SUIT MANUFACTURING PRIVACY POLICY
Last Modified on July 30, 2019
SCOPE OF POLICY
1. Suit Manufacturing Bulgaria Ltd (we or us) is committed to protecting and respecting your privacy. Please read the following carefully to understand our rules and practices regarding processing your personal data.
2. This policy is effective as of the date set forth above and applies where we process personal data, which is information relating to natural persons.
DATA CONTROLLER
3. For the purpose of clarity, the data controller is Suit Manufacturing Bulgaria Ltd, registered at Petyofi 1 Str. Plovdiv, Bulgaria (UIC/PIC 205348330; VAT BG205348330).
WHY AND WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS
4. We may process your personal data for the following purposes:
4.1. selling products and providing services to you;
4.2. communicating and providing customer support to you in relation to selling products and providing services to you (this includes calling you or sending e-mails to you after you have purchased a product and/or service from us, to check whether you are satisfied with the quality);
4.3. determining whether you would be interested in purchasing our products and services and based on that, informing you of our products and services by sending you direct marketing e-mails and/or making you direct marketing phone calls;
4.4. communicating with you after you have purchased a product or service from us, to offer you products and services to your liking based on your purchase history;
4.5. improving our business;
4.6. uploading your testimonial about our products and services to our webpage (https://www.suitmanufacturing.com/);
4.7. enforcing and defending our legal rights;
4.8. complying with legal or regulatory obligations or requests.
5. We collect and process the following personal data:
5.1. for purposes stated in sections 5.1-5.2 and 5.4: name, place of work, position, e-mail address, phone number, address, measurements, service details (e.g. purchase history), birth date;
5.2. for the purpose stated in section 5.3: name, place of work, position, e-mail address, phone number, relevant data available publicly on the data subject’s profile on LinkedIn (or any other relevant social media website);
5.3. for the purpose stated in section 5.5: name, e-mail address, phone number, any personal data which data subject may provide us by giving feedback;
5.4. for the purpose stated in section 5.6: name, any data provided in the testimonial;
5.5. for the purpose stated in section 5.7 any of the categories of personal data listed above (determined case-by-case according to the legal right which we are entitled to execute);
5.6. for the purpose stated in section 5.8 any of the categories of personal data listed above (determined case-by-case according to the legal obligation we are subject to).
6. The data which we process for the purposes established in section 5.3 of this Privacy Policy, is collected from your public profile from the professional social network LinkedIn (https://www.linkedin.com/) or from another website where such data is publicly accessible (e.g. your employer’s webpage).
7. Under the law you are not obligated to provide us any personal data (unless we indicate otherwise). However, provision of personal data is necessary to enter into the contract concluded between you and us under which we can sell you products and provide services (except the provision of the data of the testimonial). If you do not provide us the necessary personal data, we cannot enter into the contract with you.
LEGAL BASIS FOR PROCESSING PERSONAL DATA
8. We process your personal data because it is necessary for the fulfillment of a contract which is concluded between you and us (see sections 5.1, 5.2 ); or for taking steps at your request prior to entering into a contract (see section 5.2). In such a case the legal basis for processing data is the contract concluded between you and us; or your request prior to entering into a contract.
9. We process your personal data for determining whether you would be interested in purchasing our products and services and based on that, informing you of our products and services under legitimate interest pursued by us (see section 5.3). It is our legitimate interest to find people who may be interested in our products and services and offer them to such people. We assure that such activity does not entail any legal or otherwise significant effects concerning you. You have the opportunity to unsubscribe from such e-mails by clicking on the unsubscribe button in the e-mail. In case of a call you have the opportunity to tell us that you do not want us to make marketing calls anymore.
10. We process your personal data for communicating with you after you have purchased a product from us or used our services, to offer you products and services to your liking based on your purchase history under legitimate interest pursued by us (see section 5.4). It is our legitimate interest to inform you as our customer of our products and services. We assure that such activity does not entail any legal or otherwise significant effects concerning you. You have the opportunity to unsubscribe from such e-mails by clicking on the unsubscribe button in the e-mail. In case of a call you have the opportunity to tell us that you do not want us to make marketing calls anymore.
11. We process your personal data for improving our business under legitimate interest pursued by us (see section 5.5). It is our legitimate interest to continuously improve our business, also the products and services offered by us.
12. We process your personal data for uploading your testimonial to our webpage only if you have given your consent (see section 5.6). In this case the legal basis for processing the data is the consent given by you.
13. We process your personal data for enforcing and defending our legal rights under legitimate interest pursued by us (see section 5.7). It is our legitimate interest to enforce and defend our legal rights if we see it as necessary.
14. We process your personal data for complying with legal or regulatory obligations or requests as the processing is necessary for compliance with legal obligation to which we are subject (see section 5.8).
DISCLOSING YOUR PERSONAL DATA
15. We will not transfer your personal data to third parties except for the following cases:
15.1. to our measurers and salesmen (natural persons) located in European Union member states with whom you make an appointment for measuring you;
15.2. to manufacturers located in European Union member states who will create custom products for you;
15.3. to an e-mail service provider by which we send e-mails to data subjects (e.g. SendGrid, Inc., located in USA). SendGrid has joined the EU-U.S. Privacy Shield Framework which ensures the same level protection for personal data as set in the European Union (for more detailed information see: https://sendgrid.com/policies/privacy/privacy-shield-certification/);
15.4. to companies which provide us accounting services where it is necessary for selling products and providing services to you;
15.5. to companies which provide us services for developing and maintaining our ICT systems where it is necessary for selling products and providing services to you;
15.6. to companies which provide us cloud server services in which we store and process personal data (e.g. GoDaddy.com, located in the United States of America);
15.7. to companies which provide us services of finding personal data of people who might be interested in purchasing our products and services (e.g. Lusha Systems Inc, located in USA). Lusha Systems has joined the EU-U.S. Privacy Shield Framework which ensures the same level protection for personal data as set in the European Union (for more detailed information see: https://www.lusha.co/privacy_policy).
16. We take steps to verify that processors who we appoint to process personal data on our behalf will protect that personal data as required under data protection law.
17. We also have the right to disclose your personal data to the following persons in the following cases:
17.1. to a respective seller or buyer, in the event that we sell or buy any business or assets;
17.2. to a third party acquiring our company (Suit Manufacturing Bulgaria Ltd) or substantially all of our assets, if such acquisition should take place and in which case personal data held by us will be one of the transferred assets;
17.3. to a relevant institution requiring your personal data, if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;
17.4. to other companies and organisations for the purposes of fraud protection and credit risk reduction, in order to protect the rights, property or safety of our business, our customers or others.
HOW LONG DO WE STORE YOUR PERSONAL DATA
18. We only process and store your personal data for as long as it is necessary to fulfill the purpose for which it is processed – once the purpose has ceased, your personal data will be erased or anonymised.
19. Your personal data will be stored for:
19.1. up to 3 years after the last time we sold products or provided services to you, where we process your personal data regarding selling products and providing services to you (see section 5.1);
19.2. up to 3 years after last contact with you, where we process your personal data regarding communicating and providing customer support to you (see section 5.2);
19.3. up to 3 years after the first time we contacted you or until you unsubscribe from marketing e-mails or ask us not make any marketing calls (whichever is earlier), where we process your personal data for determining whether you would be interested on purchasing our products and services and based on that, alerting you of our products and services (see section 5.3);
19.4 up to 3 years after the last time we sold products or provided services to you or until you unsubscribe from marketing e-mails or ask us not make any marketing calls (whichever is earlier), where we process your personal data for communicating with you after you have purchased a product from us or used our services, to offer you products and services to your liking based on your purchase history (see section 5.4);
19.5. up to 3 years after the last time we sold you a product or provided services to you, where we process your personal data regarding improving our business (see section 5.5);
20. Your personal data will be stored:
20.1 until the withdrawal of consent by you where we upload your testimonial to our webpage (see section 5.6);
20.2. determined case-by-case according to the expiry date of the claim which we may submit or the claim which may be submitted against us but no longer than 10 years from the moment when the limitation period for the claim started, where we process your personal data for enforcing and defending our legal rights (see section 5.7);
20.3. determined case-by case according to the legal obligations we are subject to, where we process your personal data regarding fulfilment of obligations established in law (see section 5.8).
21. Personal data contained in any accounting documents (e.g. invoices) shall be stored for 7 years from the end of the last financial year they relate to.
YOUR RIGHTS
22. You have the right to contact Suit Manufacturing Ltd. at [email protected] to exercise your rights concerning processing of personal data. Such rights include the:
22.1. right to request access of personal data;
22.2. right to request rectification of personal data;
22.3. right to request erasure of personal data;
22.4. right to request restriction of processing of personal data;
22.5. right to object to processing of personal data;
22.6. right to request portability of personal data;
22.7. right that decisions are not taken concerning you which are based on automated decision-making;
22.8. right to withdraw a consent;
22.9. right to lodge a complaint with a supervisory authority.
23. Our website (https://www.suitmanufacturing.com/) may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our company is advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
CHANGES TO THE PRIVACY POLICY
24. Any changes we may make to our privacy policy in the future will be uploaded to our website and/or sent to you by e-mail.