Effective date: May 17th, 2018
Innovative Solutions Bulgaria EOOD ("us", "we", or "our") operates the www.spmtips.com website (the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
Service is the www.spmtips.com website operated by Innovative Solutions Bulgaria EOOD.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Use of Data
Innovative Solutions Bulgaria EOOD uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
Innovative Solutions Bulgaria EOOD may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it's not overridden by your rights
- To comply with the law
Retention of Data
Innovative Solutions Bulgaria EOOD will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Republic of Bulgaria and choose to provide information to us, please note that we transfer the data, including Personal Data, to Republic of Bulgaria and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, Innovative Solutions Bulgaria EOOD may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Innovative Solutions Bulgaria EOOD may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Innovative Solutions Bulgaria EOOD
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
"Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Innovative Solutions Bulgaria EOOD aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Innovative Solutions Bulgaria EOOD relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Provision of Personal Data to Third Parties in the Course of the Operational Processing of Your Purchases
Distributors and Agents
We are using the services of third parties (distributors and agents) which are situated on the territory of the European Union and the European Economic Area (“EU/EEA”) and third countries and perform deliveries of purchased and free items on our behalf.
In some cases the personal data provided by you and information about your purchase are being transferred to the nearest distributor (based on your shipping address) for the purposes of fulfillment of our contractual obligations with you and ensuring the fastest and most convenient possible purchase execution/delivery.
In case you are European citizen, your purchase (containing your personal data) shall be transferred to one of our distributors situated on the territory of the EU/EEA in order to be delivered to you.
In case you are citizen of a third country (i.e. situated outside the EU/EEA), your purchase (containing your personal data) may be transferred to one of our distributors, situated outside the EU/EEA in order to be delivered to you.
In case your purchase is performed with the assistance of one of our agents, the personal data provided by you could be transferred in EU/EEA or third countries (based on the country where the company of the relevant agent is located) for the purposes of payment of remuneration to the agent that assisted you in your purchase.
You may pay for your purchase by credit card.
In order to process credit card payments, we are obliged to forward your credit card and payment details to the relevant bank that is responsible for payment processing.
We do not have access to the credit card details provided by you. We merely forward the information provided by you directly to the relevant credit card payment provider, processing your payment. The information is being transferred through encrypted connection and we are following strictly the established procedures, as defined by the credit card payment providers.
We are using the services of an external hosting provider in order to provide the following services: infrastructure and platform services, computing capacity, data storage, database services, security services, as well as technical maintenance, which is needed for the proper functioning of this online content. Therefore we process together with our hosting services provider usage data, as well as metadata of customers and visitors of this online content, based on our legitimate interest in an efficient and safe operation of this online content, as stipulated in Article 6(1) GDPR and only for the purposes of providing you with the best user experience.
Collection of Log files
We, respectively our hosting services provider, collect data about every access on the server where this online content is being hosted (so called server log files) based on our legitimate interest as defined in Article 6(1) GDPR and only for the purposes of investigating of abuse and/or fraud cases and providing you with the best user experience. The server log files save data such as the domain name of the website visited, files, date and time of the access, transferred data volume, browser type and operating system, referring URL, IP address and the originating provider of the request. Log files are being saved for security reasons (e.g. for the purposes of investigating of abuse and/or fraud cases) for a period of 2 years and are being deleted. Data that is necessary for the purposes of investigation or as a proof is exempt from deletion until the completion of each specific case.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. We record your IP address in an anonymized format only, which means that we do not keep your personal data in Google Analytics. In addition, this anonymized data is being deleted from Google Analytics 14 months after the last visit of our website.
Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Embedded Services of Third Parties
Based on our legitimate interest in providing content, analysis, optimization and a sustainable operation of our service, as defined in Article 6(1) GDPR, we use content and services provided by third parties by embedding their content, such as videos or fonts. Below, we call such content “third party content”. In order to provide third party content, these external service providers collect the user’s IP address, because otherwise they wouldn’t be able to send their third party content to the user’s browser. The IP address is therefore absolutely necessary for the display of the third party content. We are doing our best to only use such third party content where the content providers use the IP address only for the content provision. Third parties may however also use so called pixel tags (invisible graphics, also called “web beacons”) for statistics and marketing purposes. These pixel tags enable the collection of information about the visitor traffic on our website. The pseudonym information can further be saved in cookies on the user’s device and may contain technical information related to browser and operating system, referring websites, time spent on our website or the usage of our online content and this data may be connected with information from other sources.
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.