General terms

On May 25, 2018, the General Data Protection Regulation (GDPR) entered into force for all EU member states. It applies directly in Bulgaria as well as any national law and covers the rights and obligations of administrators, processors and subjects of personal data; some of the details are additionally regulated by the Bulgarian Personal Data Protection Act. All users of www.mtscloud.eu are subjects of personal data and have different rights in this regard. This policy aims to tell more about the protection principles and personal data of users of www.mtscloud.eu, about our responsibilities as personal data controller and about the measures we have taken to prevent your data from being used without knowing by whom and for what purposes or without being able to object or withdraw your consent to their processing. The policy will not remain the same throughout the existence of our website; as digitization advances and the regulation of personal data processing relationships evolves, we will seek to continually improve and align our practices with these developments, which in turn will be reflected in policy. EMTYES CLOUD strictly adheres to the applicable regulations in the field of data protection in every personal data processing operation carried out through the website.

This Privacy Policy applies only to www.mtscloud.eu, but not to individual pages and websites of third parties that you may reach by referral or in another similar way from www.mtscloud.eu. In these cases, EMTYES CLOUD has no control over the processing of data by third parties and cannot guarantee the protection and privacy of your personal data.

This policy was approved by the manager of "EMTIES CLOUD" OOD on 01.08.2023 and regulates the processing of personal data through www.mtscloud.eu.

You can contact the EMTYES CLOUD data protection officer regarding any ambiguities related to the application of this policy or the exercise of your rights at support@mtscloud.eu.

Key concepts

"Personal data" - this is any information that relates to you - the visitor/user of our website or software application and that alone or in combination with other information can help us to establish your identity or to associate your user behaviour with an accurate specific device from which you access our website.

"Subject of personal data" – this is you, the user of www.mtscloud.eu.

"Processing of personal data" – this is any action that we perform or may perform with your personal data, including, but not limited to, their collection, analysis, storage, destruction, etc.

"Administrator of personal data" -EMTIES CLOUD OOD" (EMTIES CLOUD), registered in accordance with the laws of the Republic of Bulgaria, with registered office and address of management: Republic of Bulgaria, Veliko Tarnovo, 21 G.S. Rakovski Street, registered in the Trade register with the Registration Agency of the Republic of Bulgaria with EIC: 206248307, which is the owner of the domain www.mtscloud.eu. We determine the purpose of processing your data, on one of the grounds provided for by law; basically, we also determine the means by which this processing takes place – for example, the technical infrastructure and applications with which the processing takes place.

"Processor of personal data" – this is a third party that processes your personal data on our behalf, where EMTYES CLOUD has strictly determined the purpose of the processing, the means by which it takes place and checked whether the person meets the requirements of the GDPR. Such a processor can be, for example, an agency that is responsible for a marketing campaign of EMTYES CLOUD in a social network and creates reports on its success.

"Cookies" are small text files stored in the directories of the browser used by the user. Cookies are used to help users use the websites effectively and to make certain functionalities available. Cookies have an essential role in facilitating and improving the usability of websites, therefore, if they are deleted or blocked, some websites or certain of their functionalities may become unavailable to users.

"Information society services" are services which are generally provided for a fee and at a distance through the use of electronic means. The recipient of such service must have expressly requested it. E-commerce is also a type of such service.

Security and data protection

EMTYES CLOUD takes the necessary technical and organizational measures to protect your data on www.mtscloud.eu from any illegal actions, including loss and unauthorized access. In order to guarantee high security, the measures are taken in two stages -

at the design stage of individual segments of the website and the services offered, as well as at the default stage - when you, as a user, fill out a contact form / register to receive a newsletter or in another similar way. The measures include limiting access to your personal data, strictly following the rules in the internal policy, appropriate training of the persons responsible for the processing of your personal data and compliance with good practices, guidelines and instructions for the protection of personal data from the competent supervisory authorities. All measures are subject to regular review and are periodically updated. In the event of a breach of the security of your personal data, we will notify you without undue delay within a reasonable period of time after becoming aware if the breach of the security of personal data is likely to result in a high risk to your rights and freedoms.

Personal data processing activities

EMTYES CLOUD will process your personal data in accordance with applicable data protection legislation. When you correspond with us by email or fill out a feedback form on our website, you undertake that the data you provide will be accurate, correct and up-to-date. Through www.mtscloud.eu, EMTYES CLOUD collects personal data in the following ways:

Feedback form;

Sign up for a newsletter;
Form for Business partners (Partner log-in);
Cookies/etc. similar methods.

When you visit the website, cookies are attached to your terminal device that allows your actions or preferences to be "remembered" for a certain time. For more information, please see our Cookie Use and Management Policy.

Categories of personal data
The following categories of personal data are collected through the website:

Names
Phone
Email

Period of storage and destruction
Personal data are stored for the periods necessary to achieve the purposes for which they were collected. EMTYES CLOUD takes the necessary technical and organizational measures to destroy the data that are no longer needed, except for cases where there is a legal basis to process them for a longer period of time; upon your request to restrict processing, according to your rights, detailed below; or for a purpose compatible with the original processing purpose, of which you will be promptly informed.

Legality
Personal data are processed on the grounds specified in Art. 6 of the General Regulation on the Protection of Personal Data, as follows:

In cases where you fill in the Contact Form - we process your personal data based on your consent and for the purposes of responding to your specific request (e.g. information on device models, functionalities, questions related to the purchase of our devices and warranty service, positive reviews and criticisms, others).

In the cases when you fill in the Form for Business partners (Partner log in), we will process your data for the purposes of providing the requested service - You will have easy access to and the possibility to download files with service documentation (exploded drawings, lists of spare parts , their prices and photos, electrical diagrams, instructions for use.

In the event that you enter your e-mail to sign up for a newsletter, we will consider this action as an affirmative act by which you express your freely given, specific, informed and unambiguous request for consent to process your data for the purpose of receiving a newsletter for our products and services.

You can withdraw your consent at any time, after which EMTYES CLOUD will not send you informational materials unless you explicitly request your consent to this again by re-entering your Email in the form. You can withdraw your consent by following the link in the received Email with information materials or at support@mtscloud.eu.

If you are not sure on what basis we process your personal data, you can always ask us about this, and about the exact way in which you gave your consent, you can contact us.

Processing based on the legitimate interest of EMTYES CLOUD or a third party and objection to such processing

EMTYES CLOUD processes your data on the basis of consent and for the purposes of performing the service you have requested through the functionalities of www.mtscloud.eu. Where your consent has not been requested and given for the purposes of specific processing, or it is not immediately necessary for the performance of the service you have requested, we are most likely to have as a basis our or a third party's legitimate interest which we have determined will not damages or would significantly affect your right to privacy. Such judgment will always be documented by us and will follow certain criteria and reasoning. You have the right to familiarize yourself with the main points of it upon request, as well as to raise an objection that, given the particularities of your particular situation, a relevant

this processing affects your right to privacy and/or protection of personal data in a more substantial way than provided for in the rationale. In these cases, we should consider your objection and issue a reasoned opinion on its acceptance or rejection within 10 working days. By objecting to this processing, you can also exercise your right to object above. The objection can be addressed to us at support@mtscloud.eu.

Disclosure of Data to Third Parties
EMTYES CLOUD will not disclose personal data to Third Parties, except in cases where it is necessary to protect the vital interests of you/another natural person, or for the purposes of complying with a legal obligation that applies to EMTYES CLOUD, as an administrator of personal data.

EMTYES CLOUD does not transmit personal data collected through www.mtscloud.eu to a third country or international organization outside the European Union.

Your rights

As a data subject and user/user of www.mtscloud.eu, you have the following rights:

Right to information
In addition to the information set out above, you should be aware that you are not subject to automated decision-making, but we do perform profiling for the purposes of assessing solvency. According to the applicable legislation in the field of personal data, you have the rights below, and we undertake to respond to each of your requests within 1 month of receiving the request and without any fee. In case of factual or technical difficulties in the timely implementation of such requests, the deadline for implementation can be extended by another 2 months, for which you will be notified within one month of receiving your request.

Right of access
You can request confirmation of whether and what personal data about you is being processed, as well as access to this data.

Any information, communication and actions related to your rights are made and provided free of charge. When a user's requests are manifestly unfounded or excessive, in particular due to their repetition, EMTYES CLOUD may either impose a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the requested actions.

Right to corrections
If we process incomplete or incorrect personal data from you, you can request their correction or completion at any time.

Right to erasure

You can request the deletion of your personal data in the following cases:

the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
you withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
you believe that personal data has been processed unlawfully.
Note that there may be other reasons that prevent the immediate deletion of your data, such as statutory retention obligations, pending proceedings, the establishment, exercise or defence of legal claims, etc.

Right to restriction of processing
You have the right to request the restriction of processing if:

you dispute the accuracy of the personal data, for a period that allows us to verify the accuracy of the personal data;
the processing is unlawful, but you do not want the personal data to be deleted, but instead require the restriction of its use;
we no longer need the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims
you have objected to the processing of the data pending verification of whether EMTYES CLOUD's legal grounds for processing the data take precedence over your interests.
In the case of a requested restriction of processing, we will inform you before the cancellation of the restriction of processing.

Right to data portability
You can request the data you provide in a structured, commonly used and machine-readable format when both conditions are met:

the processing of the specific data is based on consent obtained or on a contractual basis; and
the processing is carried out in an automated manner.
Right to object
You have the right, at any time and on grounds relating to your particular situation, to object to the processing of your personal data which is based on a legitimate interest or is necessary for the performance of a task in the public interest or the exercise of official powers, in case, that such are provided to EMTYES CLOUD, including profiling based on these grounds.

When you have given your consent to the processing of data for the purposes of direct marketing, you have the right to object to the processing of personal data at any time without giving reasons.

Right to file a complaint
If you believe that we have violated applicable data protection legislation when processing your data and as a result affected your rights, please contact us. Of course, you have also the right to lodge a complaint with the supervisory authority. In Bulgaria, this is the Commission for the Protection of Personal Data.

Dispute Resolution and Applicable Law
In case of disputes, the applicable law is the law of the Republic of Bulgaria, and the competent court is the relevant court in the city of Veliko Tarnovo.

Any disputes between EMTYES CLOUD and the users of www.mtscloud.eu regarding personal data can be resolved through negotiations between the parties. In the unlikely event of a legal dispute, it should be referred to the Commission for the Protection of Personal Data or directly to the competent court in Veliko Tarnovo.

Update
The privacy policy of personal data comes into force from the date indicated at the beginning, and the same may be changed subsequently. The updated Policy enters into force on the day of its publication on www.mtscloud.eu. If you visit www.mtscloud.eu after the Policy has changed, you will be bound by the new Privacy Policy.

For additional information, as well as in connection with the exercise of your rights, you can contact us at support@mtscloud.eu.