Privacy Policy - FTS

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Privacy Policy

Last updated on March 19, 2025

FTS Bulgaria OOD undertakes to ensure the security of the personal data it collects and processes, lawfully, in good faith and in a transparent manner with respect to the data subject.

Personal data controller details
FTS Bulgaria OOD, UIC 831166152, registered office Bulgaria, Sofia, Bulgaria Blvd., Business Center Bellissimo, floor 5, office 58, telephone +359 2 818 36 63.

Definition of personal data
Personal data is any information related to the identification of a natural person (“data subject”), directly or indirectly through his name, telephone number, e-mail address, location data, online identifier, etc.

The security management of personal data by the Administrator is carried out in accordance with the Personal Data Protection Act, its subordinate regulations and Regulation (EU) 2016/679 – GDPR.

I. Data We Collect

FTS Bulgaria OOD collects personal data only when it is lawful and only if and to the extent that at least one of the following conditions is applicable:

    • the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
    • the processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract;
    • the processing is necessary for compliance with a legal obligation to which the controller is subject;
    • the processing is necessary to protect the vital interests of the data subject or of another natural person;
    • the processing 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;
    • processing is necessary for the purposes of the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

In connection with the above conditions, FTS Bulgaria OOD collects information from the following external natural persons:

  1. Data subjects showing interest in the products and services we offer (name, company, position, telephone and e-mail):
    • personal data in the forms of the company website for access to marketing materials, demo versions, chat, contact forms, etc.;
    • personal data when subscribing to a newsletter;
    • personal data contained in inquiries directly sent by e-mail.
  1. Job applicants (contact details, education, qualifications and professional experience) by means of:
    • CV submitted through web platforms for finding a job;
    • CV sent directly by e-mail;
    • CV submitted through the company website using the appropriate form;
    • LinkedIn profiles.
  1. Data subjects in their role as employees of legal entities – contractors of FTS Bulgaria OOD in connection with the performance of contractual relations.

Automatic data processing, when necessary, is carried out using methods in which there is no algorithm for receiving information about a given person, a subject of personal data, based on the initial aggregated information resulting from the automatic processing.

When accessing the websites of FTS Bulgaria OOD, information is collected regarding the domain/Internet address (IP) from which the website is used; the type of Internet browser and the operating system of the computer, the date and time of the visit; search results, as well as other similar parameters. This information is used only in aggregate form, without processing data about specific individuals, a subject of personal data, and is not provided to third parties.

II. Data We Processing and its Purposes

  1. For marketing activities:
    • to send certain information that we consider useful, including for sending marketing messages, such as newsletters and marketing messages are sent after confirmation by the recipient, with each message providing the opportunity to opt out of future such messages;
    • to contact us by phone or e-mail in connection with the interest shown in our products and services;
    • to personalize the content and advertising that you see on our websites and applications on the Internet.
  1. When applying for a job

The information collected in the process of searching for specialists for announced job vacancies or in cases of receiving a CV sent directly by e-mail is used solely for the purposes of selecting and hiring personnel for the needs of FTS Bulgaria OOD.

  1. On behalf of another administrator (client)

FTS Bulgaria OOD processes personal data on behalf of an administrator (client), only after a written agreement between the parties. This data may include:

    • client test/demo data, as well as real data in systems installed at our clients;
    • access data when providing hosting;
    • data for remote access to client environments.
  1. When interacting with contractors

As part of the fulfillment of obligations under contracts concluded with clients, FTS Bulgaria OOD may process the following data:

    • contact data stored in company systems and project documentation;
    • Microsoft Customer Source / Office 365 accounts.
  1. Processing of personal data of persons under the age of 16

FTS Bulgaria OOD does not process data of minors. In the event that such information is received through any of our communication channels, it is subject to immediate deletion.

III. Storage and Processing of Personal Data

FTS Bulgaria OOD stores and processes personal data in its capacity as administrator or processor, only for the purposes for which they were initially collected, which includes processes related to contract management, human resources management, marketing, development/implementation and maintenance of software products.

Personal data storage period:

    • FTS Bulgaria OOD stores the collected personal data for marketing purposes until the explicit withdrawal of the given consent or receipt of an objection to the processing of personal data for direct marketing.
    • Data of job applicants are stored for a period not exceeding one year.
    • Personal data of employees of contractors are stored within the statutory deadlines within which legal claims can be brought.
    • Personal data provided for processing by personal data administrators are stored only for the period of processing, subject to a written contract between the parties.

IV. Sharing Personal Data with Third Parties

Personal data may be disclosed by FTS Bulgaria OOD, provided that this is permitted by law, in connection with a change in the corporate or financial structure of FTS Bulgaria OOD or its affiliated legal entities. Personal data may also be disclosed in order to protect the vital interests of the data subject, the legitimate interests of FTS Bulgaria OOD (unless such interests of FTS Bulgaria OOD are overridden by the rights and freedoms or interests of the data subject) or where, in the opinion of FTS Bulgaria OOD, this is necessary for FTS Bulgaria OOD to comply with applicable law or to comply with its obligations under the law or to respond to requests or inquiries from competent supervisory authorities.

V. Personal Data Security

FTS Bulgaria OOD maintains a high level of competence and awareness among employees regarding the importance of secure storage and processing of personal data processed in our role as an administrator, as well as in cases where personal data of clients is processed.

FTS Bulgaria OOD concludes a contract and/or additional agreements with clients for the processes in which the company is a personal data processor, with subcontractors for personal data processing, as well as with persons to whom it assigns personal data processing, but who are not subcontractors.

FTS Bulgaria OOD concludes confidentiality agreements with its employees.

FTS Bulgaria OOD implements technical measures to protect personal data, which include:

    • authentication;
    • access management;
    • storage of access information;
    • security of workstations;
    • security of portable information assets;
    • protection of the internal network;
    • protection of servers;
    • protection of websites;
    • continuity of services;
    • archiving;
    • secure data destruction;
    • secure data exchange with customers;
    • physical security;
    • use of cryptographic mechanisms;
    • data anonymization.

VI. Rights of Individuals Regarding Their Personal Data

Every natural person, a subject of personal data, by law has:

    • Right of access: to obtain confirmation as to whether personal data relating to him or her are being processed and, if so, to obtain access to the collected personal data concerning him or her and to exercise this right to be informed of the processing and to verify its lawfulness.
    • Right to restriction of processing: to request from the controller restriction of processing where the accuracy of the personal data is contested, the processing is unlawful or FTS Bulgaria OOD no longer needs the personal data for the purposes of the processing, but the data subject does not wish the personal data to be erased, as well as where the data subject has objected to the processing.
    • Right to erasure (right to be forgotten): to request that personal data be erased where the personal data are no longer necessary for the purposes for which they were collected, there are no overriding legitimate grounds for the processing, or the personal data have been processed unlawfully.
    • Right to object: to object to processing for direct marketing purposes (including profiling), whether for initial or further processing. The data subject shall be explicitly informed of the existence of this right, which shall be presented to him/her in a clear manner and separately from any other information.
    • Right to object: to withdraw consent to the processing of personal data at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent given before its withdrawal. Before giving consent, the data subject shall be informed thereof.
    • Right to rectification: to request FTS Bulgaria OOD, as the controller, to rectify without undue delay inaccurate personal data relating to him/her. Considering the purposes of the processing, the data subject has the right to have incomplete personal data completed, including by adding a declaration.
    • Right to data portability: to receive the personal data concerning him/her, which he/she has provided to the controller, in a structured, commonly used, machine-readable and interoperable format, for the purpose of transmitting those data to another controller.
    • Right to complain: to file a complaint with the Personal Data Protection Commission of the Republic of Bulgaria if he/she believes that the processing of personal data violates his/her legal rights or to apply to the competent court, as well as to receive compensation for damages.

VII. Cookies

A “cookie” is a small data file transmitted by the website to the user’s device, to provide information about the behavior when browsing the website, which can be used to personalize the operating mode. FTS Bulgaria OOD uses cookies only after prior notification and consent from the user.

  1. What cookies do we use

Google

We use Google Analytics service of Google Inc. (“Google”), through which information about your actual location and other technical information about your visit to the website is collected and processed. The information includes the Internet Protocol (IP) address used to connect your device, the “clicks” to, through and from our website (including date and time), information about interactions with the website (such as possible views, “clicks” and “mouse movements”). Google Analytics uses various technologies to determine location, including IP address, GPS, and other sensors that can, for example, provide Google with information about nearby devices, Wi-Fi access points and power. This information will be transferred to a Google server in the USA, where it will be stored and analyzed. The corresponding results will be provided to us in an anonymized form. In this process, the data collected will not be associated with your full IP address.

For more information, see Google’s Terms of Service and Policies, which can be found at https://policies.google.com/?hl=bg.

Hotjar

We use the services of Hotjar Ltd. Hotjar provides software as a service (SaaS) in the form of a digital experience analytics platform. The platform provides visual data on the behavior and usage of the website by its visitors.

For more information, see the platform’s Terms and Conditions and Policies, which can be found at https://www.hotjar.com/legal/.

Meta Pixel

We use the Meta Pixel service of Facebook Ireland Ltd. (Facebook) on our website for the purpose of analysis, optimization and economic exploitation of the website. With the help of Meta Pixel, Facebook can define visitors to our page as a target group for displaying advertisements on the platform. Accordingly, we use Meta Pixel to display the advertisements we publish on Facebook to users of the social network who have shown an interest in our website. With Meta Pixel, we can also track the effectiveness of the advertisements for statistical and market research purposes, by seeing whether users were redirected to our page after clicking on an advertisement on Facebook (so-called “conversions” or “visitor interaction”). Meta Pixel is triggered directly by Facebook when you visit our website and may store a cookie on your device. The data collected about you is anonymous to us, so we are not provided with any information about the identity of the users. However, Facebook stores and processes the data so that a link to the respective user profile is possible. This means that user profiles can be created from the processed data.

Facebook processes the data in accordance with its Privacy Policy, which is available at https://www.facebook.com/privacy/center/.

  1. How to refuse or delete cookies

Some internet browsers automatically accept cookies. Regardless of your browser’s default settings, you can refuse, block or delete all cookies stored on your device at any time. You can find out how to do this on the “Help” menu of your internet browser or by visiting https://www.allaboutcookies.org.

Please note that if you decide to delete or block the cookies used on our website, you may not be able to access certain functionalities or be prevented from further receiving interesting content.

VIII. Additional Information

If you have any questions about our privacy practices or questions, requests or concerns about your information, please contact us by email at address: gdpr@fts-eu.com.

IX. Policy Changes

This policy may be subject to changes in connection with necessary updates or in response to changes in the regulatory framework. The current version of the policy is publicly available on the website of FTS Bulgaria OOD.