Privacy Policy
This Policy applies as between you, the User of this Website and Adastra Bulgaria EOOD (“Adastra”, “we”, “our”), the owner and provider of this Website. This Policy applies to our use of any and all data collected by us in relation to your use of the Website.
References to “you”, “your” in this Policy are to the individual who is accessing or use this Website. This includes, in relation to a client or prospective client of Adastra, any sole trader and any principals, including the managing and financial directors, any other directors and officers, shareholders, partners and beneficial owners of a customer, as well as any member of staff accessing or using this Website on behalf of a client.
Please note that we may periodically change, amend, supplement, shorten or otherwise update this Policy, and the relevant new version will be published on this Website.
Adastra may use separate notices setting out information that may be provided to data subjects when collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices) or they may be stand-alone, one-time privacy statements covering processing related to a specific purpose.
Personal data controller
The personal data controller in the sense of GDPR is:
Adastra Bulgaria EOOD, UIC 175397143, Sofia 1407, 32 Atanas Dukov Str.
Data protection officer
You can contact our data protection officer at: [email protected]
What information we collect about you and how we are using it?
I. Personal data collected when accessing this Website
a) Scope and purpose of processing:
We collect and use only personal data of users to the extent necessary to ensure the functionality of our Website.
When you access our Website, we collect only personal information that your browser automatically transferred to our server. The information is temporarily stored in the so-called log-file. The following information is recorded without your intervention and stored until it is automatically deleted:
- IP address of the computer from which the request is sent
- Date and time of access
- Name and URL of the extracted file
- Website accessed (reference URL)
- The browser used and, if applicable, the operating system of your computer
The specified data will be processed by us for the following purposes:
- General administration of the Website
- Improving the security of the Website
- Statistics and analysis
b) Legal basis of processing
Article 6 (1), (f) of the GDPR serves as the legal basis for data processing. The processing of these data is necessary for the provision of our Website and thus serves to protect our legitimate interest.
Article 6 (1), (a) of the GDPR serves as a legal basis for the processing of the data we receive when you agree to the use of cookies, other than those which are strictly necessary for the proper functioning of our Website .
c) Data deletion and retention period
Personal data is deleted or blocked once the purpose of processing it has been met. Collecting the data for the provision of the Website and storing it in log-files is essential for the functioning of our Website. Therefore, there is no possibility for the user to object. Further storage may be required in individual cases if required by law.
More information for the purpose of processing of your personal data can be found in our Cookie Policy.
II. Personal data collected by subscribing to our e-newsletter
a) Scope and purpose of processing
You can subscribe for our free e-newsletter. The newsletter informs you about current news, services and activities related to Adastra. Only your email address will be processed for the subscription for our e-newsletter.
When you register for the e-newsletter we also save the IP address used by your IT system at the time of registration, which is issued by your Internet Service Provider as well as the date and time of registration. We must collect this data to investigate any (possible) misuse of your email address at a later stage and it is therefore lawful for the purposes of our security.
Personal data collected for our e-newsletter service are not shared with third parties. You may terminate your subscription to our e-newsletter at any time. You can at any time withdraw your consent to the storage of the personal data you shared during registration. A link is provided in each newsletter to allow you to withdraw your consent. By unsubscribing, you revoke the use of your email address.
b) Legal basis
The processing of your personal data for the e-newsletter is based on the following freely given consent in accordance with Article 6 (1), (a) of GDPR.
If you have registered to receive an e-newsletter, you have provided the following statement of consent:
“I have read and understood the Privacy policy and agree to it.
I would like to subscribe to the e-newsletter of Adastra Bulgaria EOOD
I am informed that I can withdraw my consent at any time without giving a reason for it using the link to unsubscribe visible and in the email, that I receive e- newsletter.
I am informed that the controller will not process my personal data after the withdrawal of my consent, and that the withdrawal of consent will not affect the lawful processing of my personal data before that moment. “
c) Data deletion and retention period
Your email address will be stored while you are subscribed to the e-newsletter. Once you unsubscribe from the newsletter, your email address will be deleted. Further storage may be required in individual cases if required by law.
III. Personal data, collected through our contact forms
a) Scope and purpose of processing
This Website contains contact forms that allows you to communicate with us in connection with a specific service that we offer. When you contact us – online or offline, we collect information necessary to fulfill your request and provide you with our services as requested by you. For instance, we collect your:
- First and last name
- Business email
If you request something from Adastra, for example, information about our services, we will use the personal data you provide to fulfill your request. To help us do this, we may share information with other companies of Adastra Group (www.adastragrp.com) involved in fulfillment. In such cases we will request your prior consent.
We will retain your information for potential future interactions with you and will use the information solely for identifying you as one of our business partner and for staying in touch with you. We may use your personal information to support services you have obtained from us.
b) Legal basis
The processing operations of personal data described are carried out in accordance with Art. 6 (1), (f) of the GDPR on the basis of our legitimate interests to contact you and fulfill your request.
c) Data deletion and retention period
We will retain your information for potential future interactions with you and will use the information solely for identifying you as one of our business partner and for staying in touch with you.
Recipients of your data
We may share your data with third parties who provide services on our behalf.
All our third-party service providers are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.
We may also share your personal data with third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property or safety of our site, our users, and others.
Where your data is shared with third parties, we will seek to share the minimum amount necessary.
We can transfer your personal data to third parties outside of EU EEA only if:
- You have given your explicit consent in accordance with Art. 6 (1), (a) of the GDPR;
- The transfer is legally admissible and necessary for the performance of the contractual relationship with you in accordance with Art. 6 (1), (b) of the GDPR;
- If there is legal obligation for us to transfer data under Art. 6, (1), (c) of the GDPR.
Automated decision making
We do not make automated decisions, including profiling you, based on personal data provided by you for the above purposes of processing.
What Rights Do You Have Regarding Your Personal Data?
You have certain rights with respect to your personal data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected] .
Please note that in some circumstances, we may not be able to fully comply with your request, such as if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include personal data, if necessary, to verify your identity and the nature of your request.
Access: You can request more information about the personal data we hold about you and request a copy of such personal data.
Rectification: If you believe that any personal data we are holding about you is incorrect or incomplete, you can request that we correct or supplement personal data by emailing us at [email protected]
Erasure: You can request that we erase some or all of your personal data from our systems.
Withdrawal of Consent: If we are processing your personal data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your personal data, if such use or disclosure is necessary to enable you to utilize some or all of our services.
Portability: You can ask for a copy of your personal data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your personal data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your personal data.
Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your personal data with the supervisory authority Commission for Personal Data Protection, Sofia, 2 Prof. Tsvetan Lazarov Blvd.
This document has been updated as of June, 2021.