1. What is personal data?
Personal data is information which can be used to find out details about your personal or financial situation. Information which cannot (unless a disproportionate effort is made) be used to establish a link to you, e.g. by the use of pseudonyms or by making information anonymous, is not regarded as personal data.
2. Which data do we store and use?
We may collect on our websites (email, telephone, post and in person) and process the following personal data from you:
Information that you provide by filling in forms on our website, for example, your name and email address. This includes information provided at the time of placing an order through our website;
If you apply for one of our competitions we will collect the following data to keep you updated and maintain a list of competitors: your name, email, country. If you join our competitions we will also collect your full name, phone number and address to inform you upon winning and to ensure that you receive your prize;
If you register to receive our newsletter, we will ask you to provide your email address to maintain contacts and regularly inform you about news, events and other related information;
Details of your visits to our websites including, but not limited to, traffic data, location data, weblogs, IP address, date, time and the resources that you access;
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
We may also ask you for information when you report a problem with our website;
If you contact us, we may keep a record of that correspondence for security purposes.
You can decide yourself whether or not to provide this data. However, without it, we cannot offer the services you require or the services may be available only to a limited extent. Your data is deleted as soon as it is no longer needed.
3. Data processing purposes and legal basis
3.1. Based on your affirmative consent that you have given by submitting your request for order or filling in some the contact form on our website we use personal data held about you for the following purposes:
- To provide you with products and services that you request from us, or information about them where you have asked to be contacted for such purposes;
- If you contact us to send you tailored information and offers and to contact you in relation to any service we provide;
- Where you have registered your interest as a supplier or you have applied for a job or internship – to assess your application and consider your suitability, to contact you in relation to your enquiry and to add you to our databases so we can contact you about potential jobs that may be of interest;
- To notify you about changes to our service and in certain circumstances, to contact you with information about goods and services which we feel may interest you by post, telephone or other electronic means (e-mail or SMS) (see the section on ‘Marketing’ below for further information). The provision of this information is entirely voluntary and you may withdraw your consent at any time or object to receiving marketing communications (see more information about your rights in section 11).
3.2. Based on our legitimate interests to administer the websites and to interact with users we may collect your data:
- To ensure that content from our websites is presented in the most effective manner for you and for your computer;
- To allow you to participate in interactive features of our service, when you choose to do so;
- To maintain the security of our websites.
3.3. If you have taken part in our competitions, on the grounds of your consent, we will use your data to inform you upon winning and to ensure that you receive your prize; Your participation in the competitions and the provision of your personal information is entirely voluntary and you may withdraw your consent at any time (see more information about your rights in section 11). You must be aware though that if you do not provide us with this information we may not be able to participate in the events.
3.4 If you have entered into any contract with us or provided us somehow with your contact details, we may send you marketing communications related to our services and goods based on your consent to promote and improve our services’ quality. You can opt out or object to receiving such information and marketing communications by clicking on the link “unsubscribe” below each marketing message you receive or by sending us an e-mail with text “no marketing communications” to [email protected] For more information about marketing, see point 5 below.
4. IP addresses and cookies
4.1. When you access our websites, we may collect information about your computer including, where available, your IP address, operating system and browser type for system administration. This is statistical data about our websites users’ browsing actions and patterns and does not identify any individual.
4.2. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies are small text files which contain information that is transferred to your computer’s hard drive. They help us to improve our Websites and to deliver a better and more personalised service. They enable us to:
- Estimate our audience size and websites usage patterns;
- Store information about your preferences and so allow us to customise our websites according to your individual interests;
- Speed up your searches; and
- Recognise you when you return to our websites.
5.1. We would like to provide you with information about our news and most recent services which may be of interest to you, so we may use your data to contact you for such marketing purpose by post, telephone or other electronic means (e-mail or SMS).
5.2. If you are a corporate user, we will send marketing communications to your company e-mail address unless you have opted out. We will give you the opportunity to opt out of receiving marketing communications from us when we first contact you. Also, you can change your marketing preferences at any time by clicking on the “unsubscribe” link in any of our marketing communications or by contacting us at [email protected]
5.3. For non-corporate users, we will only send marketing communications to your personal e-mail address or SMS messages if those communications relate to goods, services or opportunities which are similar to services we have already provided to you in the past or which you have expressed an interest in, or if you have consented to us contacting you in this way.
5.4. You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right at any time by clicking on the “unsubscribe” link in any of our marketing communications or by contacting us at [email protected]
6. How do we protect personal data ?
6.1. All information you provide to us is stored on our secure servers.
6.2. If you decide to share your information with us through e-mail or our websites, you must be aware that our e-mail and website are encrypted using SSL technology and provide secure data transmissions. Unfortunately, the transmission of information via other channels such as social media networks (e.g. Facebook, Instagram etc.) is not completely secure and we cannot guarantee the security of your data transmitted to us. Any such transmission is at your own risk, so we strongly advise you to use our official website and e—mail for any communication and sharing your personal information.
6.3. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access and keep the information secure, confidential and integral.
We store all the documents and other devices containing personal data in secured storages in our premises with limited access, especially the data which contains “sensitive” information. Our information security systems and databases have also very high protection against external risks and we use very strict staff and technical measures to prevent breaches in data security.
7. Protection of minors
Persons under the age of 18 years should not transfer any personal data to us without the consent of their parents or guardian. We do not request personal data from children and teenagers. We do not consciously collect any such data or transfer it to third parties.
8. For how long do we keep your personal data ?
8.1. Depending on the purpose for which we have collected your data, we may keep it for different periods, but in any case, this will not be longer than what is needed for the purpose of the specific data processing. Including for the purposes of satisfying any legal, accounting or reporting requirements.
8.2. In general, we hold your information for 7 years after your last contact/correspondence in case of complaints or legal claims.
8.3. Where we have been using your personal data to provide you with marketing, we will retain this information for 7 years and we will delete immediately your personal data following your request to be removed from our marketing list.
8.4. When you have sent us your personal details for competition attendance we will retain this information for 3 years after you have submitted it, unless you have re-confirmed your interest in the meantime.
9. Disclosure of personal data
9.1. We share your personal data with the following third parties, who act as our data processors processing data on the basis of contracts that we have with them and which require them to fully comply with the Data Protection Laws and to keep your personal data secure and confidential:
- Our websites hosting provider;
- Fulfillment service providers, for example e-mail marketing platforms, event invitation service providers, payment processors, delivery processors, accounting and legal services.
9.2. Occasionally, we may need to disclose your personal data to third parties where necessary for the legitimate interests of business or in order to comply with legal obligations:
- In the event we are obliged by law to disclose your data to public bodies;
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If JWAX CO is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
10. Transferring your data to third countries
10.1. The personal data we collect from you may be transferred to, and stored at, a destination outside the European Union (EU) and the European Economic Area (EEA).
10.2. Our partners and clients are from all over the world. If you request services or sign up to events related to international deliveries and agreements, then this may involve the transfer of your personal data outside the EEA based on your explicit consent for this.
- You have explicitly given us your explicit consent for this;
- There is an adequacy decision of the European Commission about the level of data protection provided by the third country;
- The transfer is necessary for the performance of a contract between you and JWAX CO or the implementation of pre-contractual measures taken at your request;
- The transfer is necessary for the conclusion or performance of a contract between JWAX CO and another natural or legal persons concluded in your interest;
- If the US providers are also certified under the EU-US Privacy Shield which confirms they have appropriate measures in place to ensure the protection of your personal data. If you would like further information, please contact [email protected]
11. Your Rights
- Right to object: you can object to our processing of your personal data. Please contact us as noted above, providing details of your objection.
- Access to your personal data: you can request access to a copy of your personal data that we hold, along with information on what personal data we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision-making.
- Right to withdraw consent: if you have given us your consent to use your personal data – for example, to send you marketing e-mails – you can withdraw your consent at any time by clicking the “unsubscribe” link in any marketing e-mail which you receive or by contacting us as at the e-mail address noted above.
- Rectification: you can ask us to change or complete any inaccurate or incomplete personal data held about you.
- Erasure: you can ask us to delete your personal data in certain circumstances, for example where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
- Portability: if the processing of your data is based on a contract and performed through automatic means, you can ask us to provide you or a third party with the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred to other service providers.
- Restriction: you can ask us to restrict the personal data we use about you in certain circumstances, for example, where you have asked for it to be erased or where you have objected to our use of it.
- Complaint: you can make a complaint about how we have used your personal data to us by contacting us as noted above, or file a complaint with the data protection supervisory authority for Bulgaria : Commission for Personal Data Protection.
11.2. You should know that some of these rights only apply in certain circumstances and depending on the case, there may be some exceptions to them, so we may not be able to fulfill every request. If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
11.3. If you wish to exercise any of these rights, please send us a written request by post or an e-mail to [email protected] through e-signature specifying your names, ID, contact details, your request and the reason for it.
If you have any questions or comments on the protection of your data, please do not hesitate to contact us.
E-mail us at [email protected].