COSMIC NETWORK LTD
We operate in the field of performance-based advertising. At the request of our customers, who are advertisers, we target specific user groups, via third party websites and media, in order to promote to them certain services or goods online. The Company recognises the importance of protecting the privacy of individuals and their personal information.
We are bound by the EU General Data Protection Regulation (EU Regulation 2016/679) (the GDPR). Under the GDPR, we are a controller for your personal information. We have appointed Appenture d.o.o. as our representative in the EU for the purposes of GDPR compliance.
how and when the Company collects personal information;
how the Company uses and discloses personal information;
how the Company keeps personal information secure, accurate and up-to-date;
how an individual can access and correct their personal information, and the other rights an individual has in relation to our processing of its personal information; and
how the Company will facilitate or resolve a privacy complaint.
The Act defines ‘personal information’ to mean information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from the information or opinion. We collect personal information when we provide or support services to you or the website or platform you engage with online. Generally we will tell you why we are collecting information when we collect it and how we plan to use it or these things will be obvious when we collect the information. We also require our partners to inform you of the fact that we may process your personal information, and what rights you have in that regard. We usually collect personal information directly from you although sometimes we may use agents or service providers to do this for us. Where your prior consent is required from us or the website or platform you engage with, to process your personal information, or store information on your device (such as cookies), you will first be asked to consent before your personal information is processed. We may also acquire lists from other sources, both from other companies and from other public documents. It is your responsibility to ensure your personal information held by the Company is accurate, up to date and complete.
COLLECTION OF INFORAMATION
What kind of personal information does the Company collect and hold?
The kinds of personal information that we collect will vary depending on the type of interaction with you and the purpose for collection but may include:
your name, address and other contact details (including telephone number);
your email address;
your date of birth;
transaction details relating to any payment that you have made to us or that have been made on your behalf;
credit card details, if you make a payment to us;
your username and password to access your account you may have with us;
information relating to your online activity, collected on the basis of cookies or similar technologies;
any preferences that you select, communicate or have allowed to be processed, such as preferences relating to your device settings or preferences regarding certain products or services; and
any other personal information which may be required in order to facilitate your dealings with us.
How does the Company collect and use personal information?
Generally, we collect personal information when you:
register as a member;
participate in a Company survey, competition, promotion or other marketing campaign;
indicate that you wish to receive news, offers or other marketing material from the Company;
make an enquiry or a complaint;
use a website or platform that uses or is supported by the Company’s services, which inter alia involve (i) the tracking of user behaviour across a number of campaign variables to identify new sales opportunities, and (ii) the tracking of a consumer journey from the first click on an ad, through to the achievement of the advertiser’s goal such as a purchase or install (conversion).
have other dealings with us.
We use personal information for the aforementioned purposes because you have consented thereto, because it is necessary for the preparation or conclusion of an agreement with you, because we are legally required to, or because of our legitimate business interests, which consist of making improvements to, customizing and understanding how you interact with our, or our partners’ and/or advertisers’, services and related content, products or services, and sending you communications about products and services we think may be of interest to you.
‘Cookies’ are small packages of data generated by a website that are transferred and saved to an individual’s hard drive. Its purpose is to remember information about you, similar to a preference file created by a software application. If you use our Website, we may utilise cookies to enable us to monitor traffic patterns and to serve you more efficiently. A cookie may identify your internet service provider or computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.
USE OF INFORMATION
What are the purposes for which the Company may collect, hold, use and disclose person information?
Generally, the Company only uses personal information for the primary purpose for which we have collected it, or for another closely related secondary purpose. Our potential uses of personal information which the Company collects (and for which you consent to us using your personal information for) may include:
to process and fulfil your advertising or other service requirements;
to get a better understanding of you, your needs, your behaviours and how you interact with us in order to identify ways in which we can provide you with a better service, or enhance your experience of our website and mobile site or other services;
managing your dealings with us;
so that we can promote our products and services to you and the products and services of third parties with whom we deal;
to allow our related companies to promote their products and services to you and those of their partners;
for business research and development of new products and services;
to facilitate the competitions, special offers and promotions that we or our partners may run;
displaying content and advertising that is customised to your interests, preferences and experiences, including through online targeted marketing, data and audience matching and market segmentation activities;
verifying your identity;
so that we can respond to enquiries and complaint handling;
for the purpose of data analytics and predicting trends;
marketing services in connection with the products and services we provide; and
to comply with our legal and regulatory obligations and enforce our legal rights.
Sometimes the Company will produce aggregated data. The Company may also receive aggregated data from its third party suppliers and contractors or business customers. This aggregated data does not identify individuals. The Company uses, and may combine, the aggregated data it produces and receives for research purposes and in connection with products and services we provide to our business clients.
From time to time, there may be other purposes for which we collect, hold, use and disclose your personal information. We will tell you about these at the point of collection.
Direct marketing and research
As set out above, the Company may use personal information about you for marketing and research purposes (Direct Marketing Communications). If at any time you do not wish to receive any further Direct Marketing Communications from us you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the email, managing your subscriptions via your member account or by contacting us via the details set out in Section 7 below.
DISCLOSURE OF INFORMATION
The types of organisations to which we may disclose your personal information
The Company may disclose your personal information to organisations outside of the Company. Such organisations and/or parties may include:
offshore service providers, if any;
related entities and subsidiaries of the Company;
third parties, such as financial institutions (banks); and
our contractors and agents, including but not limited to our IT service providers, or other companies who assist us in providing our products and services to you.
Otherwise, the Company will only disclose your personal information where we are required to do so by law.
Cross border disclosure
Personal information may also be processed by staff or by other third parties operating outside Bulgaria who works for us or for one of our suppliers, agents, partners or related companies.
If you do not agree to the transfer of your personal information outside Bulgaria, please contact us via the details set out in Section 7 below.
DATA QUALITY, SECURITY AND RETENTION
We have taken a number of physical, electronic and procedural steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.
We will store your personal information for as long as necessary given the purposes for which the information was collected and is used.
ACCESS TO PERSONAL INFORMATION AND OTHER RIGHTS
Under the Bulgaria Privacy Principles, you are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by law. You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out in Section 7 below.
If the GDPR applies to our processing of your personal information (see above), you will also have the right to object to our processing of your personal information for (i) direct marketing, and, depending on your personal circumstances, (ii) the purposes of our legitimate interests. Furthermore, you have (iii) the right to erasure of your personal information, (iv) the right to restriction of processing, (v) the right to data portability, (vi) the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or which similarly significantly affects you, (vii) the right to lodge a complaint with the competent data protection supervisory authority and (viii) the right to withdraw your consent at any time, where our processing of your personal information is based on your consent (such withdrawal shall not affect the lawfulness of the processing prior to the withdrawal). You may only exercise your rights to the extent that the GDPR grants you such rights.
If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us by using the ‘Contact Us’ facility on the Website or write to firstname.lastname@example.org
We will always endeavour to investigate your complaint and respond to you as soon as practicable after receipt, generally within 90 days.