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Privacy and Data Protection Policy

Who are we?

This Privacy Policy applies to Crampa Ltd, Uniform Identification Code 202648453, having a seat and registered address at 42A Nezabravka Str., entrance B, fl.6, app. 24, Sofia 1113, Bulgaria.

Under this Privacy and Data Protection Policy, Crampa in its capacity as a controller takes into account the privacy and the need to protect individuals' data. In accordance with the legislation in force and the best practices, the company shall implement the necessary technical and organisational measures to ensure the protection of Personal Data.

The Personal Data required for the provision of Crampa products and services shall be collected and processed following Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons about the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) as well as the applicable national and Union law.

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Who can you contact for privacy questions or concerns?

If you have questions or comments about this Privacy Policy or how we handle your personal data, please direct your correspondence to: Crampa Ltd, 176 Europa Blvd, 1331 Sofia, Bulgaria or email office@crampa.com. We aim to respond within 15 days from the date we receive privacy-related communications.

In any event, you always have the right to submit a complaint to a Data Protection Supervisory Authority Commission for Personal Data Protection to report concerns you may have about our data handling practices at:

Postal address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria        

Telephone: +359 (2) 91-53-518

email:  kzld@cpdp.bg

website: www.cpdp.bg

 

The other EU member state regulator contacts may be found here.

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How do we collect personal data?

  • Directly. We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us with their business cards, completing our online forms, attending meetings or events we host, visiting our offices and premises, or providing references for job applicants.

  •  Public sources - Personal data may be obtained from public registers (such as the Commercial Register), and news articles.

  •  Social and professional networking sites - If you register or log in to our websites using social media (e.g., LinkedIn, Google, Facebook, Instagram or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want to share with us.

  • Suppliers, partners, sub-contractors - We may obtain personal data about representatives and contact persons of our suppliers, partners, and sub-contractors for the purposes of execution and performance of the relevant agreement.

 

What categories of personal data do we collect?

We may obtain the following categories of personal data about individuals through direct interactions with us (e.g. if you choose to provide it — for example, to contact mailboxes or to order certain products and services) or from information provided through client engagements, from job applicants, suppliers, partners, sub-contractors, and through other situations including those described in this Privacy Policy.

  • Personal data. Here is a list of personal data we commonly collect to conduct our business activities: 

    • Identification information for contact purposes (e.g., names, company name, position details);

    • Contact details (e.g., work and mobile telephone numbers, work and personal email and postal address).

  • Sensitive personal data. We typically do not collect sensitive or special categories of personal data about individuals. When we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate purposes or if required by law. Examples of sensitive personal data we may obtain include: 

    • Personal identification documents that may reveal race or ethnic origin, and possibly biometric data of private individuals;

    • Information provided to us by our clients in the course of a professional engagement. 

  • Child data. Although we do not intentionally collect information from individuals under 14 years of age, we may occasionally receive details about children attending performances and other events we host with their parents or guardians, or if such information is provided to us by our clients in the course of a professional engagement. 

 

What lawful reasons do we have for processing personal data?

We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services: 

  • Contract - this is when the processing of your personal information is necessary to perform our obligations under a contract;

  • Consent - in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information if you agree with us. You may withdraw your consent at any time by contacting Crampa at 42A Nezabravka Str., entr. B, fl.6, app. 24, Sofia 1113, Bulgaria or email office@crampa.com;

  • Legitimate interests - We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include: 

    • Delivering products and services to our clients; 

    • Execution and performance of agreements with our suppliers, partners, sub-contractors, etc.;

    • Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.

  • Legal obligations and public interests – We may process personal data to meet regulatory and public interest obligations or mandates.

Crampa does not normally carry out automated decision-making, including profiling, of personal data. If such is being carried out, Crampa undertakes to provide meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

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Why do we need personal data?

We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:  

  • Providing and promoting our services and products;

  • Sending invitations and providing access to guests attending our events or our sponsored events;

  • Administering, maintaining and ensuring the security of our premises, information systems, applications and websites; 

  • Authenticating registered users to certain areas of our sites.

 

Do we transfer your personal data?

Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards.

We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:

  • Parties that support us as we provide our services (e.g., providers of telecommunication systems, mail support, IT system support);

  • Our professional advisers, including lawyers, auditors and insurers;

  • Postal/courier providers;

  • Payment services providers.

Additionally, we may provide data to courts, law enforcement, other government and regulatory authorities or other third parties as required by, and according to applicable law or regulation.

We store personal data on servers located in the European Union.

 

Do we use cookies?

Our websites may use cookies. Where cookies are used, a statement will be sent to your browser explaining the use of cookies.

 

What are your data protection rights? 

Your data protection rights are highlighted here:

Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.

Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you. 

Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.

Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.

Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if technically feasible.

Automated Individual Decision-making – You can ask us to review any decisions made about you which are solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.

Right to Object – You can object to our use of your personal data for direct marketing purposes, including profiling, or if we are not entitled to use it any more.

Right to Withdraw Consent – You can withdraw the consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case. You may withdraw your consent at any time by contacting us at 42A Nezabravka Str., entrance B, fl.6, app. 24, Sofia 1113, Bulgaria or email office@crampa.com.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

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What about personal data security?

We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.

If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; any transmission is at your own risk. 

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How long do we retain personal data?

We retain personal data to provide our services and products, receive services or goods from our suppliers and sub-contractors, stay in contact with you and comply with applicable laws, regulations and professional obligations that we are subject to. We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual's request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted.  The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above, personal information will not be retained for more than ten years, unless otherwise required by law or for the establishment, exercise or defence of legal claims or dispute resolution. We will dispose of personal data in a secure manner when we no longer need it.

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