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With Regard to The Processing of Personal Data
We consider ensuring the right to personal data protection as a fundamental Profitshare commitment, so we will dedicate all the resources and efforts needed to process your data in full compliance with Regulation (UE) 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as any other applicable Bulgarian legislation. Since one of the key principles of this legal framework is transparency, we have prepared this document through which we want to inform you about how we collect, use, transfer, and protect your personal data when interacting with us about our products and services including through our website or through the applications available on the mobile phone.
Who we are and how to contact us
Profitshare is the trade name of Conversion Marketing E.O.O.D, a Bulgarian legal entity, with its registered office in Sofia, 1504, Ul. Sheynovo str. 18, Bulgaria, registered with the Trade Registry of the Registry Agency under no. 203168261, unique tax registration number BG203168261 (hereinafter referred to as “Profitshare”, “we” or “us”). For the purposes of the data protection law, we are a controller when we process your personal data.
Since we are always open to hearing your opinions and providing you with any additional information you may need regarding the processing of your data, we encourage you to contact Profitshare to the e-mail address email@example.com or by mail or courier to the address Conversion Marketing EOOD - Sofia, 1504, Ul. Sheynovo str. 18, Bulgaria .
Which categories of personal data we process
In general, we collect your personal data directly from you, so you have control over the type of information you give us. For example, we receive information from you like this:
When you register and set up your Profitshare account, you are sending us:
- your first, middle and last name;
- phone number;
- email address;
- any other data recorded voluntarily.
For signing the contract, you are sending us:
- national identification number (EGN);
- home address;
- bank account number (IBAN).
To calculate the applicable withholding taxes, you are sending us:
- a declaration for national insurance contributions;
- documents attesting tax-exempt status, if applicable.
We can also collect and then process certain information about your behaviour while browsing our website or using the smartphone application to personalize your online experience.
Our platform logs traffic data (including the IP addresses) provided by the device you use to enter our website or smartphone application to ensure the security and stability of our systems as well as the technical administration of the network infrastructure.
We invite you to find out more details in this regard by consulting the section on processing purposes below.
What are the purposes and grounds of the processing
We will use your personal data for the following purposes:
- To provide the Service for your benefit
This general purpose may include, as appropriate, the following:
a) Checking consent for entering into the Terms and Conditions of the Service;
b) Creating an Affiliate Account;
c) Identifying Affiliates and providing the Service to them;
d) Performing the payment of the amounts owed, according to Terms and Conditions of the Service;
e) Withholding taxes, in accordance with the legislation in force (income tax, contributions to the social security and health systems, any other withholding taxes);
f) Providing to the Affiliates, upon request, income statements;
g) Sending notifications and non-commercial messages;
h) Reporting and investigation purposes;
i) Providing support services, including providing answers to your questions about the Service and Platform.
Processing your data for these purposes is in most cases necessary for the conclusion and performance of a contract between Profitshare and you. Also, some processing underlying these purposes is required by the applicable law, including the tax and accounting legislation.
- To improve our services
We always want to offer you the best online experience. For this, we may collect and use certain information about your purchasing behaviour, we may invite you to fill in satisfaction queries or we can conduct, directly or with the help of partners, market studies and research.
We base these activities on our legitimate interest in doing business, always taking care that your fundamental rights and freedoms are not affected.
- For marketing
We want to keep you informed about the best deals for the products/services you are interested in. In this sense, we can send you any type of messages, through electronic communication channels (e-mail / SMS / mobile push / webpush / etc) containing general and thematic information, information regarding offers and promotions and other business communications, like market research and opinion polls and we can show personalized recommendations on the website and smartphone. In order to provide you with information of interest to you, we may use certain data about your online behaviour to create a profile. We always ensure that such processing is done observing your rights and freedoms and those decisions taken thereon have no legal effect on you and does not affect you in a similar way to a significant extent .
In most cases, we base our marketing communications on your prior consent. You can change your mind and withdraw your consent at any time by:
– Changing the settings in the “My account” section
– Accessing the unsubscribe link displayed in the messages you receive from us; or by
– Contacting Profitshare using the contact details described above.
In certain situations, we can base our marketing activities on our legitimate interest in promoting and developing our commercial activity. In any situation where we use information about you for our legitimate interest, we take care and take all necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you may, at any time, request us, by the means described above, to stop processing your personal data for marketing purposes, and we will respond to your request.
- To defend our legitimate interests
There may be situations in which we use or transmit information to protect our rights and commercial activity. These may include:
Measures to protect the website and the users of the Profitshare platform against cyber attacks;
Measures to prevent and detect fraud attempts, including the transmission of information to competent public authorities;
Measures to manage various other risks.
The general reason for these types of processing is our legitimate interest in defending our commercial activity, being understood that we ensure that all the measures we take guarantee a balance between our interests and your fundamental rights and freedoms.
Also, in some cases, we base our processing on legal provisions such as the obligation to safeguard the goods and values provided by the applicable legislation in this matter.
How long do we keep your personal data
As a general rule, we will store your personal data as long as you have an Profitshare account. You may request us at any time to delete certain information or to close the account and we will respond to these requests, subject to the storage of certain information including after the account has been closed, in cases where the applicable law or legitimate interests impose it.
Who we send your personal data to
As the case may be, we may transmit or give access to some of your personal data to the following categories of recipients:
– companies within the same group of companies as Profitshare;
– courier service providers;
– payment / banking service providers;
– marketing / telemarketing service providers;
– market research service providers;
– communications and IT service providers;
– accountants, auditors, lawyers and other professional consultants;
– other business infrastructure providers;
- other companies with whom we can develop joint programs to market our goods and services.
If we have a legal obligation or if it is necessary to protect our legitimate interest, we can also disclose certain personal data to public authorities.
We ensure that access to your data by third-party private law entities is done in accordance with the legal provisions on data protection and confidentiality of information, based on contracts concluded with them.
To which countries we transfer your personal data
We currently store and process your personal data in Bulgaria and Romania.
However, it is possible to transfer some of your personal data to entities located in the European Union or outside the Union, including in countries where the European Commission has not recognized an adequate level of personal data protection.
We will always take steps to ensure that any international transfer of personal data is carefully managed in order to protect your rights and interests. The transfers to service providers and other third parties will always be protected by contractual commitments and, where appropriate, by other safeguards, such as the standard contractual clauses issued by the European Commission or certification schemes, such as the Privacy Shield for Personal Data Protection transferred from within the EU to the United States of America.
You can contact us at any time, using the contact details listed above, to find out more about the countries where we transfer your data, as well as about the safeguards that we have implemented with respect to these transfers.
How we protect the security of your personal data
We are committed to ensuring the security of personal data by implementing appropriate technical and organizational measures, in line with the industry standards. We keep your personal data on secure servers using state-of-the-art encryption algorithms and ensuring storage redundancy.
Despite the steps taken to protect your personal data, we note that the transmission of information via the Internet in general or via other public networks is not entirely secure, with the risk that the data may be seen and used by unauthorized third parties. We cannot be responsible for such vulnerabilities of systems that are not under our control.
What are your rights
The General Data Protection Regulation recognizes a series of rights with respect to your personal data. You may request access to your data, correct any mistakes in our files, and / or you can oppose the processing of your personal data. You can also exercise your right to complain to the competent supervisory authority or to address the courts. As the case may be, you may also have the right to request the deletion of your personal data, the right to restrict your data processing and the right to data portability.
More information about each of these rights can be obtained by reviewing the table below.
In order to exercise your rights, you may contact us using the contact details listed above.
Please note the following if you want to exercise these rights:
Identity. We take seriously the confidentiality of all records that contain personal data. For this reason, please send us your requests regarding such records using the email address of the Profitshare account. Otherwise, we reserve the right to verify your identity by requesting additional information to confirm your identity.
Fees. We will not charge a fee to exercise any right with respect to your personal data unless your request for access to information is groundless, repetitive or excessive, in which case we will charge a reasonable amount in such circumstances. We will inform you of any fees applied before we resolve your request.
Response time We plan to respond to any valid requests within a maximum of one month, unless this is particularly complicated or if you have made more requests, in which case we will respond within maximum two months. We will let you know if we will need more than a month. We may ask if you can tell us exactly what you want to receive or what you are worried about. This will help us act faster and shorten the response time to your request.
Rights of third parties We do not have to respond to a request if it negatively affects the rights and freedoms of other data subjects.
You can ask us:
You may ask us to rectify or complete your inaccurate or incomplete personal data. We may try to verify the accuracy of the data before correcting it.
You may ask us to delete your personal data, but only if:
We have no obligation to comply with your request to delete your personal data if the processing of your personal data is required:
There are certain other circumstances in which we are not obliged to comply with your request for data deletion, although these are the most likely circumstances in which we may decline your request.
Please note that before exercising this right: you should download from the Profitshare account and save all the related documents. If you do not do so before you exercise the right to delete, you will lose all these documents and Profitshare will be unable to provide you with them, as the case may be, because the data deletion process and the deletion of the Profitshare account with all the data and documents related to it, is an irreversible process.
Restriction of data processing
You can ask us to restrict the processing of personal data, but only if:
We may continue to use your personal data as a result of a restriction request, in case:
You may ask us to provide your personal data in a structured, commonly used and readable form, or request that it be “ported” directly to another data operator, but in each case only if:
You may oppose at any time, for reasons related to your particular situation, the processing of your personal data under our legitimate interest if you believe that your fundamental rights and freedoms prevail over this interest.
You can also oppose any time the processing of your data for direct marketing purposes (including creating profiles) without giving any reason, in which case we will cease processing as soon as possible.
Making automated decisions
You can ask that you are not made the subject of a decision based solely on automatic processing, but only when the decision that is taken:
This right does not apply if the decision was reached after the automatic decision making:
You have the right to file a complaint with the competent supervisory authority regarding the processing of your personal data. According to current legislation, the lead supervisory authority for all Conversion Marketing group companies is in Romania. The contact details for the Data Protection Supervisory Authority in Romania are as follows: National Supervisory Authority for the Processing of Personal Data B-dul G-ral. Gheorghe Magheru no. 28-30, 1st district, postal code 010336, Bucharest, Romania, Phone: +40.318.059.211 or +40.318.059.212.
Contact details for the Data Protection Supervisory Authority in Bulgaria are: Commission for the Protection of Personal Data, Sofia 1592, "Prof. Tsvetan Lazarov" No. 2, phone: 02/91-53-519 or 02/91-53-555, E-mail: firstname.lastname@example.org.
Without prejudice to your legal right to lodge a complaint with the supervisory authority, we ask you to contact us first and we guarantee that we will do our best to resolve your problems amicably.
We remind you that you can contact Profitshare at any time by submitting your request in any of the following ways:
by e-mail to the address: email@example.com or
by post or courier to the address: Conversion Marketing EOOD - Sofia, 1504, Ul. Sheynovo str. 18, Bulgaria.
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© 2023 Кънвършън Маркетинг ЕООД
Operator of personal data no. 412670
© 2023 Conversion Marketing SRL
Reg.Com.: J23/5955/01.09.2022 Operator of personal data no. 28184