The website www.abopharma.info that you are viewing is operated by TECHNOCOM TRADE LTD., UIC 130375886, with registered office and management address at 168 Tsar Boris III Blvd., Sofia (hereinafter referred to as TECHNOCOM TRADE or the COMPANY).  

TECHNOCOM TRADE LTD. regards the confidentiality of your personal information as a priority and undertakes to comply with statutory data-protection requirements. This Policy explains the principles governing the protection and personal data of users of www.abopharma.info, our responsibilities as data controller and the measures we have taken to prevent your data from being used without your knowledge of who is using it and for what purposes, or without your being able to object or withdraw consent to its processing.

This Policy will change over time in response to developments in personal-data protection regulation and TECHNOCOM TRADE’s commitment to improving and aligning its practices with the latest developments in the field. TECHNOCOM TRADE strictly applies the relevant personal-data protection provisions to all personal-data processing carried out through the website.

This Privacy Policy applies only to www.abopharma.info and not to separate pages or third-party websites reached through links or by similar means from www.abopharma.info. In such cases, TECHNOCOM TRADE has no control over processing by third parties and cannot guarantee the protection and confidentiality of your personal data.
  
This Policy was approved and took effect on 25 May 2018 and governs the processing of personal data through www.abopharma.info.
You may contact TECHNOCOM TRADE with any questions about the application of this Policy or the exercise of your rights at info@abopharma.info.
Please take a moment to read this Privacy Policy. If you have any questions, please contact us using one of the methods described below.

I. Key Definitions
„Personal data“ means any information relating to you, as a visitor to or User of our website or software application, which alone or in combination with other information may enable us to identify you or associate your user behaviour with a specific device from which you access our website.

„Data subject“ means you, the User of www.abopharma.info.
„Processing of personal data“ means any operation that we perform or may perform on your personal data, including but not limited to collection, analysis, storage and destruction.

„Data controller“ means TECHNOCOM TRADE LTD., a company incorporated under the laws of the Republic of Bulgaria, with registered office and management address at 168 Tsar Boris III Blvd., Sofia, Republic of Bulgaria, entered in the Commercial Register of the Registry Agency of the Republic of Bulgaria under UIC 130375886 and owner of the www.abopharma.info domain. We determine the purpose of processing your data on one of the legal grounds provided by law and the means used for that processing, including the technical infrastructure and applications through which it is carried out.

„Data processor“ means a third party that processes your personal data on our behalf, where TECHNOCOM TRADE has strictly defined the purpose and means of the processing and has verified that the person complies with GDPR requirements. Such a processor may, for example, be an agency responsible for a TECHNOCOM TRADE social-media marketing campaign that prepares performance reports.

„Cookies“ are small text files stored in the directories of the browser used by the User. Cookies help Users use websites efficiently and make certain functions available. They play an important role in making websites easier to use and improving usability; if they are deleted or blocked, some websites or certain functions may become unavailable to Users.

II. Personal Data We Collect Through the Website
– Information collected may include data about your service provider, operating system, browser type, domain name, the IP address of your computer or other electronic device used to connect to the internet, the time you visit the website, the website from which you followed a link to the TECHNOCOM TRADE website, the web pages you searched and the date and time of the search. When the website contact form is used, we also collect the person’s name, telephone number and email address, together with any additional information they choose to provide.

– In connection with complaints, applications, requests, petitions and reports, including free-text submissions: unstructured information contained in the relevant submissions and information relating to the outcome of their processing;
– In connection with subscribing to newsletters and other marketing communications about products, promotions, events and other current information, including commercial offers, events and media publications: first and last name, email address and additional information about the subscriber;
– „Cookies“: the use of cookies is necessary for the Website to function. A detailed description of the cookies used, their purpose and the information processed through them is available in the Cookie Policy.
– Other data: TECHNOCOM TRADE may process other data relating to you where you provide such data voluntarily by completing the relevant electronic forms on the Website, adding preferences, settings or similar information.

III. If You Do Not Wish to Provide Your Personal Data
Whenever you have the option to decide whether to share your personal data with us, you may choose not to share it.
If you object to our processing of your personal data, we will respect your wishes in accordance with our legal obligations. Your objection may mean that we are unable to carry out activities necessary for the purposes described below. It may also mean that you cannot use the services and products we offer if you do not provide personal information or if, after providing it, you object to our processing it. 

IV. We Use Your Personal Data for the Following Purposes:

– Communicating with Users who are data subjects and sending informational messages;
– Handling reports, complaints, requests to exercise rights and similar submissions, including preparing responses;
– Keeping logs of electronic declarations;
– Other activities required to fulfil legal obligations, including providing information to competent state and judicial authorities and assisting with inspections by competent authorities;
– Ensuring that the Website functions normally and can be used by data subjects and third parties, including maintaining and administering the Website, preventing cyberattacks and other malicious acts;
– Designing, developing and improving Website functionality;
– Exercising and protecting the rights and legitimate interests of TECHNOCOM TRADE, including through legal proceedings, and assisting in the exercise and protection of the rights and legitimate interests of other Website visitors;
– Managing and controlling the quality of services provided by TECHNOCOM TRADE;
– Sending marketing and advertising communications about products, services, special offers, packages, events and similar matters;
– Conducting surveys and obtaining feedback on service quality;
– Sending newsletters;
– Other purposes for which the data subject has specifically given consent.

Change of Purpose
TECHNOCOM TRADE will use your personal data for the purposes for which they were collected, unless it reasonably determines that they should also be used for another purpose that is compatible with the original purpose.
If your personal data need to be used for a purpose incompatible with the original purpose, TECHNOCOM TRADE will inform you promptly and explain the legal basis permitting their use for the new purpose.

V. Legal Basis
TECHNOCOM TRADE processes your personal data on the grounds set out in Article 6 of the General Data Protection Regulation, as follows:
– Performance of a contract;
– Legal obligation;
– Legitimate interest;
– Consent.

When you complete the Contact Form, we process your personal data on the basis of your consent and for the purpose of responding to your specific request.
If you subscribe to our newsletter, we process your data on the basis of a freely given, specific, informed and unambiguous statement of consent to processing for the purpose of receiving a newsletter about our products and services.

You may withdraw your consent at any time, after which TECHNOCOM TRADE will no longer send you informational materials unless you expressly provide consent again by re-entering your email address in the form. You may withdraw consent by following the link in an email containing informational materials or by contacting info@abopharma.info.

Where your consent has not been requested and given for specific processing, and that processing is not directly necessary to provide a service you requested, we will most likely rely on our own or a third party’s legitimate interest, having determined that it does not prejudice, or affects only insignificantly, your right to privacy. We will always document this assessment against defined criteria and supporting reasons.

VI. Retention Period for Your Data
As a general rule, TECHNOCOM TRADE retains personal data only for as long as necessary to fulfil the purposes for which they were collected, including compliance with legal requirements.

Types of Data	Retention Period	Explanation
Logs	For one (1) year. In accordance with the requirements of the Electronic Document and Electronic Trust Services Act, logs are retained for one (1) year.	As an intermediary for electronic statements within the meaning of the Electronic Document and Electronic Trust Services Act, TECHNOCOM TRADE must retain log information about the time and source of every electronic statement made through the Website. In addition, to ensure the security of the Services, normal Website operation and the protection and exercise of the legitimate rights and interests of TECHNOCOM TRADE and other Website users, data retained for this period may include logs of Website sign-ins and sign-outs, deletion of Website data, access to Website data and other similar legally significant actions performed on the Website.
Email Newsletter Subscription Data	For as long as the subscription remains active, until it is terminated	The subscription may be terminated at any time. When the data subject withdraws consent to receive the email newsletter, the subscription data required to send it are deleted.
Correspondence, Complaints and Reports	Correspondence, complaints and reports are retained for up to five (5) years.	To resolve complaints, reports, disputes, enquiries, requests or other matters communicated to us through the Website or by conventional or electronic mail, we retain and process that information and the outcome of its processing. In view of the limitation periods under Bulgarian law and for the purpose of resolving disputes, this information is retained for up to five (5) years.

 

Where a legal dispute or proceeding requires data to be preserved, or where a competent state authority requests it, data may be retained beyond the periods stated above until the dispute or proceeding has been finally concluded at every level. These periods may be changed if applicable legislation establishes a different retention requirement.

 

VII. Disclosure of Your Personal Data to Third Parties
TECHNOCOM TRADE may share your personal data with the following categories of third party:
– Tax authorities and other state bodies and institutions in the event of an inspection;
– Service providers, such as IT and systems-support providers;
– Professional advisers, such as accountants, lawyers, bankers, auditors and insurers;
– Courts, arbitration tribunals, the Consumer Protection Commission, the Commission for Personal Data Protection and similar bodies for the purposes of legal proceedings or inspections;
– An external consultant providing marketing services.
TECHNOCOM TRADE requires all third parties to respect the security of your personal data and process them in accordance with the law. TECHNOCOM TRADE does not permit third-party service providers to use your data for their own purposes, but only for specified purposes and in accordance with its instructions.

VIII. International Transfers of Personal Data
TECHNOCOM TRADE does not transfer your personal data outside the European Economic Area; in other words, data are not transferred to countries that do not provide a level of personal-data protection equivalent to that under Bulgarian law.  
Where necessary, TECHNOCOM TRADE may disclose your personal data to third parties that will process them in accordance with our instructions or the law.

IX. Data Security

TECHNOCOM TRADE takes measures to protect personal data against accidental loss and unauthorised access, use, alteration or disclosure. Access within the company is restricted to employees, contractors and other third parties who need it for their work and official duties. They will process your data only in accordance with instructions issued by TECHNOCOM TRADE and are required to maintain their confidentiality.

X. Links to Other Websites
The TECHNOCOM TRADE website may contain links to third-party websites and applications. Clicking these links may enable those third parties to collect or share data about you. TECHNOCOM TRADE has no control over those websites and is not responsible for their data-protection policies. You should therefore read their policies carefully.

XI. Conditions Applicable to the Consent of a Person Under 18 in Relation to Information Society Services
Where the processing of a data subject’s personal data is based on their express consent and relates to the direct provision of information society services to a data subject under 18 years of age, the personal data of that data subject will be processed only after consent has also been given by their parent, guardian or custodian.
 
XII. Your Legal Rights
Personal-data protection law grants you certain rights, including:
1. Right of access, including the right to a copy of data being processed:
You may request information about the personal data we hold about you at any time. Contact us with a written request and proof of your identity, and the data will be provided to you;
2. Right to rectification of inaccurate personal data:
You have the right to request correction of your personal data if they are inaccurate, including completion of incomplete personal data. You may do so through your profile or by submitting a written request to us.
3. Right to erasure (‘right to be forgotten’) in the following cases:
– The data are no longer necessary for processing;
– Consent is withdrawn where processing is based on consent;
– The data have been processed unlawfully;
– There is a legal obligation to erase the data;
The right to be forgotten is not absolute and may not be upheld in cases provided for by law or where your identity has not been duly verified.
4. Right to restriction of processing where:
– The accuracy of the data is contested, for the period required to verify their accuracy;
– Processing has no legal basis, but you request restricted processing instead of erasure;
– The data are required to establish, exercise or defend your legal claims;
– An objection to processing has been submitted, pending verification of whether the controller’s grounds are lawful.
If personal data are rectified or erased, or processing is restricted, we will notify every recipient to whom the data were disclosed unless doing so is impossible or requires disproportionate effort.
5. Right to portability of machine-readable data:
If your personal data are processed by automated means on the basis of your consent or for the performance of our contractual relationship, you may request that we provide them to you in a machine-readable format for transfer to another data controller.
6. Right to object to processing:
You have the right to object to processing of your personal data based on the legitimate interests of the controller or a third party. The controller will cease processing unless compelling legal grounds are demonstrated that override your interests and rights, or unless processing is required in connection with litigation or other judicial or extrajudicial proceedings.
7. Right to lodge a complaint with a supervisory authority:
If you believe that we are in breach of applicable law, please contact us so that the matter can be clarified. You also have the right to lodge a complaint about our processing of your personal data with the Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, or at www.cpdp.bg.

XIII. Dispute Resolution and Applicable Law
Any dispute is governed by the law of the Republic of Bulgaria and falls within the jurisdiction of the relevant court in Sofia.
Any dispute between TECHNOCOM TRADE and users of www.abopharma.info concerning personal data may be resolved through negotiation between the parties. In the unlikely event of legal proceedings, the dispute should be referred to the Commission for Personal Data Protection or directly to the competent court in Sofia.

XIV. Amendments to This Privacy and Personal Data Protection Policy
Various circumstances may require this Privacy Policy to be amended and improved periodically. Amendments will take effect immediately upon publication at www.abopharma.info. If you visit the website after the Policy has been amended, you will be bound by the new Privacy Policy.
For further information or to exercise your rights, you may contact us using the following details:

TECHNOCOM TRADE LTD.
168 Tsar Boris III Blvd., Sofia 1618
Tel. 02/955 94 13
e-mail: info@abopharma.info