PRIVACY POLICY

1.Who we are and what our Privacy and Cookies Policy comprises

New Branch Ltd. Is a limited liability company organized and existing under the laws of the Republic of Bulgaria, entered in the Commercial Register under Uniform ID Code 204672875, having its seat and registered address in 120 Tintyava Str., entr. B, fl. 7, ap. 19, 1113 Sofia, Bulgaria (hereinafter referred to as “NB”, “we”, “us” or similar derivative), e-mail: [email protected].

The protection of privacy and the safeguarding of our Clients’ Personal Data is of immense importance to us.

The objectives of this Policy are to provide you with information regarding:

  • how we operate with personal data;
  • what are your rights in this regard;
  • what cookies are;
  • cookies that we use and what we use them for;
  • how can you restrict, block, or delete cookies;
  • other useful information.

NB is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, NB is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, ”personally identifiable information” or ”PII”) that has been collected online.

Generally, our intent is to collect only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this Privacy and Cookies Policy to learn more about how we collect, use, share and protect the personal information that we have obtained.

2.Collection and use of personal data

2.1.What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your personal information to NB.

By registering and/or submitting personal information to NB, you are also acknowledging that NB may use this information in accordance with this Policy. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to NB web site and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other NB sites you visit.

In some cases where you have registered for certain services we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

2.2.The legal grounds we have to use your personal information

NB generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

The law in the Republic of Bulgaria allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

  • Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
  • Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
  • Legitimate interests: we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
  • Your consent: we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting NB at [email protected].

NB collects ”sensitive” personal information only when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person's race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to NB, and under any circumstances, do not provide sensitive information to NB, unless you thereby consent to the NB's use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in the NB’s databases. If you have any questions about whether the provision of sensitive information to NB is, or may be, necessary or appropriate for particular purposes, please contact NB at [email protected].

2.3.Automatic collection of personal information

In some instances, NB and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of NB's online presence, and to measure the effectiveness of our marketing activities.

2.3.1.IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

2.3.2.Cookies

Cookies are small text files stored on your computer when you visit certain web pages. At NB we use cookies on our website https://www.newbranch.tech, including any subdomains and derivatives (the “Website”) to allow the Website to recognize you on subsequent visits.

Cookies can be used by us for other purposes. For instance, they may be used to remember your preferences on our Website, to remember your user ID on our Website, and to help you navigate between pages more efficiently. Cookies can also be used by us to collect information about webpages visited and content viewed by you, links and buttons clicked, URLs visited before and after you visit our Website.

Much, though not all, of the data that is collected through cookies, is anonymous, though some of it is designed to detect browsing patterns and approximate geographical location to improve your user experience.

Most web browsers have cookies enabled and accept cookies automatically, but you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer.

Please note that cookies can't harm your computer. We use encrypted information gathered from them to help improve your experience of the Website. For example, they help us to identify and resolve errors, or to determine relevant related products to show you when you're browsing.

On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as ”user-input” cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies.

Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.

Below is a list of the types of cookies used on our web sites:

PurposeDescriptionType & Expiry
Performance (i.e., User's Browser)Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content).

Session

Deleted upon closing the browser

Site PreferencesOur cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account.

Session

Deleted upon closing the browser

AnalyticalWe use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on NB for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites.Persistent, but will delete automatically after two years if you no longer visit
Google Analytics with anonymized IP (Google Ireland Limited)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of NB, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

Personal Data processed: Cookies; Usage Data.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Persistent, but will be deleted automatically after two years if you no longer visit
Site visitor feedback

By filling in the contact form with their Data, the User authorizes NB to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data processed: company name; email address; field of activity; first name; last name; phone number; website.

Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

Persistent, but will be deleted automatically after two years if you no longer visit
Social sharingWe use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed on our webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider's privacy information before using any such service. For further details on our use of social media widgets and applications, see below.Persistent, but will be deleted automatically after two years if you no longer visit
YouTube video widget without cookies (Google Ireland Limited)

YouTube is a video content visualization service provided by Google Ireland Limited that allows us to incorporate content of this kind on its pages.

This widget is set up in a way that ensures that YouTube shall not store information and cookies about Users on NB web sites unless they play the video.

Persistent, but will be deleted automatically after two years if you no longer visit

SPAM protectionThis type of service analyzes the traffic of NB, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.Persistent, but will be deleted automatically after two years if you no longer visit
Google reCAPTCHA (Google LLC)

Google reCAPTCHA is a SPAM protection service provided by Google LLC.

The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

Personal Data processed: Cookies; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

Session

Deleted upon closing the browser

Third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

2.4.Children

NB understands the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.

3.Sharing and transfer of personal information

3.1. Transfers to third parties

We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This would include:

  • Our service providers: NB work with reputable partners, service providers or agencies so they can process your personal information on our behalf. NB will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.
  • If we are reorganized or sold to another organization: NB may also disclose personal information in connection with the sale, assignment, or other transfer of the business of the site to which the data relates;
  • Courts, tribunals, law enforcement or regulatory bodies: NB may disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations.
  • Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.

In addition, NB may transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Policy. NB may also store personal information outside of the EEA. If we do this your personal information will continue to be protected by means of contracts we have in place with those organisations outside the EEA, which are in a form approved by the European Commission. By providing personal information on online, visitors are consenting to this transfer and/or storage of their personal information across borders.

NB will not transfer the personal information you provide to any third parties for their own direct marketing use.

4.Choices

In general, you are not required to submit any personal information to NB, but we may require you to provide certain personal information in order for you to receive additional information about our services and events. NB may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in ”Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

5.Your rights

If you have submitted personal information to NB, you have the following rights:

  • Access and correction:you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you may ask us to correct any inaccuracies in the personal information.
  • Object to processing:you have the right to object to us processing your personal information if we are not entitled to use it any more, to have your information deleted if we are keeping it too long or have its processing restricted in certain circumstances.

You can make a request or exercise these rights by contacting NB at [email protected] and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

6.Data security and integrity

NB has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite NB's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual's request or until that person asks that the information be deleted.

7.Links to other sites

Please be aware that NB web sites may contain links to other sites, including sites maintained by other companies that are not governed by this Policy but by other privacy policies that may differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information.

By registering on any NB’s web sites and then navigating to another the NB’s web site while still logged in, you agree to the use of your personal information in accordance with the policy of NB web site you are visiting.

8.Changes to this Policy

NB may modify this Policy from time to time to reflect our current privacy practices. When we make changes to this Policy, we will revise the ”updated” date at the top of this page. We encourage you to periodically review this Policy to be informed about how the NB is protecting your information.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

9.Policy questions and enforcement

NB is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at [email protected]. You may also use this address to communicate any concerns you may have regarding compliance with this Policy.

In any event, you always have the right to lodge a complaint with the Commission for Personal Data Protection of the Republic of Bulgaria.

LAST UPDATED: 07 April 2022