Personal data protection policy

Personal data protection policy
Details of personal data controller:

1. Name: Betelgeus Ltd.
2. Company UIC: 831617445
3. Seat and registered office: Sofia,57-59, Vranya Str.
4. Mailing details: Sofia, 1, Manastirska vodenitsa Str.
5. E-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
6. Telephone: +359 2 8090 120
7. Web site: www.betelgeus.com

Details of competent supervisory authority:

1. Name: Personal Data Protection Commission
2. Seat and registered office: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd.
3. Mailing details: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd.
4. Telephone: 02 915 3 518
5. Email: This email address is being protected from spambots. You need JavaScript enabled to view it., This email address is being protected from spambots. You need JavaScript enabled to view it.
6. Website: www.cpdp.bg

Background 

Betelgeus Ltd. carries out its activities in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

Purpose of personal data processing

1. Management of human resources, payment of renumerations and performance of relevant Employer’s obligations to deduct and pay health and social security contributions of its employees, taxes, as well as other rights and obligations of Betelgeus Ltd. in its capacity of Employer;
2. Administering the relations with customers of Betelgeus Ltd. and service delivery;
3. Conclusion and implementation of contracts with service providers of Betelgeus Ltd;
4. Responding to enquiries: the aim of this operation is to provide feedback and to respond to written or oral queries received through a website or by e-mail or phone and regarding products and services provided by Betelgeus Ltd, and sending requested or necessary information;
5. Provision of after-sales services for products under warranty;
6. Accounting and statistical purposes;
7. Marketing and performance of advertising and promotional activities, improvement and individualisation of services by giving appropriate offers for new products and technologies, events and other products and services that may be of interest;
8. Sending newsletters: the aim of this operation is to administer the process of sending newsletters to present and future customers;
9. Delivery of goods ordered online at www.betelgeus.com.

Principles of personal data processing

Personal data are processed lawfully, in good faith and transparently, in accordance with the following principles:

1. The data subject will be informed in advance of the processing of his/her personal data;
2. Personal data will be collected for specific, well-defined and legitimate purposes and will not be further processed in a manner that is incompatible with such purposes;
3. Personal data will be consistent with the purposes for which it is collected;
4. Personal data must be accurate and, where necessary, kept up to date;
5. Personal data will be erased or rectified where it is found to be incorrect or not in accordance with the purposes for which it is processed;
6. Personal data will be kept in a form that allows identifying the relevant natural persons, for no longer than necessary for the purposes for which such data is processed.

In order for data processing to be lawful, at least one of the following conditions must be met:

1. The data subject has given his/her consent, including by signing a contract with Betelgeus Ltd;
2. Processing is necessary for the performance of a contract to which the data subject is a party, or for taking steps at the request of the data subject prior to the conclusion of a contract;
3. Processing is necessary for compliance with a legal obligation to which the controller is subject;
4. Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
5. Processing is necessary for the performance of a task carried out in the public interest;
6. Processing is necessary for the purposes of the legitimate interests of the controller, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject;
7. Processing of data stored in cookies for the sole purpose of facilitating the user-friendliness of the website, improving its operation and storing information on customers’ behaviour. No personal data is stored in this process, i.e. Betelgeus Ltd may not identify you using cookies on the website. Information collected by cookies is generally used in an aggregated form to analyse users’ behaviour on the website, which enables improving the website functionality, the user paths and the content used.

Providing personal data to third parties

1. Betelgeus Ltd. may send personal data of its customers to suppliers, couriers, lawyers, law firms and other persons working for Betelgeus Ltd, to ensure the proper performance of obligations under existing contracts with customers.
2. In case personal data is required to be sent to third parties, the latter are only allowed to process such data for the needs of contracts with customers and may not use such data for their own marketing or other purposes.
3. Personal data will be transferred to third parties only in the following cases:

1. with the customer’s explicit consent;
2. if required by the Bulgarian or European legislation;
3. if Betelgeus Ltd. needs to protect its rights and take measures against acts that obstruct the contractual relationship with the customer.

Duration of storage of your personal data

Betelgeus Ltd. stores personal data required under the applicable legislation for the prescribed period, which may exceed the time limit for the implementation of the contractual relationship.
Personal data processed for the purpose of direct marketing: until the explicit withdrawal of consent for direct marketing or until the receipt of an objection to the processing of personal data for direct marketing.
Data collected for the purpose of subscription to receive free newsletters will be stored from the time of your subscription until you withdraw your wish to be a free subscriber, and then it will be automatically deleted. This is also the case when we publish a newsletter on the website.

Consent

1. Consent of the data subject is not required, if the data is necessary for the fulfilment of a legal obligation of the controller. The data subject agrees with the processing, if he/she expresses this clearly and unambiguously by means of a statement or any other confirmatory act. If consent to personal data processing is given in a document governing other matters also, it should be required separately from the consent regarding such other matters.
2. Data subjects must be able to easily withdraw their consent at any time and the withdrawal must be granted in due time. If there is no other condition for the lawfulness of processing, the withdrawal of consent should terminate it.

Rights of data subjects

1. Any natural person has the right of access to his/her personal data, including confirmation of whether data concerning him or her is processed, the right to be informed of the purposes of such processing. The right of access is exercised at the request of the natural person concerned, which must be received at the registered office or at the official e-mail of Betelgeus Ltd.
2. Any natural person has the right to request erasure, rectification or blocking of his/her personal data, if the processing fails to comply with the legal requirements; rectification of recorded personal data.
3. Any person has the right to object in writing to the processing and/or transfer of his/her personal data to third parties without the necessary legal grounds.
4. Any person has the right to portability of his/her personal data (i.e. the right to receive the personal data they have provided in a structured, commonly used and machine-readable format, and the right to transfer this personal data to another controller).
5. Right to withdraw his/her consent to personal data processing.
6. Right to object to the use of their personal data for the purposes of direct marketing;
7. Right to be informed of a data security breach that is likely to result in a high risk to their rights and freedoms.
8. Right to lodge complaints with the regulatory authority.

Where a customer wishes to exercise any of the above rights, it should contact Betelgeus Ltd. at the following e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

Data security 

Security of any type of information, including personal data available in the facilities of Betelgeus Ltd, is a priority for the company. Organisational and technical measures are taken to ensure the maximum possible protection against unauthorised access or disclosure of information. Protection of data contained in hard copy and on electronic data carriers from unlawful access, damage, loss or destruction is ensured through a series of internally regulated technical and organisational measures.

„Cookies" and tracking pixels 

1. We use cookies and tracking pixels in our web site.
2. Cookies are small files containing a string of characters which are stored on your hard disk. When you visit the Sites again, the cookies allow us to recognise your computer/device.
3. Tracking pixels are miniature images or other web development code that could be delivered through the web browser or e-mails we send to you.
4. We use cookies and tracking pixels to:
   - personalize our service to you and to adapt them to your needs based on your preferences;
   - improve website performance;
   - track the web site traffic for statistical purposes and to find out which pages or features users find useful and which don't;
5. Cookies cannot read data off your hard disk, mobile device or other device except for the information you have decided to share with us.
6. Some cookies may not be linked to our website. When you visit a page with embedded content, such as YouTube or Facebook, cookies may be recorded on your device from these sites. We do not control third-party cookies. More information about these cookies, please refer to the relevant third party's website.
7. Third parties, including Google and Social media use cookies to provide relevant advertisements using information about your visits to this and other web sites.
8. By clicking "accept" button, you agree accept Cookies from our site. In case you do not want to accept our cookies, please click the button "deny".
9. Your desire to use cookies may be modified at any time.
10. Further information about the procedure to follow in order to control cookies on your computer, mobile device or other device can be found on www.aboutcookies.org.
    

Complaints

1. Customers have the right to complain to Betelgeus Ltd, if they believe that their rights under this Privacy Policy and the General Regulation have been infringed. For this purpose, customers may contact Betelgeus Ltd. at the following e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.
2. At any time, customers have the right to lodge a complaint with the competent supervisory authority responsible for the application of the General Regulation.