Privacy Policy

August 9, 2022 by Rossen Dimov

Name and address of the person responsible

The person responsible within the meaning of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:

Rossen Dimov, Smart Farm Robotix Ltd., 19 Rusaliyski Prohod, office 3, Sofia 1407, Bulgaria

General information on data processing

Scope of processing personal data

As a general rule, we only collect and use personal data from our users to the extent that this is necessary to provide a functional website and our content and services. The collection and use of our users’ personal data regularly only takes place with the user’s consent. An exception applies in cases in which obtaining prior consent is not possible for actual reasons and the processing of the data is permitted by legal regulations.

Legal basis for processing personal data

To the extent that we obtain the consent of the data subject for processing personal data, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.

When processing personal data that is necessary to fulfil a contract to which the data subject is a party, Art. 6 Para. 1 lit. b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.

If the processing of personal data is necessary to fulfil a legal obligation to which we are subject, Article 6 Paragraph 1 Letter c GDPR serves as the legal basis.

In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6 (1) (d) GDPR serves as the legal basis.

If the processing is necessary to protect a legitimate interest of us or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 Para. 1 lit. f GDPR serves as the legal basis for the processing.

Data deletion and storage period

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage can also take place if this has been provided for by the European or national legislator in EU regulations, laws or other regulations to which the person responsible is subject. The data will also be blocked or deleted if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data to conclude or fulfil a contract.

Website visit, request headers, server-side log files

When you visit our website, your browser automatically sends various general information to the website in the so-called request header. This data is listed below:

  • browser types and versions used:
  • the operating system used by the accessing system
  • the website from which an accessing system accesses our website (so-called referrer)
  • the sub-websites that are accessed via an accessing system on our website
  • the date and time of access to the website
  • an Internet protocol address (IP address)
  • further technical information that is technically necessary for communication between browser and server (full list in Wikipedia (https://de.wikipedia.org/wiki/Liste_der_HTTP-Headerfelder)

The server on which the website is operated evaluates the IP address from this data in order to be able to technically process the request and return the answer to the requesting system. In addition, the website evaluates the operating system as well as the browser type and version used to decide whether the mobile version of the website or the desktop version of the website needs to be delivered.

The purpose of data processing in accordance with Art. 13 Para. 1 lit. c GDPR is to provide and operate a technically flawless website.

The legal basis for processing the transmitted data is Article 6 Paragraph 1 Letter f GDPR; it is in our legitimate interest to operate a website and provide information to our interested parties.

Registration on our website

When registering for specific offers, we ask for some personal information such as name, address, contact, telephone number or email address. Registered users can access certain additional services. Registered users have the opportunity to change or delete all personal data provided at any time. You can also request the data you have stored from us at any time. If there is no legal deadline for retaining the data, it can be changed or deleted. Please contact us via our contact page.

There are contact forms on our website that can be used to contact us electronically. If a user takes advantage of this option, the data entered in the input mask will be transmitted to us and stored. Depending on the form, these data include:

  • E-mail address
  • Surname
  • First name
  • Address details
  • Telephone number
  • fax number
  • Company name
  • Regarding
  • Message text

In accordance with the principle of data economy, only the input fields necessary for communication or the respective purpose of the form are implemented as mandatory fields; all other fields can be filled out optionally.

Your consent will be obtained for the processing of the data as part of the sending process and reference will be made to this data protection declaration.

The data will only be used to process the request.

The purpose of data processing in accordance with Article 13 Paragraph 1 Letter c GDPR is to provide our website visitors with an easy way to contact us.

The legal basis for processing the data, if the user has given his consent, is Article 6 (1) (a) GDPR.

The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For the personal data from the input mask of the contact form, this is the case when the respective conversation with the user has ended. The conversation ends when it can be seen from the circumstances that the matter in question has been finally clarified.

The user has the option to revoke his consent to the processing of personal data at any time. If the user contacts us using the contact form, they can object to the storage of their personal data at any time. In such a case, the conversation cannot continue.

Cookies

This website does not use cookies to protect our users.

Google ReCaptcha

We use the Google reCaptcha service to determine whether a human or a computer makes a specific entry in our forms. Google uses the following data to check whether you are a human or a computer: IP address of the device used, the website you visit on our website and on which the captcha is integrated, the date and duration of the visit, the identification data of the device used Browser and operating system type, Google account if you are logged in to Google, mouse movements on the reCaptcha areas and tasks that require you to identify images. The legal basis for the data processing described is Article 6 Paragraph 1 Letter f of the General Data Protection Regulation. There is a legitimate interest on our part in this data processing to ensure the security of our website and to protect us from automated entries (attacks).

E-mail contact

You can contact us on our website using the email address provided. In this case, the user’s personal data transmitted with the email will be stored.

The data will only be used to process the request.

The purpose of data processing in accordance with Article 13 Paragraph 1 Letter c GDPR is to provide our website visitors with an easy way to contact us.

The legal basis for processing the data transmitted when sending an email is Art. 6 Para. 1 lit. f GDPR. It is our legitimate interest to be able to be contacted by our website visitors. If the e-mail contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 Para. 1 lit. b GDPR; the processing serves to fulfill a contract or pre-contractual measures.

The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be seen from the circumstances that the matter in question has been finally clarified.

The user has the option to revoke his consent to the processing of personal data at any time. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot continue.

Email application

If you apply to us via email, we collect and process your personal data to process the application process.

The purpose of data processing in accordance with Article 13 Paragraph 1 Letter c GDPR is to carry out an application process.

The legal basis for collecting and processing your personal data in the application process is Section 26 BDSG in the version applicable from May 25, 2018 and Article 6 Paragraph 1 Letter b GDPR (implementation of pre-contractual measures). Art. 6 GDPR serves as the legal basis for storing your data beyond the application process, in particular to protect legitimate interests according to Art. 6 Paragraph 1 lit. f. Our interest then lies in asserting or defending against claims, e.g. B. as part of a burden of proof in proceedings under the General Equal Treatment Act (AGG). If you have agreed to further storage of your personal data, we will add your data to our applicant pool. The data will be deleted there after two years; the legal basis for further storage of your data with your consent is Art. 6 Para. 1 lit. a GDPR

When applying by email, data transmission is generally unencrypted, unless the applicant’s email service provider supports transport encryption via Secure Socket Layer. If desired, an applicant can send us encrypted emails after prior coordination. Alternatively, the applicant can send us his application data in encrypted and password-protected files (.zip or similar) and provide us with the password for decryption by telephone or other means.

If we conclude an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with legal regulations. If we do not conclude an employment contract with the applicant, the data will be deleted immediately after completion of the application process (including the probationary period), provided that deletion does not conflict with any other legitimate interests of the person responsible for processing.

The user has the option at any time to revoke his consent to the processing of personal data as part of the application process. If the user contacts us by email, they can object to the storage of their personal data at any time. In such a case, the conversation cannot continue.

Data security

This website uses the popular encryption method Secure Socket Layer (SSL) in conjunction with the highest level of encryption supported by your browser to make your visit as secure as possible. You can tell whether an individual page of our website is transmitted in encrypted form by the closed display of the key or lock symbol in the bottom status bar of your browser.

Data that you may provide to us. Via contact forms, data is encrypted when sent and transmitted securely from your browser to our server.

We also use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

Rights of the data subject

right of providing information

You can request confirmation from the person responsible as to whether personal data concerning you is being processed by us.

If such processing occurs, you can request information from the person responsible about the following information:

  • the purposes for which the personal data are processed;
  • the categories of personal data that are processed;
  • the recipients or categories of recipients to whom the personal data concerning you have been or will be disclosed;
  • the planned duration of storage of the personal data concerning you or, if specific information is not possible, criteria for determining the storage period;
  • the existence of a right to rectification or deletion of personal data concerning you, a right to restrict processing by the controller or a right to object to this processing;
  • the existence of a right to lodge a complaint with a supervisory authority;
  • all available information about the origin of the data if the personal data is not collected from the data subject;
  • the existence of automated decision-making including profiling in accordance with Article 22 Paragraphs 1 and 4 GDPR and – at least in these cases – meaningful information about the logic involved as well as the scope and intended effects of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you will be transferred to a third country or to an international organization. In this context, you can request to be informed about the appropriate guarantees in accordance with Art. 46 GDPR in connection with the transfer.

Right to rectification

You have the right to request correction and/or completion from the person responsible if the personal data processed concerning you is incorrect or incomplete. The person responsible must make the correction immediately.

Right to restriction of processing

You can request the restriction of the processing of personal data concerning you under the following conditions:

  • if you contest the accuracy of the personal data relating to you for a period enabling the controller to verify the accuracy of the personal data;
  • the processing is unlawful and you refuse the deletion of the personal data and instead request the restriction of the use of the personal data;
  • the person responsible no longer needs the personal data for the purposes of processing, but you need them to assert, exercise or defend legal claims, or
  • if you have lodged an objection to the processing in accordance with Article 21 Para. 1 GDPR and it is not yet clear whether the legitimate reasons of the controller outweigh your reasons.

If the processing of personal data concerning you has been restricted, this data – apart from its storage – may only be used with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If processing has been restricted in accordance with the above conditions, you will be informed by the person responsible before the restriction is lifted.

Right to deletion

(a) Obligation to delete

You can request that the person responsible delete the personal data concerning you immediately, and the person responsible is obliged to delete this data immediately if one of the following reasons applies:

     the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

     You revoke your consent on which the processing was based in accordance with Article 6 Paragraph 1 Letter a or Article 9 Paragraph 2 Letter a GDPR and there is no other legal basis for the processing.

     You object to the processing in accordance with Art. 21 Para. 1 GDPR and there are no overriding legitimate reasons for the processing, or you object to the processing in accordance with Art. 21 Para. 2 GDPR.

     the personal data concerning you were processed unlawfully.

     The deletion of the personal data concerning you is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.

     The personal data concerning you was collected in relation to information society services offered in accordance with Art. 8 Para. 1 GDPR.

(b) Information to Third Parties

If the person responsible has made the personal data concerning you public and is obliged to delete it in accordance with Article 17 Para. 1 GDPR, he will take appropriate measures, including technical ones, taking into account the available technology and the implementation costs, to ensure that the person responsible for data processing to inform those processing the personal data that you, as the data subject, have requested them to delete all links to that personal data or copies or replications of that personal data.

(c) Exceptions

There is no right to deletion if processing is necessary

  • to exercise the right to freedom of expression and information;
  • to fulfill a legal obligation requiring processing under Union or Member State law to which the controller is subject, or to carry out 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 in accordance with Article 9 Paragraph 2 Letters h and i and Article 9 Paragraph 3 GDPR;
  • for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes in accordance with Article 89 Para. 1 GDPR, insofar as the law mentioned under section a) is likely to make the achievement of the objectives of this processing impossible or seriously impair it, or
  • to assert, exercise or defend legal claims.

Right to information

If you have asserted the right to rectification, deletion or restriction of processing against the controller, the controller is obliged to inform all recipients to whom the personal data concerning you have been disclosed of this rectification or deletion of the data or restriction of processing, unless: this turns out to be impossible or involves disproportionate effort.

You have the right to be informed about these recipients by the person responsible.

Right to data portability

You have the right to receive the personal data concerning you that you have provided to the person responsible in a structured, common and machine-readable format. You also have the right to transmit this data to another person responsible without hindrance from the person responsible to whom the personal data was provided, provided that

  • the processing is based on consent in accordance with Article 6 (1) (a) GDPR or Article 9 (2) (a) GDPR or on a contract in accordance with Article 6 (1) (b) GDPR and
  • the processing takes place using automated procedures.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one controller to another controller, to the extent that this is technically feasible. The freedoms and rights of other people must not be impaired by this.

The right to data portability does not apply to processing of personal data that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Right to object

You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; This also applies to profiling based on these provisions.

The person responsible will no longer process the personal data concerning you unless he can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; This also applies to profiling insofar as it is connected to such direct advertising.

If you object to processing for direct advertising purposes, your personal data will no longer be processed for these purposes.

Right to revoke the declaration of consent under data protection law

You have the right to revoke your data protection declaration of consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out based on the consent before its revocation.

Automated decision-making in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

  • is necessary for the conclusion or fulfillment of a contract between you and the person responsible,
  • is permitted by Union or Member State law to which the controller is subject and such law contains appropriate measures to safeguard your rights and freedoms and your legitimate interests or
  • with your express consent.

However, these decisions may not be based on special categories of personal data in accordance with Article 9 Paragraph 1 GDPR, unless Article 9 Paragraph 2 Letters a or g applies and appropriate measures have been taken to protect your rights and freedoms as well as your legitimate interests.

With regard to the cases mentioned in (1) and (3), the controller shall take appropriate measures to protect the rights and freedoms as well as your legitimate interests, including at least the right to obtain human intervention on the part of the controller, to express one’s own point of view and heard to challenge the decision.

Right to complain to a supervisory authority

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work or the place of the alleged violation, if you believe that the processing of personal data concerning you violates the GDPR.

The supervisory authority to which the complaint was submitted will inform the complainant of the status and results of the complaint, including the possibility of a judicial remedy in accordance with Art. 78 GDPR.

A list of the data protection authorities with contact details can be found at https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschrift_links-node.html

Asserting your rights against the person responsible

You can exercise your rights at any time in writing, by email or by telephone. Please contact:

Smart Farm Robotix Ltd.

Rossen Dimov

19 Rusaliyski Prohod, office 3

Sofia 1407

Bulgaria

Tel.: +359 885 342 177

Email: office@smartfarmrobotix.eu

Please use “GDPR request” as the subject of the email. Emails without this subject will not be processed.

Change in data protection regulations

In order to ensure that our data protection declaration always complies with current legal requirements, we reserve the right to make changes at any time. This also applies in the event that the data protection declaration needs to be adjusted due to new or revised services, for example new services. The new data protection declaration will then take effect the next time you visit our website.

Status of the data protection declaration: August 9th, 2022