“Personal data” means any information by which an individual is identified or can be identified;
“Data subject” is a natural person who is identified or identifiable on the basis of certain information;
“Processing” means any operation or set of operations performed with personal data or a set of personal data by automatic or other means such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, consulting, using, disclosing by transmission, dissemination or other means by which data become available, arranged or combined, restricted, deleted or destroyed;
“Administrator” means a natural or legal person, a public authority, an agency or other entity which, alone or jointly with others, defines the purposes and means of processing personal data. In this case, the data controller is SIRMA SOLUTIONS JSC;
“Personal data processor” means a natural or legal person, a public authority, an agency or other entity that processes personal data on behalf of the controller. “Personal data processing” in this policy shall mean an employee of SIRMA SOLUTIONS JSC;
SIRMA SOLUTIONS JSC handles personal data when using the above mentioned websites. Personal data processed by SIRMA SOLUTIONS JSC is provided directly by you or collected automatically.
The legal basis on which SIRMA SOLUTIONS JSC handles personal data is your voluntary consent. For the purposes listed below, you should explicitly agree to each individual goal by ticking it in a CheckBox box that appears as a square box with accompanying text. When a choice is made, a check box appears in the context of which you have already agreed that your personal data will be processed by SIRMA SOLUTIONS JSC. When no choice is made, the box is empty.
Personal data you provide:
Personal data you provide directly is processed and used for the purposes set out in this Policy. The provision of your personal data when using the sites is optional unless you wish to make a voluntary registration. The personal data we collect on your voluntary registration is: name and surname, email, address, and/or others, depending on the site you wish to sign up for. This is information you should provide in order to be able to sign up for the site and through which you can be personally identified.
When you provide publicly personal information on our sites, you should keep in mind that it may be viewed by other visitors on the same sites and we are unable to prevent further use by them.
The purposes of collecting the specified personal data are described below in this privacy and data protection policy.
What information we collect about you
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.
Account and Profile Information:
We collect information about you when you register for an account, create or modify your profile, set preferences, or sign-up for. We collect only the data, which the user provides via the website User Interface and keeps it on the secure server.
- Email address, Username, First and Last name, Password (encrypted, not readable by us)
- Your name, Birthdate, Gender
- Public facebook profile (required) profile picture, age, gender and other public info
- Job Title
- Contact Preference Language, country, time zone
- Registration date
- Status of consents
The application doesn’t collect any personal information from the device where it is installed without user permission.
Relevant information we collect:
Personal Data: first name, last name, address, date of birth/age, gender, telephone number.
Commercial and Usage Data
App store download, purchase, invoices, payment status, payment method (google play/app store) promo codes used, IP address, device ID, operating system, browser type and version.
Other information we collect
Personal data collected automatically:
When you visit our web page, our web server automatically recognizes and collects your IP address that has been determined by your ISP and does not personally identify you.
Summary Information – Log Files – Like many other sites, we get information from log files: IP address; ISP (Internet Service Provider) the browser you use when visiting a site (such as Google Chrome, Internet Explorer, and Mozilla Firefox); the time spent on a site, and which pages you’ve visited on the site. The information contained in these files includes:
Cookies: this is a small amount of information the web server sends to the web browser, allowing the server to collect feedback from the browser. You can choose to delete our or third-party cookies using the options of each browser. This may affect interaction with our or other sites.
You can find more information about cookies at https://en.wikipedia.org/wiki/HTTP_cookie
We use the following types of cookies:
(1) Statistics cookies that anonymously remember your computer or mobile device when you visit our websites. They follow the search method and help us build an account of how our readers use the website. We may use this information to display ads that might be of particular interest to our and other websites.
(2) Service cookies that help us make our websites as effective as possible. They allow you to remember the registration and login data, to keep your preferred settings.
(3) Third-party advertising and analytics that are placed on behalf of independent advertisers advertising on our sites. These cookies can be placed in the ad or elsewhere on our sites. These cookies are anonymous – they cannot identify you. They are used for statistical analysis, allowing the advertiser to count how many people saw his ad or have seen it more than once. They can also allow the advertiser to adjust the ad to you when you visit other websites.
(4) We do not have access to third-party cookies, and third-party organizations do not have access to ours. Third-party cookies have their own strict confidentiality rules.
Web beacons are files that allow a website to collect information about the number of users who have visited it and have access to their cookies. More information about web beacons can be found at https://en.wikipedia.org/wiki/Web_beacon
How we use the information we collect
Purposes of processing your personal data:
Sirma Solutions JSC processes your personal data only for the purposes described below:
- for registering and managing your account, including troubleshooting;
- to measure and track statistical dependencies on user behavior on Sirma Solutions JSC site in order to improve our products;
- send you a regular newsletter that you have explicitly subscribed to;
- for marketing purposes related to activities on the relevant website;
- send you marketing messages and information to third parties when we have expressly agreed to do so.
Recognition and IP address collection allows:
– disclosure of users’ identity when required by law, legal procedures or to comply with these terms;
– analyzing traffic to sites and preventing malicious attacks;
– to show you an ad related to your location or service information such as the weather forecast of your location or closest to it;
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
Google Analytics and Advertising
We work with Google Analytics to help us understand how the Application is being used, such as the frequency and duration of usage. We work with advertisers and third party advertising networks like AdMob, who need to know how you interact with advertising provided in the Application which helps us keep the cost of the Application low. Advertisers and advertising networks use some of the information collected by the Application, including, but not limited to, the unique identification ID. We may also share anonymously via Google APIs your gender and age for advertising related use.
For more details about Google Analytics please visit: Google Analytics
If you’d like to opt-out from third party use of this type of information to help serve targeted advertising, please visit the section entitled Opt-out the targeted advertising below.
Name and Address of the responsible entity
Loyax is a property of and operated by Sirma Solutions JSC. Responsible entity for the purposes of data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
SIRMA SOLUTIONS JSC
135 Tsarigradsko Shosse, fl.3
1784 Sofia, Bulgaria
Your rights and opportunities with respect to the processing of your personal data:
You have certain rights under the applicable law with regard to the personal data we hold for you, namely:
- You are authorized to request access and receive personal data, which is stored for you as well as information regarding the purposes of the processing, the categories of personal data, the recipients to which your personal data may be disclosed and others;
- You have the right at any time to request correction of inaccurate data relating to you, as well as supplementing incomplete data, if appropriate and/or necessary for the purpose with which the data are processed;
- You may at any time withdraw your consent to the use of your personal data that you provided at a previous time. In this case, withdrawing your consent to the use or processing of your personal information may result in the inability to take advantage of certain products or services provided by the above sites;
- If you do not wish Sirma Solutions JSC to process your personal data, you have the right to be “forgotten”, that is, you may at any time ask for your personal information to be deleted for one of the following reasons:
4.1. Your data is no longer necessary for the purposes for which it was collected or otherwise processed;
4.2. If you have withdrawn your consent to the processing of your personal data;
4.3. If your personal data is being processed unlawfully;
4.4. In case you have objected to the processing of your personal data;
4.5. Other cases provided for in the legislation governing the protection of personal data.
- In many cases, you have the right to request, instead of deleting the data, to restrict the processing of your personal data;
- Right of objection to Sirma Solutions JSC against the processing of your personal data, provided there is a legal basis for that;
All listed rights can be exercised by submitting a free written application to the following email address: email@example.com, sent from your registration email address, containing at least the following:
- Username, email and other identification data of the individual concerned;
- A description of the request;
- Referencing the domain of a site to which this request relates;
- The preferred form for providing information;
The submission of the application is completely free of charge. The time limit for processing the application shall be one month as from the date of receipt of the application.
In addition to the above rights, Sirma Solutions JSC gives you the right to make some of the following changes in relation to the processing of your personal data yourself, as follows:
- In your profile, you can edit and delete personal data that is not mandatory to use the site and do not want to be publicly available;
- You can manage your subscription preferences from your profile settings and opt-out of receiving a specific email newsletter by selecting the write-off option at the end of each e-mail received.
More information about personal data protection can be found on the Commission for personal data protection website: https://ec.europa.eu/info/law/law-topic/data-protection_en