Privacy Policy

Key details


This Privacy Policy applies to the Smart Factory Ltd. website at www.smfactory.eu (the “Website”). This Website Privacy Policy describes how Smart Factory Ltd. ​protects and makes use of the information you give the company when you use this Website.
If you are asked to provide information when using this Website, it will only be used in the ways described in this Privacy Policy.
We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on our Website, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates.


Definitions


Personal data: any data that that relates to an identified or identifiable individual or that is linked or linkable to them, no matter where the individual lives.
Data Subject: an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, e-mail address or to one or more factors specific to that natural person.
Processing: means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, alignment or combination, restriction, erasure or destruction.
Controller: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Consent: of a data subject means a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of the data subject's agreement to the processing of personal data relating to him or her.


Data Controller


The Data Controller of your personal data is Smart Factory Ltd. (UIC 206939997) with its’ registered office in 3, Iliya Beshkov St, Iskar district, municipality Stolichna, 1517 Sofia, Bulgaria, hereinafter referred to as the Data Controller or the Company.

Contacting the Data Controller shall be possible via:
- e-mail: info@smfactory.eu;
- post, in writing at the address specified below:
3, Iliya Beshkov St, Iskar district, municipality Stolichna, 1517 Sofia, Bulgaria.


Manner, Purpose and Bases of Personal Data Processing


I. Personal data processed by the Data Controller are collected, stored, edited, archived in paper documents, as well as IT systems and on electronic information media.
The Data Controller declares that it has implemented relevant operational and technical measures to secure the processed data:
- in reference to data contained in paper documents – such documents are stored in a properly secured archive which may be accessed exclusively by authorised persons;
- in reference to data in electronic format – data are stored on electronic information media equipped with proper securities.

II. In order to provide services in line with the profile of operation, the Company processes the collected personal data – for different purposes, yet always in compliance with the law.
We gather and use certain information about individuals in order to provide products and services and to enable certain functions on this Website.
We also collect information to better understand how visitors use this Website and to present timely, relevant information to them. We use analytical and statistical tools that monitor details of visits to our Website and the resources that the user access, including, but not limited to, traffic data, location data, weblogs and other communication data.
We strive to collect only the personal data that we need. The personal information we collect depends on how you interact with our Website.
The data we may collect on our Website includes:

• Contact Information including name, email address, phone number, or other contact information;
• Account Information, including email address, devices registered, account status;
• Device Information, such as device serial number, or about your device, such as browser type;
• Usage Data about your activity on and use of our offerings, including product interaction; crash data, performance and other diagnostic data; and other usage data;
• Other information provided by the user.

Provision of personal data is voluntary. However, in some cases provision of specific personal data is necessary for efficient provision of offered services.

III. For the purpose of estimating a service and providing a service, personal data is processed by the Data Controller on the basis of Art. 6.1.b) of the General Data Protection Regulation (the “GDPR”), which allows for the processing of personal data if such processing is necessary for the performance a contract or in order to take steps prior to entering into a contract; Provision of surname shall be understood as approval for the processing of such data, which has its’ basis in Art. 6.1.a) of the GDRP, which allows for the processing of such data on the basis of a freely given consent.
For the purpose of sending e-mail notifications and marketing information, personal data is processed by the Data Controller on the basis of Art. 6.1.f) of the GDPR which allows for the processing of personal data if, in this manner, the Data Controller pursues its’ legitimate interest (in this case, the Company’s interest is informing the client about activities related to the processing of the ordered service) or Art. 6.1.a) of the GDPR, which allows for the processing of personal data on the basis of a freely given consent.
For the purpose of telephone contact with respect to issues related to the performance of a Service or estimation of a Service, personal data is processed by the Data Controller on the basis of Art. 6.1.f) of the GDPR which allows for the processing of personal data if, in this manner, the Data Controller pursues its’ legitimate interest (in this case, the Company’s interest is informing the client about activities related to the processing of the ordered service) or Art. 6.1.a) of the GDPR, which allows for the processing of personal data on the basis of a freely given consent.
For analytical purposes, i.e. testing and analysing the activity on the Data Controller’s Website, personal data is processed by the Data Controller on the basis of Art. 6.1.f) of the GDPR which allows for the processing of personal data if, in this manner, the Data Controller pursues its’ legitimate interest.
For the purpose of administering the Website, personal data is processed by the Data Controller on the basis of Art. 6.1.f) of the GDPR which allows for the processing of personal data if, in this manner, the Data Controller pursues its’ legitimate interest.

We will never lease, distribute or sell your personal information to third parties unless we have your permission or the law requires us to.
We retain personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law.
When the data is no longer needed or goes out of date, it is deleted from our systems. In certain cases, the data is securely archived to allow legal requirements or agreed industry practises. No data is held any more than 20 years.


Cookies and how we use them


What is a cookie?


Our Website, online services and advertisements may use “cookies”. These technologies help us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our Website people have visited, and facilitate and measure the effectiveness of advertisements and web searches.
A cookie is a small file placed on computer's hard drive. It enables our Website to identify your computer as you view different pages on our Website.


How we use cookies


We may use cookies to:
● Analyse our web traffic using an analytics package. ​Aggregated usage
data helps us improve the Website structure, design, content and functions.
● Identify whether you are signed in to our Website. ​A cookie allows us
to check whether you are signed in to the Website.
● Store information about your preferences.​ The Website can then
present you with information you will find more relevant and interesting.
● To recognise when you return to our Website. ​We may show your
relevant content, or provide functionality you used previously.
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.


Controlling cookies


You can use your web browser’s cookie settings to determine how our Website uses cookies. If you do not want our Website to store cookies on your computer or device, you should set your web browser to refuse cookies. This can be done by activating the setting on your browser which enables you to decline the cookies.
Please note that should you choose to decline cookies, you may be unable to access particular parts of our Website.
Unless you have changed your browser to refuse cookies, our Website will issue cookies when you visit it.
To learn more about cookies and how they are used, visit www.allaboutcookies.org.


Your rights



We aim to take reasonable steps to allow you to correct, amend, delete or limit the use of your personal data.
In certain circumstances, you have the following data protection rights:
- the right to access, update or delete the information we have on 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 to process your personal information at any time.

If you do not want us to use your data or want to vary the consent that you have provided you can write to us at info@smfactory.eu at any time.
If the processing of personal data took place on the basis of a consent, its’ withdrawal does not render the processing of personal data until such withdrawal illegitimate. Until the consent was withdrawn, processing was legitimate, and its’ withdrawal does not influence the legitimacy of hitherto processing.


Security


We will always hold your information securely.
To prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards.
While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.


Contact us


If you have questions or comments about this Privacy Policy, please email to: info@smfactory.eu or write to: 3, Iliya Beshkov St, Iskar district, municipality Stolichna, 1517 Sofia, Bulgaria.