PRIVACY POLICY FOR PERSONAL DATA

On May 25, 2018, the General Data Protection Regulation (GDPR) came into effect for all European Union member states. It directly applies in Bulgaria, similar to any national law, and covers the rights and obligations of data controllers, processors, and data subjects. Some details are further regulated by the Bulgarian Personal Data Protection Act.

All users of www.ef-gv.com are considered data subjects and have distinct rights in this context. The purpose of this policy is to elaborate on the principles of data protection and privacy for users of www.ef-gv.com, outline our responsibilities as data controllers, and describe the measures we’ve taken to prevent your data from being used without your knowledge or consent.

Please note that this policy will evolve over time as our website continues to exist. As digitalization advances and data processing regulations develop, we strive to continually improve and align our practices with these changes, which will be reflected in our policy.

ETHICAL FINANCE GV strictly adheres to applicable provisions in the field of data protection for every data processing operation carried out through our website.

The current Privacy Policy is valid only for www.ef-gv.com, and not for individual pages or third-party websites that you may access through redirection or similar means from www.ef-gv.com. In such cases, ETHICAL FINANCE GV does not have control over data processing by third parties and cannot guarantee the protection and integrity of your personal data.

This policy was approved by the management of ETHICAL FINANCE GV LTD on August 1, 2023, and it regulates the processing of personal data through www.ef-gv.com.

If you have any questions related to the application of this policy or wish to exercise your rights, you can contact the responsible data protection officer for ETHICAL FINANCE GV at office@ef-gv.com.

Key concepts:

Personal data - refers to any information related to you as a visitor/user of our website or software application. It can be used independently or in combination with other information to establish your identity or link your user behavior to a specific device from which you access our website.
Subject of personal data - this is you, the user of www.ef-gv.com.
Processing of personal data - it encompasses any action we perform or can perform with your personal data, including but not limited to their collection, analysis, storage, destruction, etc.
Personal Data Administrator - ETHICAL FINANCE GV LTD, registered according to the laws of the Republic of Bulgaria, with its headquarters and management address at Veliko Tarnovo, Bulgaria, is the owner of the domain www.ef-gv.com. We determine the purpose of processing your data based on one of the legal grounds provided by the law. In essence, we also define the means by which this processing is carried out – for example, the technical infrastructure and applications used for processing.
Personal Data Processor - refers to a third party that processes your personal data on our behalf. In such cases, ETHICAL FINANCE GV strictly defines the purpose of processing, the means by which it occurs, and ensures that the entity complies with GDPR requirements. An example of such a processor could be an agency responsible for ETHICAL FINANCE GV’s marketing campaign on a social network, creating reports on its performance.
Cookies - refers to small text files stored in the directories of a user’s browser. These cookies assist users in effectively using websites and making specific functionalities accessible. Cookies play a crucial role in facilitating and enhancing the usability of websites. If they are deleted or blocked, certain websites or specific features may become inaccessible to users.
Information society services - refers to services that are typically provided for payment and from a distance using electronic means. The recipient of such a service must have explicitly requested it. Electronic commerce is also a form of such a service.

Data security and protection

ETHICAL FINANCE GV takes the necessary technical and organizational measures to protect your data on www.ef-gv.com from any unlawful actions, including loss and unauthorized access. To ensure high security, these measures are implemented in two stages:

Design Stage: During the design of individual segments of the website and the offered services, we establish the purpose of processing and the means by which it occurs.
Default Stage: When you, as a user, fill out a contact form or register for receiving newsletters or similar actions.

Measures include restricting access to your personal data, strict adherence to internal policies, appropriate training for personnel responsible for processing your data, and compliance with guidelines and instructions for data protection from competent supervisory authorities. All measures undergo regular review and periodic updates. In the event of a breach of the security of your personal data, we will promptly notify you if there is a likelihood that the breach may pose a high risk to your rights and freedoms.

Data processing activities

Your personal data will be processed by ETHICAL FINANCE GV in accordance with applicable data protection legislation. When corresponding with us via email or filling out a feedback form on our website, you commit to providing accurate, correct, and up-to-date information. Through www.ef-gv.com, ETHICAL FINANCE GV collects personal data in the following ways:

Contact Form
Sign-up for Newsletter
Cookies (or other similar methods)

When visiting a website, cookies are stored on your terminal device, allowing your actions or preferences to be “remembered” for a certain period of time. For more information, please refer to our Cookie Usage and Management Policy.

Category personal data

The following categories of personal data are collected through the website:

Names
Phone number
E-mail

Storage and destruction

Personal data is stored for the periods necessary to achieve the purposes for which they were collected. ETHICAL FINANCE GV takes the necessary technical and organizational measures to destroy data that is no longer necessary, except in cases where there is a legal basis to process them for a longer period of time; upon your request for processing restriction, in accordance with your rights, as described in detail below or for a purpose compatible with the initial processing purpose, for which you will be promptly informed.

Legality

Personal data is processed on the grounds specified in Article 6 of the General Data Protection Regulation, as follows:

When you fill out the Contact Form, we process your personal data based on your consent and for the purpose of responding to your specific request (e.g., information about device models, functionalities, questions related to purchasing our devices and warranty service, positive feedback, and critiques).
When you enter your email for Newsletter Sign-up, we consider this action as an affirmative act through which you express your freely given, specific, informed, and unambiguous consent for us to process your data for the purpose of receiving a newsletter about our products and services.
You can withdraw your consent at any time, after which ETHICAL FINANCE GV will no longer send you informational materials unless you explicitly reconfirm your consent by entering your email again in the form. You can withdraw your consent by following the link in the received email with informational materials or by contacting us at office@ef-gv.com.

If you are unsure about the legal basis for processing your personal data, you can always ask us, as well as inquire about the exact manner in which you provided your consent. You can reach out to us.

Processing based on legitimate interest by ETHICAL FINANCE GV or a third party and objection to such processing

ETHICAL FINANCE GV processes your data based on consent and for the purpose of fulfilling the service you requested through the functionalities of www.ef-gv.com. When your consent is not specifically requested and given for a particular processing purpose, or when it is not directly necessary for the requested service, we most likely rely on our own or a third party’s legitimate interest that we have assessed will not harm or significantly affect your right to personal data privacy. Such assessments are always documented by us and follow specific criteria and reasoning. You have the right to be informed of the key points of this assessment upon request and to raise an objection if, given the specifics of your situation, the processing in question significantly impacts your right to privacy and/or data protection beyond what was initially considered. In such cases, we will review your objection and provide a reasoned opinion on its acceptance or rejection within a period of 10 working days. By submitting an objection to this processing, you can also exercise your right to object as described above. The objection can be sent to us at office@ef-gv.com.

Disclosure of data to third parties

ETHICAL FINANCE GV will not disclose personal data to third parties, except in cases where it is necessary to protect the vital interests of you or another natural person, or for the purpose of complying with a legal obligation applicable to ETHICAL FINANCE GV as the data controller.

ETHICAL FINANCE GV does not transfer personal data collected through www.ef-gv.com to a third country or international organization outside the European Union.

Your rights

As a data subject and a user of www.ef-gv.com, you have the following rights:

Right to information

In addition to the information provided above, please be aware that you are not subject to automated decision-making, but we do perform profiling for creditworthiness assessment purposes. According to applicable data protection legislation, you have the following rights, and we commit to responding to each of your requests within a 1-month period from receiving the request, without any fee. In cases of factual or technical difficulties that may hinder timely execution of such requests, the deadline for completion may be extended by an additional 2 months, and you will be informed of this extension within one month of receiving your request.

Right to access

You can request confirmation whether and what personal data about you is being processed, as well as access to that data.
Every piece of information, communication, and actions related to your rights are carried out and provided free of charge. However, in cases where user requests are evidently unreasonable or excessive, particularly due to their repetitive nature, ETHICAL FINANCE GV may impose a reasonable fee, taking into account administrative costs for providing the information or communication, or for taking the requested actions.

Right to rectification

If we process incomplete or incorrect personal data about you, you can request their correction or supplementation at any time.

Right to deletion

You can request the deletion of your personal data in the following cases:

Personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
You can withdraw your consent, upon which the processing of data is based, and there is no other legal basis for processing;
You consider that the personal data have been unlawfully processed.

Please note that there may be other reasons that prevent the immediate deletion of your data, such as legally regulated retention obligations, pending legal proceedings, establishment, exercise, or defense of legal claims, and others.

Right to restriction of processing
You have the right to request restriction of processing if:

You contest the accuracy of personal data, for a period that allows us to verify the accuracy of the personal data;
The processing is illegal, but you do not want the personal data to be deleted; instead, you request that their use be limited;
We no longer require personal data for processing purposes, but you request that they be used for establishing, exercising, or defending legal claims;
We have objected to the processing of data in anticipation of verifying whether the legal grounds of ETHICAL FINANCE GV for data processing take precedence over your interests.

When requested, we will inform you before lifting the processing restriction.

Right to data portability

You can request the data provided by you in a structured, commonly used, and machine-readable format when both conditions are met:

The processing of specific data is based on obtained consent or on a contractual basis;
The processing is carried out by automated means.

Right to objection

You have the right, at any time and on grounds related to your specific situation, to object to the processing of your personal data based on legitimate interest or when it is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, including profiling based on these grounds.

When you have given your consent for data processing for the purposes of direct marketing, you have the right to object to the processing of personal data at any time, without specifying grounds.

Right to lodge a complaint

If you believe that we have violated applicable data protection legislation in the processing of your data and as a result have affected your rights, please contact us. Of course, you also have the right to complain with the supervisory authority. In Bulgaria, this is the Commission for Personal Data Protection.

Dispute resolution and applicable law

In case of disputes, the applicable law is the law of the Republic of Bulgaria, and the competent court is the relevant court in Veliko Tarnovo.

Any disputes between ETHICAL FINANCE GV and users of www.ef-gv.com regarding personal data can be resolved through negotiations between the parties. In the unlikely event of a legal dispute, it should be referred to the Commission for Personal Data Protection or directly to the competent court in Veliko Tarnovo.

Updates

The Privacy Policy for Personal Data comes into effect from the date indicated at the beginning, and it may be amended subsequently. The updated policy takes effect on the day of its publication on www.ef-gv.com. If You visit www.ef-gv.com after a change in the policy, You will be bound by the new Privacy Policy.

For additional information, as well as regarding the exercise of Your rights, you can contact us at office@ef-gv.com.