Personal Data Policy

1. General

1.1. This Personal Data Policy (the Policy) is adopted by Hamilton Apps EOOD (Hamilton Apps). This Policy contains a general description of how personal data is processed through the website hamiltonapps.com (the Website).

1.2. Hamilton Apps is a legal entity under the laws of the Republic of Bulgaria (VAT No. BG201334130) and acts according to the laws of the Republic of Bulgaria.

1.3. Hamilton Apps’ policy with regard to personal data processing is that personal data must be processed only in cases and in the procedure specified by the applicable laws and, at the same time, Hamilton Apps considers the observance and protection of data subjects’ rights and legal interests as its main priority. Personal data is processed solely on a legal and fair basis.

1.4. This Policy is publicly available at the Website and always accessible for acknowledgement.

2. Data Processing Purposes and Lawfulness

2.1. This is an international Website addressed to users from all over the world who are interested in Hamilton Apps business applications. The users are deemed to include representatives of legal entities and any private individuals accessing the Website.

2.2. The Website does not have any user registration or authentication functionality. The users have the right to access any parts or sections of the Website without registration. The users’ personal data may be collected and processed when users fill out a feedback form or other web-forms on the Website or otherwise use the Website.

2.3. In all cases Hamilton Apps processes personal data only subject to the user’s explicit consent. The user has the right, at any time and free of charge, to withdraw the consent that they have given for Hamilton Apps to process their personal data by sending a notice to bulgaria@hamiltonapps.com or the postal addresses specified in this Policy. The user should note, however, that such withdrawal may mean that Hamilton Apps may not be able to reply to user’s messages or otherwise serve the user. In addition, the user may no longer be able to use all the functionalities on the Website, since the personal data processing activities relying on the user’s consent is an integral part of such functionalities.

2.4. Hamilton Apps never collects personal data without the user’s knowledge. Personal data is always processed for the purposes for which it was provided.

2.5. Hamilton Apps may process personal data via the Website for the following purposes:
• Replying to users’ messages; and
• Informing users of Hamilton Apps, business applications and advertising.

2.6. The consent clauses incorporated into a web-form must set forth particular data processing purposes.

3. Personal Data Collection

3.1. Hamilton Apps always collects personal data through web-forms assuming that
• All personal data belongs exclusively to the data subject who filled out a web-form;
• The user followed web-form guidelines and, among other things, inputted information to the proper sections;
• The user has attained the legal age of adulthood and he/she is a legally capable person; and
• The user provided authentic and actual personal data.

3.2. The personal data collected by Hamilton Apps may include, among others, the following information
• your name, e-mail address, phone number, text of message, consent, feedback, IP-address.

3.3. Hamilton Apps may ask users to amend or clarify personal data and confirm their authenticity if it appears to be necessary.

3.4. In no case will the Website be used in order to collect personal data about bank (credit) cards, other personal financial information, biometrical or sensitive categories of personal data (criminal convictions, political preferences, etc.).

4. General Conditions of Personal Data Processing

4.1. Hamilton Apps treats personal data as confidential information and takes all reasonable, necessary and adequate measures for maintaining secrecy and preventing illegal access to personal data and/or the illegal use thereof. Hamilton Apps will not disclose personal data collected through the Website unless the data subject personally requests (in writing) that information about him/her be made public.

4.2. The scope and content of processed personal data is limited to the declared processing purposes.

4.3. Hamilton Apps ensures the accuracy, adequacy and, if necessary, actuality of processed personal data with regard to the processing purposes. Incomplete or incorrect data is clarified or destroyed without delay.

4.4. Hamilton Apps processes personal data with and without use of automation tools. If arrays of personal data are processed for incompatible purposes, they must not be merged into one database. Personal data is not used for automated decision making having legal or similar consequences to you.

4.5. The Website is directly used only for collecting personal data and transferring it to computer systems and/or employees of Hamilton Apps or to other parties specified in Section 4.6 here below. The Website and its hosting servers do not perform any automatic (independent) actions aiming at recording, systematising, accumulating, storing, clarifying (updating, changing) and extracting of personal data.

4.6. Hamilton Apps may provide personal data to third parties, including affiliated companies, partners and suppliers for achieving the data processing purposes. If this is necessary, Hamilton Apps mentions such third party processors in the data processing consent included into all web-forms on the Website. At the same time, Hamilton Apps ensures compliance with all applicable statutory requirements and requests to strictly ensure the secrecy of personal data from all data recipients.

4.7. Hamilton Apps may carry out transborder transfers of personal data also outside the European Union (“EU”) or the outside the European Economic Area (“EEA”). In such situations, Hamilton Apps ensures that sufficient level of data protection is maintained through EU commission’s model clauses. Data subjects may receive a copy of the safety measures by sending a notice to bulgaria@hamiltonapps.com.

4.8. Hamilton Apps pays due attention to personal data processing operations and protection in its day-to-day business. Hamilton Apps only admits employees with appropriate job duties to perform operations with personal data and only provided that they have received training and their access rights are documented properly.

4.9. Storage of personalised data is limited to the time period required for achieving the data processing purposes unless otherwise prescribed by the applicable law. The processed data must be destroyed or depersonalised when the processing purposes are achieved or no longer actual unless otherwise prescribed by the applicable law.

5. Personal Data Rights of Users

5.1. Data subjects have the following rights:
• To receive information concerning the process of their personal data;
• To demand that their personal data be clarified, blocked or destroyed if this data is incomplete, outdated, incorrect, illegally received or irrelevant to the declared personal data processing purpose;
• To challenge actions (negligence) of Hamilton Apps before the competent authorities;
• To protect rights and legal interests including the right to recover damages and/or moral hazard in a legal action or in any other action as prescribed by the applicable law; and
• Other rights established by the applicable law.

6. Use of Cookies and Website Analytics

6.1. A cookie is typically a small piece of data sent to your computer device from a website and stored in your web browser while you are browsing a website. When you browse the same website again, the data stored in the cookie may be retrieved by the website to notify the website of your previous activity.

6.2. From time to time, a ‘cookie’ file may be placed on your computer to improve the effectiveness of this site and/or Hamilton Apps’ services to you. Most browsers are set to accept cookies. You can change your settings to refuse all cookies or to tell you when a cookie is being sent.

6.3. This policy details how Hamilton Apps utilizes cookies and cookie-like files and technologies on the Website. If you visit the Website and your browser settings accept cookies, Hamilton Apps considers this as an express consent of Hamilton Apps’ use of cookies.

6.4. The use of certain cookies is necessary to run basic functions on the Website. These cookies are essential for running the Website and are needed to provide you a pleasant experience when visiting the Site.

6.5. Hamilton Apps may also use cookies to provide better services and products to you. These cookies are used for e.g. site improvement, personalization and advertising. From your point of view this means that the Website may remember e.g. the language and country choices you have made. Hamilton Apps may look at where the content of the Site is accessed to help Hamilton Apps arrange the Website for best possible user experience. These cookies help make the content of the Site personalized, for example by showing you targeted banners and recommendations. Hamilton Apps also looks at what kinds of references are used to reach the Site in order to evaluate the effectiveness of Hamilton Apps’ campaigns and promotions. Hamilton Apps uses these cookies to serve Hamilton Apps ads from Hamilton Apps.

6.6. When you visit our website, you may notice some cookies that aren’t related to Hamilton Apps. We use some third-party cookies to optimize your experience regarding our website ads and to help us offer relevant content. If you go on to a web page that contains embedded content, you may be sent cookies from these websites. We don’t control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.

6.7. The length of storage of information depends on the type of cookie used. Session cookies expire when the browser is closed, while persistent cookies have typical expiration dates between two months and a couple of years.

6.8. The Website uses a web analytics service provided, for example, by Google, Inc (“Google”). To read a statement on the web analytics service by Google, please click here: http://www.google.com/analytics/terms/gb.html. By using the Website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above statement.

7. Feedback

7.1. Hamilton Apps aims at communicating with users in order to prevent any breach of their rights and legal interests in a prompt and effective way to the maximum possible extent. Any questions about personal data processing must be addressed to bulgaria@hamiltonapps.com or delivered by regular mail to Hamilton Apps EOOD, Sredets District, 3, “Narodno Sabranie” Sq., 1000 Sofia, Bulgaria.

Appendix. Information about Fulfilled Data Protection Requirements

1. Hamilton Apps uninterruptedly improves its personal data protection system and takes all necessary administrative, legal and technical measures with a view to international standards.

2. Hamilton Apps complies with the following personal data protection requirements and ensures that third party processors also meet them if and when it is required and taking into account threats to information systems used for the functioning of the Website and personal data processing:
− Ensures security of premises accommodating the equipment of information systems, which are used for processing personal data collected through the Website, in a way preventing any person without appropriate access rights from uncontrolled intrusion or stay in these premises;
− Ensures safety of all personal data carriers;
− Adopts a list of employees whose work duties require access to the personal data;
− Uses information security tools, of which compliance with the information security requirements of the applicable laws is duly assessed and confirmed, when such tools are necessary for neutralisation of actual threats;
− Appoints an employee or a business unit as a data protection officer;
− Ensures that all changes of access rights with regard to the personal data are automatically recorded in the electronic messages log;
− Provides access to the electronic messages log only to those employees or other authorised persons who need this access for the discharge of their work duties; and
− Fulfills other requirements.