We are committed to respect the privacy of your personal data. Within the present document we describe your rights related to the protection of your personal data, which we process in the course of our business activity.

Should you have any questions or comments on the manner in which we govern and process your personal data or you wish to exercise any of your rights, as mentioned below, you may reach us via the following electronic address: management@iow.bg

You may also use this address to express your concerns with regard to our compliance with the present document.

Which is the controller of your personal data?

IOW Bulgaria EOOD, UIC 131111220, having its registered seat and address at 1186, German village, 3 Smrekata street (hereinafter referred to as “IOW”, “the Company” or “we”)

Which is the supervisory authority?

The supervisory authority as regards the processing of personal data by IOW is the Commission for Personal Data Protection of the Republic of Bulgaria, e-mail: kzld@cpdp.bg, website: https://www.cpdp.bg/.

Whose personal data we collect and process?

In the course of the business activity of IOW and for the performance of this activity, we collect and process personal data pertaining to:

  • Website visitors/users as well as visitors of our social media profiles
  • Job Applicants
  • Participants in events organized by IOW
  • Clients

As clients we refer to both individual clients, as well as to legal representatives/ employees of a corporate client, including where our business relationship are established via our website.

For the purposes of the activities of IOW as regards our obligations under the Measures against Money Laundering Act (MAMLA), along with data concerning clients pieces of personal data pertaining to other persons may be collected.

These may be individuals who are the beneficial owners of a corporate client and/or individuals who are the legal representative of entities.

  • Service providers

As service providers we refer to individual service providers, as well as to legal representatives/ employees of a corporate service providers.

  • Visitors of our premises/offices

What personal data we collect? How do we obtain them and why do we process them?

Personal data we collect upon your visits of our corporate website and our social media profiles

Personal information we collect when you visit our website may include information you provide voluntarily as well as information collected automatically.

WE collect personal data that you provide voluntarily via our website, such as when filling in online forms/ applications/ inquiries/ complaints or when you use our email to reach us. This information may include name, positions and company (employer), contact details such as email and phone number, as well as other personal information, which you freely decided to disclose. We also collect these data you subscribe for receiving of bulletin or other marketing communication from us, as well as when you participate in surveys/ promotions and games, organized by the Company.

We also collect your personal data when you create a profile on our website, as in this case along with the identification data above, we also receive data of your account name. Should you use this account name to make an order for purchase of our products we may also, for the purposes of the order, collect additional details, e.g. delivery address. In this regard, please refer to the relevant section of the present Information Notice which relates to Clients of IOW.

If you visit our website/ social media profile in order to apply for a job, we will also collect date related to your application. For more information, please refer to section Job applicants at IOW.

When you visit our website, we automatically collect particular personal details. This information collected automatically may include your IP address, device type, device unique identification number, browser type, geo-location, webpages visited, time and date of visit as well as other technical information.

Collecting this type of information allows us to better understand our website visitors, where they come from and which elements of our web content is of interest to them. We use this information for internal analytics purposes and for improvement of the quality and suitability of our website in terms of you visitors’ preferences.

Some of the data we collect by the use of cookies and other similar technology. More information in this regard may be found in our Cookies Policy.

Personal data about you may also be collected and processed when you visit our pages/profiles in social media, including when you use these to contact use. We also receive data on you adding our page to favourites, like-ing our published content, as well as data about the total number of visitors and other similar details concerning your activity in social media. All this data we receive from the company that owns the platform.

Please bear in mind that IOW is not responsible for the governance of social mead or their data collection and processing practices, including for the use of cookies, analytics, web beacons and other similar technology. Should you prefer of deem it necessary, you may exercise your rights concerning data protection towards the providing company.

Personal data we collect when you apply for a job

In order to review and assess your job application for a position at IOW, we collect personal data as follows:

  • Names (name and surname)
  • Contact details – e-mail address and phone number
  • Curriculum Vitae (CV)
  • Cover letter
  • Letters of reference
  • Education details
  • Previous employment

Why do we collect this information?

We use this information in order to assess whether your skills, motivation, education and professional experience math IOW requirement for future employees.

The information you provide upon applying is viewable only for IOW employees who are responsible for the recruitment of personnel to enable them to assess your suitability, to review the evidence of qualification provided, as well as to contact your and set an interview. In the course of the interview we may collect additional information you share meanwhile.

How do we collect information?

We collect personal data of job applicants at IOW via the following channels:

  • Directly from you – when you send us your application via IOW’s website or via postal service or when you personally provide your application documents in the course of event organized by IOW
  • Job searching platforms – when you apply for a job via platforms facilitating publishing of job advertisements such as jobs.bg
  • Publicly available sources – e.g. if you own a professional profile online (on the website of your current employer or on website facilitating professional communication, such as LinkedIn)

What else do you need to know?

If you apply through our website, we will collect other information as well. For more details, please refer to the section above concerning IOW website visitors.

If you are included in our shortlist of successful job applicants and you are about to start, we will need to collect additional information, e.g. additional contact information, including corporate email, personal and/or company phone number, personal and business address, photo, date of birth and other.

In relation to the constitution of employment with IOW, IOW will collect, store and process the above listed personal data, as well as other personal details, including as necessary PIN, conviction status, health condition (if necessary), remuneration details, bank account details and other.

As regards the processing of your personal data in the area of employment, we will present you with additional information upon signing of your employment contract.

Personal data we collect when you participate in events organized by IOW

We collect personal information, which you provide freely when you register for an event organized by IOW.

When you register for an event organized by IOW, including via our website, by filling in an online form or via email, you provide us with information that includes the following: name, position and company (employer), contact details, such as email address and phone number.

We collect your personal details in view of organizing the event, your inclusion in guest list for the purposes of the access regime, issue of a badge.  We use your contact details to inform you of relevant details concerning the event (venue; date), as well as to send you necessary or requested materials, such as presentations, brochures and others.

If in the course of particular event, e.g. a career development event, you provide us you’re your job application for a position within the Company, we will process additional data, e.g. CV, etc. For more information, please refer to the section on the personal data we collect when you apply for a job.

Personal information we collect for our clients

In the course of its business activity, IOW collects personal data for its clients, including:

  • Full name
  • Personal Identification Number or Personal Number of Foreigner
  • Main Address
  • Other contact details, such as address, e-mail, phone number
  • Position
  • Employer
  • Bank details, such as credit/debit card details, IBAN or other payment account number

We also collect and process data, including information for reclamations, requests for remedy of defects, complaints, applications, grievances, etc.

We collect information about offers sent, data on the development of our contractual relations, as well as all other information concerning the business relations, including financial information (payments data; bank account; data in accounting documents), phone calls records (if admissible), as well other feedback received from client.

In accordance with MAMLA, IOW is obliged to identify its clients and whereas the client is an entity, IOW shall identify its beneficial owners.

In connection with the above identification, we collect the following pieces of personal information:   

Full name; date and place of birth; official personal identification number of other unique identity identifier, included in official identity document, the period of validity of which has not expired and has a photo of the client; any citizenship acquired; country of residence and address; copy of the presented identity document. We also gather data about the professional and business activity of the client as well as other data in accordance with the requirements of the law.

How do we collect the information?

In the course of exercising our business activity, IOW collects personal data via the following channels:

  • Directly from you – when you send us requests, register on our website, submit forms and documents for participation in different initiatives, e.g. surveys/ games or events
  • Publicly available sources – data from Commercial Register, including published financial statements, Register of Non-profit Legal Entities, professional profile online (on the website of the company you represent or work for, or on a website facilitating professional communication, e.g. LinkedIn), information published in the media

Why do we use your personal data?

We use your personal data in the course of the performance of our activities upon establishment of relations with potential and current clients, for establishment of our position at the market and others. In particular, we process your personal data for the following:

  • Drafting of contract offers and conclusion of contracts
  • Administration, management and performance of clients’ request or orders concerning our products or services, performance of contracts for products or services
  • Drafting and sending receipts/ invoices
  • Collection of sums
  • Performance of deliveries, client support, rendering technical assistance, including upon grievances or complaints from clients
  • Sending of marketing messages, brochures and other types of letters concerning the products and services of IOW
  • Marketing surveys and analyses in connection with the demand for our products and services, including for the establishment of the main trends in market demand.

What else you need to know?

If you use our website for creating an account and for sending orders, register for events or participation in surveys of games, as well as when you use our contact form to send us reclamations, complaints, grievances or other communication, we will also process your personal data in your capacity as website visitor/user, including via electronic means upon loading of our webpage.

For more details, please refer to the section above concerning visitors/ users of IOW website.

Personal data we collect for our service providers

In the course of the performance of our business activity we rely on the services of a variety of other companies or individuals. To access different products and services necessary for our activities, IOW collects personal data for its service providers, including:

  • Full name
  • Personal Identification Number or Personal Number of Foreigner
  • Main Address
  • Other contact details, such as address, e-mail, phone number
  • Position
  • Employer
  • Bank details, such as IBAN or other payment account number

How do we collect the data?

In the course of exercising our business activity, IOW collects personal data about you via the following channels:

  • Directly from you – when you send us offers, advertisements, proposals for your products or services, when you create account on our website, submit form and documents for participation in different initiatives.
  • Publicly available sources – data from Commercial Register, including published financial statements, Register of Non-profit Legal Entities, professional profile online (on the website of the company you represent or work for, or on a website facilitating professional communication, e.g. LinkedIn), contact details provided on the Internet and information published in the media

Why do we use your personal data?

We use your personal data in the course of the performance of our activities upon establishment of business relations with you in connection with purchasing products and services offered.

We process your personal data in relation to the conclusion and performance of contracts for products or services, including for payment of due fees, accounting, drafting and sending of receipts/ invoices/ delivery protocols, receiving of materials and consumables, installing of equipment and post-guarantee service, contacting you, including for sending grievance or complaint and other similar purposes related to the business relations between you and IOW.

What else you need to know?

If you use our website for creating an account, register for events or participation in surveys of games, as well as when you use our contact form to send us reclamations, complaints, grievances or other communication, we will also process your personal data in your capacity as website visitor/user, including via electronic means upon loading of our webpage.

For more details, please refer to the section above concerning visitors/ users of IOW website.

Are there other scenarios when IOW will collect and process personal data for you?

Security measures

We may collect your personal data when you visit of offices, bases and other premises, managed by IOW. Processing of your personal data may amount to registering you as visitor or constitute video surveillance or any other suitable measure which requires the processing of your data, e.g. issuance of a visitor’s badge.

Additional information concerning the above processing will be made available at the respective premises:

  • IOW office at 1186, Sofia (German), 3 Smrekata Str.

Automated decision making, which includes profiling

We do not process your personal data for automated decision making, which includes profiling.

Legal bases for processing your personal data

In brief, we process your personal data on the grounds of:

  • Your consent, provided for one or more particular purposes
  • Contract, including pre-contract stage, between you and IOW
  • Obligation, provided for in a legislative act
  • Legitimate interests

Our legal basis for collecting and processing your personal data as described above varies depending on the particular personal details and the context in which we collect them, e.g. upon visit of our website, applying for a job or within our business (professional) relations with IOW as a client or a service provider.

Under normal circumstances, we will collect personal data for you only when we have obtained your consent (when you apply for a job), where we need your data to undertake certain activities for the conclusion or performance of a contract with you (e.g. when you or the entity you represent become our client), or when the processing of your data pursues the satisfaction of our legitimate (legal) interests, which are not overridden by your right of privacy or other fundamental rights and freedoms of yours (e.g. tracking website visits, sending of marketing messages, when you are already our client, video surveillance at our premises).

In some cases we may have a legal obligation to process your personal data or we may need to process them to exercise, establish of defense against legal (court) claims, e.g. for tax compliance purposes when we make payments for services delivered by you as service provider.

We will strive to inform you of the legal bases for processing when we collect your data directly from you and will always be available if you need any additional clarifications in this regard. We will also explain whether the provision of personal data is a statutory or contractual obligation or is otherwise necessary to perform an act requested by you (e.g. bank account details to make payments or e-mail address to send you the materials you requested and other similar cases), as well as the potential consequences if you decline to provide your data in the particular case (e.g. that we will not be able to send you requested materials/brochures).

If you have any questions or concerns on the legal basis, on which we collect and use your personal information in the course of our business activity, please contact us by sending email to management@iow.bg

How long do we store your personal data?

We keep your personal data for no longer than is necessary to meet the purposes for which this personal data has been collected. Upon expiration of this period, your personal data will be securely deleted, as long as it is no longer required for the conclusion or performance of a contract, for securing court proceedings or if the applicable law explicitly does not require your personal data to be processed for a longer period of time (e.g. our obligation to store invoices). Where we comply with our statutory obligation to retain your data for a longer period, your data will be stored where possible in a form that does not allow for your identification and will not be otherwise processed until the expiry of statutory period of storage.

Who will we share your personal information with?

We undertake to share your information only amongst employees of IOW who require your information to perform their job functions, e.g. team leaders in whose team you may be included, relevant hiring managers, our accounting team if you are a client/ provider administrative staff, etc. on a need-to-know basis, as well as the management officials of IOW. All of the mentioned individuals are under duty of confidentiality in terms of further disclosure of your personal information.

Sometimes IOW need to share your personal information with our partner organizations. When this is necessary, e.g. for accessing the services of IT providers for development of our systems and technical maintenance; auditors and consultants, who assess the compliance of our activity with various regulatory requirements; legal advisors securing our legal interests; successors of the Company or business partner in case all of part of the Company is sold, restructured or merged with another company, including in the course of due diligence processes for this purposes and other cases, we will comply with all aspects of applicable European and national data protection legislation.

Whenever necessary or required, we share information with:

  • IT services Providers
  • Equipment Providers
  • Legal advisors
  • Auditors and consultants
  • Banks
  • Insurance companies
  • Printing companies
  • Other service providers, e.g. corporate events organizers, couriers and others
  • Legal successor of the Company, other company of the IOW group of companies or business partner of ours
  • Public authorities of the Republic of Bulgaria (in compliance with applicable legislation).

Do we transfer your data to countries outside the European Economic Area?

We do not transfer your personal data to countries or territories outside the European Economic Area.

What are your rights?

The General Data Protection Regulation guarantees you a certain set of rights that you may exercise in relation to your personal data processed by us. In summary, you have the following data protection rights: to access, correct, update or request deletion of your personal information or the restriction of their processing. You may also be entitled to object to the performed processing (when we process data on legitimate interest grounds) or may have the right of data portability.

If you wish to exercise any of your rights, you can do so at any time by contacting us via electronic mail sent to the following email address: management@iow.bg

In more details

Right of information: You have the right to receive relevant information of our processing of you data, which is actually the purpose of this Policy. However, at any time you may contact us to receive additional information or clarifications on whether and how IOW processes any of your personal data

Right of access: You have the right to get free information about the nature, volume and way we use your personal data, and get a copy of this information. In addition, you have the right to receive information about the recipients of your data, including whether your personal data is being transferred to a country or an international organization located outside the European Union. If such a transfer takes place, you have the right to be informed of the appropriate precaution measures taken to protect your personal information.

Right of Rectification: You may request from us within a reasonable time to supplement and / or correct incomplete, inaccurate or outdated personal data.

Right of Erasure: You may require the deletion of your personal data and we are obliged to delete the personal data without undue delay, unless there is a legitimate legally prescribed reason to deny your request, e.g. when the processing is mandatory under the applicable legislation.

Right to Restriction of Processing: In the event that personal data that we process is inaccurate or obsolete or if you deem our processing unlawful, you have the right to ask us to limit / suspend the processing of such data for a period that allows us to verify the accuracy of the information and correct it accordingly, or until we resolve the matter of the legality of our processing.

Data portability: This right allows you to get your personal data in a structured, machine-readable format.

You are entitled to data portability inly where we process your personal information on the basis of consent or for the conclusion/performance of a contract and provided that the information itself is processed via automated means.

Right of objection: You may object to processing performed by IOW at any time on grounds relating to your particular situation (applicable when processing your data is done on the basis of a legitimate interest of IOW or a third party). In any case you may object to processing for the purposes of direct marketing (if performed on this legal basis).

Right to withdraw consent: When processing your personal data is based on your consent, you are entitled to withdraw it at any time. This can be done online by contacting us via email: management@iow.bg or in our office or via postal service at IOW address.

Withdrawal of your consent does not affect the legality of the processing prior to the consent withdrawal.

Right to Complain before the Surveillance Authority: If you believe that your privacy and data protection rights have been violated, you have the right to contact the Bulgarian Data Protection Commission. CPDP data is contained at the top of this Policy.

To exercise any of the above rights, you may contact us at any time via management@iow.bg or personally at our office. Before we can fulfil your request, we may ask for additional information to verify your identity.

Security of processing

As controllers, we maintain and require from our partners and suppliers appropriate technical and organizational measures to protect and safeguard your personal data processed.

Changes to this Policy

This Policy was last updated on 11.09.2019. We may change its contents by updating this page to reflect changes in applicable legislation or IOW privacy practices. However, we will not use your personal data in new ways without your knowledge or consent.

External links

Our website and services may provide links to other websites through direct links or through third party applications. IOW do not control these sites or their privacy practices, so we recommend that you familiarize yourself with their privacy practices before sharing your personal data with these platforms.