Commasense Ltd. – Privacy Policy
- The following Privacy Policy (PP) is intended to inform the users of BuildPlateZ how we process private data, the rights you have and how the law protects you. Please, before using the services on our website, read the said PP.
- This PP relates to the products and/or services, content, functions, technologies, mobile apps, mobile stores, etc. that we offer and you will use on your part.
- WHO ARE WE?
- Commasense Ltd. 205242073 (CCI), is situated in Plovdiv, Maritza 82 Bul., Bulgaria. The company is represented by the owner Vasil Nikolaev Nikolov.
- Commasense Ltd. is a Controller of your personal data pursuant the European and Bulgarian law. The Controller of personal data processes and collects personal data of the users for the implementation of the services provided on the BuildPlateZ platform, in accordance with the General Terms and Conditions.
- WHAT DATA DO WE COLLECT?
- Commasense Ltd. collects only personal data that are necessary for the functional operation of the WeMakeIt website.
DATA PROVIDED THROUGH DIRECT INTERACTION:
- When you register on BuildPlateZ to use our Services, we may collect the following information about you:
- When subscribing to a plan: first and last name, address, phone number, corporate details;
- Depending on the choice you make when gaining access on our website and platform, you can provide the following additional personal data:
- your name;
- Your e-mail address;
- phone number;
- Your credit card information (name of the owner, expiry date, type of credit card, last four digits of the credit card).
PARTICIPATION IN USER STUDY:
- BuildPlateZ will periodically offer the users the chance to participate in user studies with the aim to evaluate your satisfaction with the services we provide. For this purpose we will only use a session (this is a random identificator assigned to you when you download our mobile application or visit our website). You can also choose to provide to us your personal data such as e-mail and phone number, in order for us to connect with you and invite you to participate in our user experience tests. Please keep in mind that the information you provide in connection to the survey may contain personal data, voluntarily provided by you in your responses.
INFORMATION WE COLLECT AUTOMATICALLY:
- When you use our services, we automatically collect the following information about you:
- Device: We collect device-specific information such as operating system version, unique identifiers. For example, the name of the mobile service provider you use, your IP address, your device’s language settings, device brand and type, device operating system and version, browser type and version, and device-specific software information such as fonts, system and browser time zone, available video and audio formats
- Location: Depending on your device’s permissions, if you post an item to our platform, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points and cell towers. Your location data allows you to see user items near you and helps you post items to your location. In the event that we need your location data, we will first show you a pop-up window asking you to choose whether or not to allow us access to your location data. If you do not allow us access to your location data, you will still be able to use our Services, but with limited functionality. If you do allow us access to your location data, you can always change this later by going to the settings on our website or mobile app and disabling the permissions related to location sharing. To learn more about the purposes for which your location data is used and how this data is processed, please refer to this Policy;
- Customer and Log Data: Technical details, including your device’s Internet Protocol (IP) address, time zone and operating system. We will also store your login information (date of registration, date of last password change, date of last successful login), type and version of your browser;
- Clickstream Data: We collect information about your activity on our Services, which includes the sites from which you accessed our Services, a date and time stamp of each visit, searches you performed, advertising listings or advertising banners, on which you clicked on, your interaction with such advertisements or advertising lists, the duration of your visit and the order in which you visit the content on our services;
- Cookies and similar technologies: We use “cookies” to manage our users’ sessions, store your preferred language selection and provide you with relevant advertisements. “Cookies” are small text files transferred from a web server to your device’s hard drive. Cookies can be used to collect the date and time of your visit, browsing history, preferences and your username. You can set your browser to refuse all or some cookies or to warn you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our services may become unavailable or may not function properly.).
DATA FROM THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES:
- We receive personal data about you from various third-party and public sources, which we may combine or link with the personal data we collect from you through our Services. In particular, this includes the following information:
- Certain technical information and information about the use by analytics providers, such as Google Analytics 360, for statistical purposes and to analyze the use of our Services, to improve our Services and for online marketing
- government authorities provide us with a username, phone number and email when they ask Comamsense Ltd. to carry out checks or provide these authorities with more data in the context of fraud prevention activities
- Our Services are not intended for persons under the age of 18, and we do not knowingly collect data from them. If we learn that a person under the age of 18 has provided us with personal data, we will delete it immediately.
- WHY DO WE PROCESS YOUR PERSONAL DATA?
- We will only use your personal data where we are legally permitted to. We will most often use your personal data in the following circumstances:
- When we need to fulfill the contract we are about to enter into or have entered into with you;
- Where necessary for our legal interests and where we believe that our legal interest is not superseded by the interests of you or other data subjects or fundamental rights and freedoms;
- where we must comply with a legal or regulatory obligation.
- In certain circumstances, we may also process your personal data based on your consent. If we do this, we will notify you of the purpose and category of personal data that will be processed at the time we ask for your consent
- Below we have set out a description of the reasons why we use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where relevant
- We use third-party payment service providers to process any payment you make for our Services. Depending on the payment method, you may be asked to provide us with your payment and credit card details, which we will then provide to the payment service provider to process your payment. We do not store your credit card information.
- We do not store any credit card code verification values and simply forward such values and your credit card number in an encrypted manner for the purpose of processing your payment to our payment service provider
We process the above information for the performance of the contract between us.
1. CHANGES TO PRIVACY POLICY. NOTICES OF CHANGES.
- We may amend and update this privacy policy periodically. We will notify you of such changes when they occur, as required by the applicable law, for example by posting a prominent notice within our Services.
2. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
- We may need to share your personal data with the parties listed below for the purposes listed above
- Third Party Service Providers: We use third party service providers to help us provide certain aspects of our Services and to maintain and monitor our Services. In this context, your personal data may be shared with the following recipients or categories of recipients:
- payment service providers, such as Stripe, may receive your personal data for the purposes of processing payments you wish to make through our Services; to make payments in connection with our services, regardless of whether it is a card payment or a payment with a payment order;
- cloud service providers such as Amazon Web Services, Inc. (AWS), Google Ireland Limited (Google Cloud), Microsoft Corporation (Microsoft Azure), which may receive some of your personal data for cloud storage purposes;
- integrated third-party tool providers, such as Google Ireland Limited (Google Maps), which may receive your location data in order to improve the performance of our Services and to personalize the content we direct to you;
- These third party service providers may be located in or outside the (European Economic Area) EEA.
- We carry out checks on our third-party providers and require them to respect the security of your personal data and treat it in accordance with the law. We do not allow them to use your personal data for their own purposes and only allow them to process your personal data for specified purposes and in accordance with our instructions.
- Advertising and analytics providers: To improve our Services, we will sometimes share your information with analytics providers, such as Google Analytics 360, which help us analyze how people use our Services to improve our Services and help us with online marketing and interest-based advertising. For the most part, we share your information with them in de-identified form to monitor and report campaign delivery performance to our business partners and for internal business analysis. This information typically includes a cookie identifier, (abbreviated) IP address, referring URL, as well as browser and device information. By analyzing your browsing behavior on our Services through cookies with the help of analytics providers, we are able to better understand the use of our Services and improve our product and will be able to show you more relevant OLX ads when visit other websites. For advertising purposes, we partner with advertising vendors that are organized by the Interactive Advertising Bureau (IAB) and listed here: https://iabeurope.eu/vendor-list/. We may share with our advertising partners your cookie identifier (first-party and third-party cookies), which allows us to show you more relevant third-party ads on our Services based on your browsing behavior outside of our Services. To control and manage your ad settings, you can access the settings via a link in the footer of our website.
- Mergers and acquisitions: If (part of) our business or our assets are reorganized, sold, transferred or merged with another business, your personal data will be disclosed and transferred to the new owners of the business. In such cases, we will take any action required by law, which may include notifying you and providing you with a choice as to whether you wish to continue using our Services.
- Law enforcement authorities, regulatory authorities and others: We may disclose your personal data to law enforcement authorities, regulatory authorities, governmental or public authorities and other relevant third parties in order to comply with any legal or regulatory requirements.
- Publicly Available Information: When you post an item for sale using our Website, you may choose to make certain personal information visible to other WeMakeIt users. This may include your first name, last name, your email address, your location and your contact number. Some information, such as your rating and feedback received from other users, may automatically be publicly disclosed when an ad is posted. We also make your rating and feedback, along with your username, public to the users you rated. Please note that any information you provide to other users may always be shared by them with others, so please use appropriate judgment in this regard.
4. WHERE DO WE STORE YOUR PERSONAL DATA?
- The data we collect about you will be stored and processed both within the EEA and on secure servers to provide the best possible user experience, for example to quickly build a website or mobile application. The data of WeMakeIt users in the EEA is stored on cloud servers provided by ICDSoft Ltd and Shopify Inc.
- We will only retain your personal data for as long as is necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, tax and accounting or reporting requirements
- To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and applicable legal requirements
1. CONTACTS.
- For further information or to exercise your rights, please check your account/privacy settings or contact our privacy office using our contact form. You can also contact the data controller for your local services at: city of Plovdiv, 82 Maritsa Blvd., Entrance In, app. 5 (or other address where the WeMakeIt office will be)
2. DATA PROTECTION.
- For data protection complaints, you can contact the responsible data protection (Supervisory) authority. You can exercise this right by contacting the authority of your place of residence or place of work or the location of the data controller
- For Bulgaria, the relevant Supervisory authority is the Personal Data Protection Commission
Address: Sofia, Tsvetan Lazarov Blvd #2;
Telephone:
For inquiries on complaints, alerts and questions: 02/ 91-53-519; fax: 02/ 91-53-525;
For consultation on the application of Regulation (EU) 2016/679 and national legislation in the field of personal data protection: 02/ 91-53-555.
Website: http://www.cpdp/bg/