Data Protection Policy

MTM Ltd.

The protection of personal data is of great importance to MTM EOOD, therefore we want the process of processing your personal data to be completely open and transparent to you. That is why we have a policy that defines how your personal data will be processed and protected.

This Personal Data Protection Policy (“Policy”) is issued pursuant to the Personal Data Protection Act and its by-laws, as amended (“Bulgarian Legislation”), and the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

Who is responsible for your personal data?

MTM is a Bulgarian sole proprietorship with limited liability (“MTM EOOD”) is the controller of the personal data you provide to us and is responsible for them, in accordance with the applicable personal data protection law. The personal data controller collects and processes certain information about individuals. This information may relate to employees, managers, customers, suppliers, contractors, business contacts and other individuals with whom the Controller has a relationship or wants to establish business contact.

MTM Ltd.

5 Petko Staynov Street

Varna 9009

Bulgaria

Protecting your privacy is important to us. We are committed to protecting all personal data, whether provided to us by individuals we work with, visitors and users of our website, or otherwise. Personal data is information that relates to an identified or identifiable natural person, which information identifies the natural person, either directly by name, postal address or email address, or indirectly, for example, by Internet Protocol (IP) address, telephone number, age range, etc. Personal data is obtained by tracking the use of the site or by voluntarily providing information to us, such as by filling out forms on the website.

This notice explains what personal and non-personal information we collect, both on this site and elsewhere; how we may use and manage it; and the rights you have in relation to your personal information. Before you provide us with any personal information or browse our website, you should read this notice in its entirety and make sure you agree with our privacy practices.

Please note that our site may contain links to other websites. These third-party websites are not subject to this notice and we recommend that you check the security and privacy policies of each website you visit. We are only responsible for the security and privacy of the personal data we collect through www.mtm.bg and do not control the actions of third parties in relation to your personal data.

Please see the glossary below for an explanation of the terms defined in this notice.

Whose personal data do we collect?

The Company collects personal data from a number of individuals in the context of its business activities, including from:

• employees;
• representatives of our suppliers, customers and other business partners
• subcontractors;
• users of our website;
• consumers;
• individuals who contact us in any way;
• job applicants.

How we collect your personal data

We receive personal data that you knowingly and voluntarily provide to us, both online and offline. For example, we collect personal data when you:

• visit our website and/or complete our web application form;
• contact us on any of the listed customer service numbers or request information from us in any other way;
• visit our premises;
• send us an application;
• provide us with your contact details via a business card or otherwise;
• complete a survey;
• communicate with us via social networking websites, third party applications or similar technologies;
• visit one of our trade stands at an exhibition, fair, etc.

We may also collect information obtained from third-party sources related to your use of other websites we operate or from related third-party subcontractors.

What personal data do we collect?

The Company may collect a range of personal data from you, such as your name, gender, job title, photographic identification, email address, telephone number, home or business address and other contact details, details of your interests, communications with you from calls or meetings) and financial and payment information.

When you use our site, we collect certain standard information that is sent from your browser to our site. This includes technical information, such as your IP address, browser type, operating system, language, time zone setting, access time and all website addresses that refer to our site.

Purposes for which we process your personal data

We process your personal data for the following purposes:

• to provide you with information about products and services and to perform them;
• to respond to your questions;
• to conduct research and advertising;
• to contact you about improved products or product usage;
• to send you emails;
• to notify you of any changes to the services and to provide you with information about similar goods and services that may be of interest to you;
• to administer and manage warranties;
• to communicate with you and third-party contacts;
• to administer our website and help improve our products and services;
• to enable you to report problems with our website;
• to conduct analytics regarding the use of our website;
• to comply with applicable laws and regulations;
• to carry out other business-related purposes, including negotiating, entering into and performing contracts, managing accounts and documents, personalizing licensed content (as defined in the Site Terms of Use), supporting corporate social responsibility activities, legal, regulatory and internal investigations, general business activities and debt management.

Please note that without providing personal information, you cannot communicate with us via the “CONTACT US OR ASK A QUESTION” contact form and by email. If you contact us, a record of that session or correspondence will be kept.

Recruitment

When you apply for a job through our website or otherwise, we will collect even more specific personal data about you, such as your qualifications, career history, third-party recommendations and interview notes. We may also ask you for other information, such as your interests and the types of jobs you are interested in. Any personal data you provide to us in connection with a job vacancy will be processed in accordance with this notice.

Legal basis for the Company’s processing of your personal data

In order to comply with applicable data protection laws, the Company is required to establish a legal basis for the processing of your personal data. In accordance with the purposes for which we collect and use your personal data, as set out above, the legal basis of the Company processing your personal data is usually one of the following:

• Your consent;
• the performance of a contract we have with you or others;
• the Company or third parties’ legitimate business interests (for example, in maintaining and promoting our business by providing customer feedback opportunities);
• compliance with our legal obligations.

Who we share your personal data with

Our company maintains a database primarily in the Republic of Bulgaria, but we may transfer your data to one or more databases outside the country or outside your country of residence (for customers from abroad), which may include countries that may not require an adequate level of protection for your personal information compared to that provided in your country. The company has implemented controls as required by applicable law to protect the possession and transfer of personal data. Below are examples of how and why your personal data may be shared:

The company may share your personal data with people within the company who have a “need to know” this data for official or legal reasons, under a concluded contract, for example, to fulfill an order, to provide a good or service in the country or abroad, to perform an administrative function such as processing an invoice, or directing a request that you have submitted to the relevant department or a related company.

We may disclose your personal data to third parties, including government authorities, the Company’s advisors, IT service providers and third parties engaged by the Company or its affiliates, in order to provide services requested by you; to protect any intellectual property rights in any materials displayed or otherwise accessible on the Company’s website; to seek legal or professional advice; to respond to a legal request or comply with a legal obligation; to enforce the Terms of Use of the Company’s website.

We may disclose your personal information to third parties in the event that we sell, buy or merge businesses or assets, including to a potential seller or buyer of such businesses or assets.

Our employees may use personal devices to access our systems that contain your personal information, so your personal information may be transferred through or to service providers that have contractual relationships with our employees for mobile data, for example.

We may need to share your personal information to comply with a court order, law or legal process, including to respond to government or regulatory requests. Disclosure may also be necessary if we reasonably believe that disclosure is necessary to identify, contact or bring legal action to enforce any of the Company’s rights, including against you or a third party for non-payment or breach of an agreement with us. We may share your personal information to protect the safety of the Company, our customers or others; to prevent harm or interference with our rights or property, or the rights or property of other personal data processors, or anyone else who might be affected by such activities.

Personal Data Transfer Considerations

Please note that any person to whom the Company may disclose your personal data under this notice may be located in a country other than yours and that such country may not provide an adequate level of data protection requirements. By agreeing to this notice, you consent to the transfer of your personal data to a country other than yours.

Security

The Company takes appropriate technical and organizational security measures to protect personal data against accidental or unlawful destruction, accidental loss and unauthorized access, destruction, misuse, alteration or disclosure.

Document Retention

We will retain your personal data for as long as we need it for the purposes set out above, so this period will vary depending on your relationship with us. For example, when you have made a purchase from us, we will retain your purchase details for the period necessary for invoicing, tax and warranty purposes. We may also retain correspondence with you (for example, if you have made a product complaint) for as long as is necessary to protect us from legal claims. When we no longer need to keep your information, we will delete it.

Your rights

Applicable data protection laws give individuals rights in relation to the personal data that organisations hold about them. If you wish to:

• to request a copy of the personal data we hold about you;
• to request that we correct, erase or restrict the processing of your personal data,

Please send your written request via office@mtm.bg

Accessing and correcting your information

Maintaining accurate and up-to-date information is very important. Inaccurate or incomplete information may affect our ability to provide appropriate services to you. Please notify us of any changes required in relation to your personal information via our “CONTACT US OR MAKE A QUESTION” form or at the emails specified on the site.

Updates to this notice

We reserve the right to change or amend this notice at any time by posting the amended notice on our website. It is your responsibility to review the notice each time you submit information to us or place an order.

Information about non-personal data and cookies

Non-Personal Information is information about you that does not identify you as an individual, directly or indirectly, such as your browser type, the URL of the previous website you visited, your Internet connection, the equipment you use to access the Site, etc. The Company, directly or through third parties, may automatically collect certain Types of Non-Personal Information from you when you use the Site. We may also collect Non-Personal Information that you voluntarily provide, such as information included in a questionnaire or survey response.

We may share Non-Personal Information with other third parties not described above. When we do so, we may aggregate or present the information without the personally identifiable information so that the third party will not be able to associate the information with you, your computer or device. Aggregation means that we combine the non-personal information of many people so that the information does not relate to any specific individual. Information submitted without the personal data means that we attempt to remove or change some parts of the information that can be used to associate the data with a specific individual.

Except as described in this Privacy Notice, which the Company may collect from you, any other materials, information or communications that you transmit through the Website or send by email to the Company (“Communications”) will be considered non-confidential and non-proprietary. The Company is under no obligation to maintain the confidentiality of such Communications or to refrain from disclosing them. The Company will have no liability with respect to such Communications, and will be free to copy, disclose, distribute, incorporate or otherwise use the Communications, as well as all data, images, sounds, tests, ideas for products, proposals or improvements and everything included therein, for any commercial or non-commercial purpose.

“Cookies”

In general, you can visit the Site without telling the Company who you are or revealing any personal information about yourself. However, the Company or companies providing services to or on behalf of the Company may use various technologies such as cookies and web beacons (1×1 pixels) to collect non-personal information that may be discovered as a result of your visit. We will explicitly ask for your consent to the use of cookies on our Site. Cookies are used to collect general usage statistics and volume of activities. You can control the use of cookies in your browser (visit www.aboutcookies.org for more information); however, if you decline cookies, some or all of your ability to use our Site may be limited. In addition to using cookies, we use Google Analytics to analyze trends, administer the Site, track site movements, and gather demographic information about our user base as a whole. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. They may also use and disclose non-personal information obtained from our advertising campaigns for the purposes of reporting, planning and optimizing content delivery, and of course, they may do so if they are required to do so by law. The Company may use any information obtained through the Site for any lawful purpose, including without limitation, for the purposes of developing, using and providing to third parties (free of charge or for a fee) aggregated information about trends, products, patterns and research on security and privacy issues, internal reporting and reporting, measurement and reporting of training, performance and other statistical information regarding any aspect of the Site, except that the Company will not report aggregated data that allows such information to be identified with any user.

Social media functions

Our site may also include social media or sales recommendation features, such as buttons and widgets for Facebook or Twitter, such as sharing with this button. These features may collect your IP address, the pages you visit on our site, and set a cookie to enable the feature to function properly. The social media and sales recommendation features and widgets may be hosted by a third party. Your interactions with these features and widgets are governed by the privacy policy of the company that provides them.

Questions and Complaints

If you have a concern or complaint about the way the Company has used your personal data, as a first step, you should do so in writing to the Company using office@mtm.bg

Glossary

Data Administrator	Party that determines the purposes and means of data processing.
Data protection authorities	The relevant supervisory authority responsible for the right to privacy or data protection falls within the jurisdiction of the Company and/or its affiliated company;
European Economic Area (EEA)	The EEA includes all Member States of the European Union and Iceland, Liechtenstein and Norway.

Version 01/22.05.2018.