participant.
6.7. Right to withdraw consent.
The participant in the Program has the right to withdraw his consent to the processing of his personal data at any time. The withdrawal of the consent of a participant in the Program does not affect the lawfulness of the processing before the withdrawal. The withdrawal of the consent of a participant in the Program can be done in the commercial network of the Organizer or by mail, at the address: Sofia 1000, Lozenets quarter, str. Kr. Sarafov " No. 45 office 1, phone: 02 49 50 493, with headquarters of LIFTKOM AD elevator factory, Shumen, 219 Rishki Prohod Blvd., phone: 054 831 855, e-mail: office@liftkom.com.
In the case of services such as the subscription to e-mail or SMS announcements, for which the subscription is based on the participant's desire (consent), the possibility to terminate the subscription at any time (withdrawal of consent) is provided.
The organizer will not be able to ensure the use of the customer number as intended, therefore the withdrawal of consent is treated as a cancellation of the customer contract. Withdrawal of consent to data processing for the purpose specified in item 3.4 hereof will result in the Organizer not being able to send the Program participant messages and publications for advertising, marketing and commercial purposes, as well as contact with him on matters related to the loyalty program electronically, at the e-mail indicated by the participant in the application. Withdrawal of consent to data processing for the purpose specified in item 3.4 will result in the Organizer not being able to contact the Program participant on issues related to the loyalty program on the phone specified by the participant, as well as sends sms messages and messages through the Viber application for advertising, commercial and marketing purposes.
6.8. Right to object.
The participant in the Program has the right to object to the processing of his personal data.
In case of receiving such an objection, the Organizer will consider the received request and, if it is justified, will fulfill it. If it considers that there are compelling legal grounds for the processing or that it is necessary for the establishment, exercise or defense of legal claims, it will inform the participant thereof.
6.9. Right of appeal to a supervisory authority.
The participant in the Program who believes that there has been a violation of the rules for the protection of personal data, can submit a complaint to the Commission for the protection of personal data, with the address: Sofia 1592, Blvd. "Prof. Tsvetan Lazarov" No. 2.
6.10 Providing the specified personal data is a requirement necessary for registering a participant in the Program. When applying for participation in the Program, the applicant must fill in all personal data specified in the Registration Application, as well as note that he agrees to the processing of his personal data for his participation in the LIFTKOM AD loyalty program on his behalf. If these fields are not filled in, the Organizer is not obliged to enroll the participant in the Program.
7. Existence of automated decision-making, including profiling and essential information about the logic used, as well as the meaning and intended consequences of this processing for the data subject:
The organizer sends an automated email message in the following cases:
a/ within two weeks after the participant has joined the Policy for the Protection of Personal Data of Individuals - end users.
8. The Data Protection Officer
You can address questions and requests related to exercising the rights to protect personal data of a participant in the Program to the Data Protection Officer of the Organizer.