This Privacy and Cookie Policy is solely intended to provide you with information in relation to our processing of personal data through your use of the Spread IT website.

1. WHO WE ARE

“We”, “us” or “our” means:
Spread IT Ltd.
21B Moskovska str., 3rd floor - 1000, Sofia
BG205513443
And it’s subsidiaries

We act as a controller for the personal data we gather through your use of our website. Your privacy is important to us, so we have developed this Privacy and Cookie Policy that sets out how we collect, disclose, transfer and use the personal data that you share with us, and which rights you have.

If you have any questions, concerns or complaints regarding this Privacy and Cookie Policy or our processing of your personal data or you wish to submit a request to exercise your rights as set out in article 5, you can contact us:

I. Via-mail: gpdr@spread-it.eu, to the attention of our Data Protection Officer
II. By post:
          Spread IT
          To the attention of the GDPR Officer
          21B Moskovska str., 3rd floor - 1000, Sofia

2. WHAT INFORMATION WE COLLECT

We collect information about you when you fill in a contact form, download brochure, download whitepapers/reports, sign up for our newsletters, sign up for our events, chat with us, email us directly or consent to receive information via call. We also collect information when you voluntarily comment on our blog posts, provide feedback and participate in competitions. Website usage information is collected using cookies.

The information we collect about you may include; your name, job title, email address, company name, address, phone number, IP address, location, and plus any information you supply voluntarily. The personal data we collect is collected and used for the purposes as listed hereunder:
I. In the event you use the contact form on our website, we will use your personal data to reply to your query, via e-mail or telephone.
II. In the event you register for our newsletter, your e-mail address will be used in order to send you our newsletters, which may include invites to events, seminars, etc. organized by us.
III. We process your personal data for the purpose of supporting the website and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of the website.
IV. We process your personal data to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defence of legal claims.
V. We may also use your personal data to fulfil our obligations as set out by the applicable law.

3. WHY DO WE USE YOUR PERSONAL DATA

We use the personal data we receive directly from you (via our contact form, newsletter, download options such as white papers, documentation, etc.) as well as the user information we aggregate from your behaviour shown on our website and the information we retrieve on third-party websites such as Google, LinkedIn, Facebook, Twitter and Youtube on the basis of the legal ground “legitimate interest”. In any case, we strive towards a balance between the legitimate interest and respecting your privacy.

Thus, we have a legitimate interest to answer the question(s) being asked by you or to react on the remarks you made, we will also use this information to contact you directly, manage your account and, to email you about other products, services, and information we think may be of interest to you.

If you subscribe to our newsletter through our website, and in case you are not yet a client from us, you give us your explicit consent therefor. Your personal data will also be used for direct marketing, provided that you gave explicit consent. If you are already added to our mailing list to receive electronic marketing material, we can use your data to send marketing regarding our services. In the event the legal basis for the processing of your personal data is consent, you will, at all times, have the right to withdraw your consent. This will, however, not affect the lawfulness of any processing done prior to the withdrawal of consent. And in the event the legal basis for processing is our legitimate interests the public interest, you will have the right to object to such processing, as set out in article 5 of this Privacy Policy.

With regard to our services and to our clients, we use the identification and financial data based on the legal ground “necessary for the execution of the agreement”. Thus, we need these identification data to deliver you our invoices (electronically) or to incorporate them in our accounting, as well as for our client administration and our supplier administration.

4. RETENTION & DELETION OF YOUR DATA

Your information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information. In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future. The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.

5. WHAT ARE YOUR RIGHTS

This article lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.
To exercise any of your rights, please send us a written request in accordance with article 1 of this Privacy Policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.
On the basis of the December 8, 1992 Law and as of the 25th of May 2018 on the basis of the General Data Protection Regulation you have the right to:

The right to access:
You have the right to confirmation as to whether or not we process your personal data and, in the event we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this Privacy Policy. You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.

The right to rectification:
If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.

The right to erasure (right to be forgotten)
In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:
(a) The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
(b) You withdraw your consent, and no other lawful ground exists;
(c) The processing is for direct marketing purposes;
(d) The personal data have been unlawfully processed; or,
(e) Erasure is necessary for compliance with EU law or Belgian law.

There are certain exclusions to the right to erasure. Those exclusions include where processing is necessary,
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation; or,
(c) for the establishment, exercise or defence of legal claims.

The right to restrict processing;
You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:
(a) You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);
(b) The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);
(c) We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; or,
(d) You have objected to processing, pending the verification of that objection.

In addition to our right to store your personal data, we may still otherwise process it but only:
(a) with your consent;
(b) for the establishment, exercise or defence of legal claims;
(c) for the protection of the rights of another natural or legal person; or,
(d) for reasons of important public interest.
We will inform you before we lift the restriction of the processing.

The right to data portability
To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others. You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.

The right to object to processing
You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
(a) The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
(b) The purposes of the legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

• ask us to get insight into the personal data we process, provided that this has no adverse effect on the rights and freedom of others. You have the right to ask for a copy of your personal data in an understandable format that is free of charge;
• add, remove or protect data because of being false or incomplete;
• have your data removed in case (i) the personal data are no longer needed, (ii) you withdraw your consent (and there is no other ground for processing, such as a contractual relationship), (iii) your personal data were processed in an unlawful way, or (iv) this needs to be done based on a legal requirement.
• use the right on limitation of your personal data, in case (i) the correctness of your personal data is being contested, (ii) the processing is illegal, (iii) your personal data or no longer necessary, but needed for the set-up of a legal claim, or (iv) you object the processing;
• use the right on transferability of your personal data in case the processing is based on consent and is being processed through automated procedures;
• use the right on an objection against the processing of personal data in case the ground for the processing is the legitimate interest or in the light of direct marketing;
• use the right to not be subjected to automated individual conclusions;

The right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Belgium, you can submit a complaint to the Authority for the protection of personal data (Data Protection Authority), Drukpersstraat 35, 1000 Brussel (contact@apd-gba.be; https://www.dataprotectionauthority.be/contact-us).

6. THIRD PARTIES

This Privacy Statement is only applicable to our website and social media channels. The website can include links to other websites, which we do not monitor and wherefore this Privacy Statement is not applicable. Other websites do have their own privacy policy. Our website uses social media plugins that make it possible to link you to our social media channels, or that enable you to share content on your social media channels. These social media channels are Facebook, LinkedIn and Twitter. In case you click on such a link, it is possible that the social media partners mentioned here use personal data, such as personal data concerning your profile.

7. INTERNATIONAL TRANSFERS

We will not transfer your personal data outside of the European Economic Area. We will ensure that any transfer of personal data to countries outside of the European Economic Area will take place pursuant to the appropriate safeguards.

8. COOKIES

This website makes use of cookies that track your online activity, including, but without restriction, your subscription, the offer of information and the request for information. Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device when you visit the website or certain pages. The cookie allows the website to “remember” your actions or preferences over time. Most browsers support cookies, but users can set their browsers to decline them and can delete them whenever they like.

Cookies will usually contain the name of the website where the cookie has come from, how long the cookie will remain on your device and a value which is usually a randomly generated unique number. Some cookies will be deleted as soon as you leave the website (the so-called “session cookies”), other cookies will remain stored on your computer or mobile device and will help us identify you as a visitor of our website (the so-called “permanent cookies”).

Why do we use cookies?
Cookies on our Website are used for a variety of different purposes. We use cookies to improve the user experience on the Website and to map your surfing behaviour (e.g. the pages you have visited and the time you spent on that page). Cookies make our Website easier to use and allow us to better tailor our Website to your interests and needs. Cookies are also used to help speed up your future activities and experience on the Website. We use cookies, for example, to remember your language preferences.
We also use cookies to compile anonymous, aggregated statistics that allow us to understand how our Website is being used and how we can improve our services.

9. AMENDMENTS TO THE PRIVACY AND COOKIE POLICY

We reserve the right to modify this Privacy and Cookie Policy at any time, and without prior notice, by posting an amended Privacy and Cookie Policy on the website. You will always be able to consult the most recent version of the Privacy and Cookie Policy on the website.

This Privacy Policy was revised last on 18/06/2019, version nr. 2019/01.