The protection of personal data and the protection of the personal and financial information of our clients is especially important to us. Therefore, we process your information exclusively on the basis of the applicable legislation, specifically the General Regulation 2016/670 (better known as GDPR), the Personal Data Protection Act (PDPA) and the Electronic Commerce Act (ECA).

Please take a close look at this privacy policy for your personal data, informing you how ICS Technologies Ltd. (hereinafter “We”, “Us” or “the Company”) processes your data, specifically as regards to deadlines and legal basis for their collection, storage, use and destruction.

About our service

Our service enables our customers to send, receive and manage commercial messaging campaigns through mobile channels (SMS, Viber, Facebook Messenger, WhatsApp, etc. ). We also offer other related services, such as data analytics, to help our customers track and customize their campaigns. Find out more about our service here https://subscribe.bg/.

Personal data

The personal data we collect and process stems from the information you provide to us.

You (or your organization) may provide us with certain personal information when you create an account to use our service, consult our customer service team, send us an email, or contact and communicate with us in any other way.

This information may include:

Your name, job title or job position, employer name, phone number, email address and postal address, confidential login details (such as email address or username and password), contact details of your customers, the content of your campaigns, financial information, including amounts and details about payment methods, information about your device and use of the service (more about the latter can be found in the Cookies section below).

Processing of your data as a data controller

When you write to us via the form on our website, send us an email or message via one of the mobile platforms, we store your data for the period necessary to process your request and to answer your follow-up questions.

We process the data provided by you on two grounds: (1) in order to fulfill our pre-contractual or contractual obligations to you or (2) in case of establishing a legitimate interest of the Company.

Upon completion of an account registration and a contract executed by us, we store all data of the legal relationship thus arising on the basis of Art. 6(1)(b) of the GDPR until the expiry of the estimated 10-year term of Art. 12 of the Accountancy Act (AA).

In the case of only pre-contractual relations, we retain the data for a period of 30 days.

In cases of use on the basis of the legitimate interest of the Company, we process the data for a period of 12 months.

Processing of your data as a processor

As such, we process data provided to us by the relevant data controllers on the basis of a data processing contract, which contains the specific purposes and time limits of the processing. In these cases, the data controller we assist is responsible for the processing. As processors, we do not provide the processed data to third parties, except for the data controllers from which we have obtained it.

Role of third parties

As an administrator or processor of your data, we do not share them with third parties beyond the situations specified in this privacy policy.

We use the technical solutions of Amazon Web Services (AWS), MongoDB and Heroku, whose server infrastructure serves us in our data processing.

We value the privacy of our customers and their clients, which is why we have a separate contract for data processing using AWS.

We use the AWS service, which is co-located in the Frankfurt region, so when processing your data does not leave the territory of the European Union. If the data processing requires a transfer outside the EU or the European Economic Area, AWS shall ensure that one is carried out on one of the following grounds: (1) an approved code of conduct, (2) an alternative approved mechanism or (3) adopted by the national supervisory authority and approved by the European Commission “Standard Data Protection Clauses”.

The MongoDB and Heroku applications are additions to the AWS service and run on the latter’s servers in the Frankfurt region. In their terms and conditions, both MongoDB (here and here) and Heroku (here and here) ensure their compatibility with the legal framework for data processing in the European Union.

Cookies

 We use so-called cookies. These are small text files that are loaded in the browser and in another application and stored on your end device and on your customers’ devices. They allow us to analyze your campaigns and provide you with information arising from your use of the service.

Please also note that some of the cookies are “strictly necessary”. This means that by loading our site into your browser you have already accepted them because they are necessary for the functionality of our platform and cannot be excluded in our system.

Specifically, the cookies used on our site are

Statistical cookies help us understand how visitors interact with the website by collecting and processing anonymised information:

_ga – Registers a unique identifier that is used to generate statistical information about how users use the website.

_gat – Used by Google Analytics to limit the frequency of queries.

_gid – Registers a unique identifier that is used to generate statistical information about how users use the website.

Marketing cookies connect users of different websites in order to present relevant advertising content:

_fbp – Used by Facebook to provide advertising services.

fr – Used by Facebook to provide advertising services.

tr – Used by Facebook to provide advertising services.

We want you to know that we use cookies on the basis of Art. 4a of the Electronic Commerce Act (ECA) and Article 6(1)(a)(e) of the GDPR. Our legitimate interest within the meaning of GDPR consists of improving the functionality of the service provided by us.

Using opt-out

If you do not agree with our use of cookies, you can refuse to store cookies by setting your browser to inform you when a site wants to save cookies on your device and you may or may not accept them accordingly. Please note that disabling cookies in your browser may limit the functionality of our site for you.

Your rights

You have the right to access your data that we process, as well as the right to rectification, erasure (right to be forgotten), restriction of processing, data portability, withdrawal of consent and objection. If you believe that our processing of your data violates the provisions on the protection of personal data, or if you believe that your rights under these provisions have been violated in any way, you can contact the competent administrative authority. In Bulgaria, this is the Commission for Personal Data Protection.

Contact us in one of the following ways:

ICS Technologies Ltd. , with its seat and registered office in Sofia, Bulgaria, 11 Liditse street, ap.5

Phone: +359 877 000 123

Email: info@subscribe.bg

In each case, look for and contact Marin Georgiev.