Terms English

Content:

    1. Definitions
    2. What information do we collect?
    3. Who do we collect information from?
    4. Who can get your information?
    5. Data security and retention period
    6. Transfer of data to foreign countries
    7. Third Party Services
    8. Cookies
    9. The right to be forgotten
    10. Updating this Policy and contacting us

1. Definitions
The "Processor", "We" is iTrack Bulgaria Ltd, with UIC 201525241, registered office in. Sofia, ul. Ivan Susanin 70 and manager Veleslav Todorov.
"Administrator", "You" You, as representing a legal or natural person who is a visitor to this website, a potential or current customer of iTrack Bulgaria Ltd.
"Parties" are collectively referred to as the Processor and the Administrator.
"GDPR" Regulation (EU) 2016/679 with the intention to modernise and unify the rules for the protection of personal data of individuals in the EU. It replaces the previous directive (95/46/EC) of 1995. Unless specifically stated, all references to GDPR should be interpreted as a reference to the local interpretation of (EU) 2016/679/GDPR, if one exists.
"Personal Data" means personal data as defined in the GDPR that the Processor processes on behalf of the Administrator in connection with the services it provides to the Processor.

2. What information do we collect?
The purpose for our collection, redaction, processing and use of Personal Data is to provide services in which the Administrator has an interest and/or for which we have a signed contract with the Administrator.

We process Personal Data on behalf of the Administrator. We may not use Personal Data for any purpose other than as described in this Agreement or the contracts between us and the Administrator.

    First name, last name, company name, position, email address, phone number, personal and/or business address
    Access data
    Telecommunication data (e.g. connection, location, usage and traffic data)
    Customer relationship data (contract term, product interests, opinion)
    Customer history, summary correspondence, invoices and payment details
    Login history, IP addresses and information on browsers and devices used
    Precise location (GPS position) along with exact date and time, speed, altitude and direction of travel (*)
    Registration number and chassis number of vehicles and/or machines (*)
    Diagnostic data of the vehicles, GPS devices and/or service (*)
    Use data of vehicles and/or machines such as: Exact route; distance traveled; driving time; date, time and duration of stops; driving speed; altitude; ignition status; amount of fuel used; fuel level in tanks; temperature in cargo hold; engine speed; engine load; coolant temperature; outside temperature; emergency braking/turning/acceleration maneuvers; trip length and duration; battery voltage; road accident data. (*)

(*) - This data is only collected if the Administrator is or was a customer of iTrack Bulgaria Ltd. It is not collected from visitors to this website.

Some of the information described above reveals your identity or is directly linked to your identity such as your name, phone number or email address. Some of the information does not reveal your identity or is not directly related to you, such as information about your browser or device. If we ever combine non-personally identifiable information with personally identifiable information, we will consider the combination to be personally identifiable and protect it accordingly.

Our services are not intended to be used by persons under the age of 16 and we would never knowingly collect Personal Data from them.

3. Who do we collect information from?
Personal Data may be collected, processed and used by us from the following data subjects under this Agreement:

    The controller, in case it is an individual
    A person representing the Controller
    Employees of the Controller
    Customers and suppliers of the Controller
    Interested parties according to the Controller

4. Who can get your information?
a/ Our business partners and service providers
    We may share information about you with our our service providers, contractors and business partners (referred to as "partners" for short) to process your information on our behalf. We have contractual relationships with our partners that prohibit them from sharing your information with third parties or using it for any other purpose.
    The partners we use, and with whom we share some of our users' and customers' data for the purposes of analysing, offering and billing related to the services we offer are
        Google Analytics - analytics
        Google G Suite - email
        Cloudflare - CDN and DNS
        DigitalOcean - hosting
  Due to the nature of information sharing between Aitrak Bulgaria Ltd. and the partners we use, you should review the privacy policies and terms of those partners, which may include practices that are different from those described in this Privacy Policy.

b/ Legal and Administrative Obligations
We may use and/or share your Personal Information if we are required by law to:

    Prevent fraud: We may use and/or share the information we collect from and about our customers if we believe it is necessary to investigate or prevent suspected illegal or fraudulent activity or to protect the security, privacy, rights or property of us, our customers or others.
    For Law Enforcement Purposes: If an executive, law enforcement agency, court, and/or regulatory body lawfully requests data from us, we may be compelled to disclose information about our users and/or customers. We may also use and/or disclose information relating to you to protect our interests in the event of legal claims.

5. Data Security and Retention Period
We take many measures to protect your personal information. If you suspect that someone else is using your iTrack access please notify us by email to office@itrack.bg

We endeavour to use reasonable organisational, technical and administrative measures to protect your Personal Data within our organisation from loss, misuse, unauthorised access or disclosure, alteration and/or destruction.

If you have reason to believe that your interactions with us are no longer secure (for example, if you believe that the security of any account you had with us has been compromised), please notify our Data Protection Officer immediately by email at dpo@itrack.bg

We will retain your personal information for as long as is necessary or permitted, for the purposes for which it was obtained. Criteria used to determine retention periods include the length of our ongoing relationship and provision of our services to you, our legal obligations or legal position (for example, in relation to litigation and/or regulatory investigations).

6. Data transfer between countries
The storage, processing and use of Personal Data takes place in a member state of the European Union. Any transfer of data to a non-EU country requires the prior approval of the Controller.

7. Third Party Services
We are not responsible for the privacy and data protection practices of third parties linked to our platform. This Privacy Policy does not address the privacy, information security or other practices of third parties, including third parties that operate any site and/or service to which our Services link. Posting links to third party sites on our Services does not imply that we endorse and/or guarantee the security of the linked site or service.

8. Cookies
We and the third party services we use place cookies on your browsers to enable us to:

    track and analyze visitor behavior as well as potential and current customers
    calculate traffic to our website and services and highlight users who visit our websites more than once
    identify you as a customer and authorize you to log in again
    remember your preferences and settings
    to remember that you have completed our request, survey or questionnaire

If you do not wish to accept cookies from us, you can delete the cookies we have recorded so far, and you can turn off the acceptance of cookies from us or from the third party services we use from your browser settings. Please note that disabling cookies may negatively affect the functionality of the sites and/or services we provide to you.

9. The right to be forgotten
You have the right to ask us to delete personal data relating to you, and we have the obligation to delete it, where any of the following grounds apply:

    the personal data is no longer necessary for the purposes for which it was collected or otherwise processed
    you withdraw your consent on which the processing is based and there is no other legal basis for the processing
    you object to the processing of personal data relating to you, including for direct marketing purposes, and there are no legitimate grounds for the processing which override
    the personal data have been unlawfully processed
    the personal data must be erased in order to comply with a legal obligation under EU or Member State law that applies to us
    the personal data have been collected in connection with the provision of information society services

We are not obliged to delete your personal data if we store and process it:

    to exercise the right to freedom of expression and the right to information
    to comply with a legal obligation requiring processing under EU or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller
    for reasons of public interest in the field of public health
    for archiving purposes in the public interest, scientific or historical research or statistical purposes
    for the establishment, exercise or defence of legal claims

To exercise your right to be forgotten, you should submit a written request sent to email dpo@itrack.bg and then verify your identity to a member of our staff.

We do not delete data that we have a legal obligation to keep, including for the defence of legal claims made against Us or to prove Our rights.

10. Updating this Policy and Contacting Us
The policies in this Privacy Policy may be updated and amended over time. Any changes will become effective when We post the updated Privacy Policy on this page.

We reserve the right to make changes to this Privacy Policy. Please check back periodically for changes. You will be aware that changes have been made when the effective date of this Privacy Policy has changed. If iTrack determines that it will use or disclose information that identifies you in a manner that is materially different from what is disclosed in this Privacy Policy at the time we collect that information, we will provide you with a choice about the disclosure of that information, which may include an opt-out mechanism.

We welcome questions, suggestions and feedback regarding this Privacy Policy. Please feel free to contact us at:

iTrack.bg Ltd.
Cherni Vrah 47A
Sofia 1407
Bulgaria

In addition, you can contact the Data Protection Officer at dpo@itrack.bg.

Please do not include passwords, bank card numbers or other sensitive information in your email communications.

The competent data protection authority in your country can be found at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm .