Privacy Policy and Personal Data Protection

1. Introduction

As part of its operations Orthoteh Ltd. VIES 113564393, seated at Pernik, 26 Naycho Tsanov street, apt. 7, processes information, including personal data.

All information, including that collected from the website www.orthoteh-bg.com, is owned and managed by Orthoteh Ltd. in accordance with the provisions of the Personal Data Protection Act and related legislation, including, but not limited to, Regulation (EU) 2016 / 679 (“GDPR”).

This Policy aims to inform you about the way we process your personal data as an administrator, as well as your rights.

The protection of personal data is of the utmost importance to us. Orthoteh Ltd. does not sell your data to other companies or individuals. If we provide your data to third parties, it is our contractors or suppliers who process the information on our behalf, following our instructions and applying the adopted Regulation on personal data protection. We strive to provide the most clear, specific and transparent information possible regarding the processing of your personal data.

 

2. Personal data

Personal data is any information related to an identified or identifiable individual, such as email address, names, age, date of birth, phone number and others. Due to the specifics of its activity Orthoteh Ltd. could also collect and process specific biometric data, in order to unambiguously identify a person and their specific physical condition.

Personal data revealing race or ethnic origin, political views, religious or philosophical beliefs or trade union membership and processing of genetic data, or data regarding the sexual life or sexual orientation of an individual are a special category of personal data. Orthoteh Ltd. does not collect or process such information about you.

 

3. Collection and use of personal data

Orthoteh Ltd. collects, uses, stores and processes your personal data, which the company needs in order to provide the services and goods of Orthoteh Ltd. Your data is used to manage your account on our website, if you have created one, and to manage your purchases. Some of the personal information you provide is also used for the production of custom products that you have requested. The collected personal information could also be used for statistical and marketing activities of Orthoteh Ltd., which are related to improving the quality of our services.

 

4. Types of personal information collected

• When creating an Account, registering on our website, buying a product, preparing a contract – your names; your email address; delivery address for the goods ordered by you;
• To manage the access and identification of your account – email address and password;
• When paying online with a debit/credit card – email address, customer number, phone number, delivery address, information related to the means of payment, purchase amount.
• For issuing an invoice and its processing – all data required under Art. 114 of the VAT Act;
• Participation in online research and other marketing activities – the data provided within the various surveys is outlined in the survey itself and when providing it you will be notified of the storage and processing period.
• In case of returns and complaints – your names, your e-mail address (if used as a means of communication), the products that have been purchased; postal address, information regarding the return/complains and the product(s) concerned;
• For the production of custom products – your names, delivery address, e-mail address (if used as a means of communication), means of payment used, amount of payment and product(s), date of acceptance of the order, specific characteristics which we must take into account when designing a custom medical device.

 

5. Purposes and grounds for use of personal information

The main activities, goals and grounds related to the processing of personal data for Orthoteh Ltd. are:

• Management activities of our e-shop;
• Data for the purposes of execution of an order/s made by the e-shop of Orthoteh Ltd. on the basis of concluding a contract;
• Activities for the design of a custom medical device, based on our legitimate interest in producing quality products and providing them with the necessary corrections, replacements and repairs when necessary;
• Data for our payment fraud prevention system based on our legitimate interest in protecting the data we control;
• Accounting and invoicing of purchases based on our legal obligation to do so;
• Activities related to managing your account on our website, based on your consent;
• Data related to the management of your access to your personal profile on our website (identification), based on your consent;
• Marketing activities of the Company on the basis of a given consent.
• Noting and reviewinganomalies and complaints related to Orthoteh Ltd. products, based on the legitimate interest;
• Questions addressed to us related to our products, based on your consent.

 

The personal information we collect assists us in developing, delivering and improving our products, services, content and advertising. If you have created an account on our website, you can update your preferences at any time.

We may periodically use your personal information to send important messages such as notifications about your purchases and changes to our terms, conditions and various policies.

If you participate in events, lotteries, contests or promotions, we may use the information you provide for the administration of these programs.

6. Collection of information through other technologies. Use of cookies and web beacons

A “cookie” is a very small file, containing data, which is stored in your computer’s web browser when specific web pages are visited. By itself, a cookie does not contain or collect information, except when read by a server through a web browser; it may provide information in order to achieve a more user-friendly service by registering, together with other data and user preferences, by identifying errors and/or collecting data for statistical purposes. The cookie will not harm your computer, and no personal data is stored as a result of using the website. The installation of cookies is required for the full use of our website. In case you want to stop the operation of any of the installed cookies you will probably still be able to browse the website but certain functions of the website may be disabled. By changing the default settings of your browser you can determine whether, and to what extent, you allow cookies to access your computer. In Cookie Setting you can find out how to check and change the pre-set setting related to cookies. Please note that if you do not make any changes, you are accepting the default settings of your browser and agreeing to the activation of the cookies function. If you do not agree, please change your browser settings and restrict or remove the cookie installation feature. This information is summarized and provided as part of our efforts to comply with the requirements of the latest legal provisions, as well as to ensure that we are open, honest and clear regarding the confidentiality of user data.

A web beacon is a transparent graphic image that is inserted into online content, video, or email, and allows a server to read certain types of information from your device, such as when certain content or a specific email message has been viewed.

The paragraphs below aim to give you necessary and comprehensive information about the cookies and web beacons that Orthoteh Ltd. uses on its website for the purpose of transparency. We draw your attention to the fact that if you share the use of your device with others, it is possible for the personalized nature of the functions of cookies or beacons to change.

The website uses cookies to facilitate your navigation. Cookies and beacons are used for:

• Cookies necessary for the functioning of your search, which allow you to use the main functionalities such as managing your “shopping cart” and maintaining your identification throughout the search possible;
• Customizable cookies that allow you to visit websites in a personalized way according to your previous visits, purchases, etc. They allow you to find the offers that suit you best faster;
• Advertising cookies that allow you to receive offers from Orthoteh Ltd. on the websites of external partners;
• A web beacon to identify interest in specific products.

 

You can set your internet browser so that it does not save cookies or delete the cookies which have already been saved. If you want to take advantage of these features, please contact the manufacturer of your internet browser for more information on setting it up.

 

7. Personal data in social networks.

Your access to social networks such as Facebook, Instagram, Google +, YouTube, Twitter and others, requires a separate registration and accepting the General Terms and Conditions of these sites. Orthoteh Ltd. is not responsible for the protection of your personal data when accepting these General Terms and Conditions. Please read the General Terms and Conditions of these sites in detail.

 

8. Disclosure of personal data

Within Orthoteh Ltd., only employees whose immediate obligations are related to the activities for which the respective personal data is collected and processed have access to personal information.

Orthoteh Ltd. may disclose certain personal information to strategic partners – subcontractors, who work with us by providing products and services related to the company’s activities or assist Orthoteh Ltd. in the production, delivery and marketing to customers. Personal information will be provided only in cases where this is unavoidable (for example, producing personal customer cards or sending a specific product that you have ordered through the courier company selected by you in the order or specified in the terms of delivery).

In the cases in which Orthoteh Ltd. shares information about you with third parties – suppliers of Orthoteh Ltd., the company has mechanisms to ensure that they provide a level of data protection according to the agreed standard. Your data is also considered confidential for our partners.

It may be necessary – by law, during a legal trial, in litigation and/or at the request of public and governmental authorities in or outside your country of residence – for Orthoteh Ltd. to disclose your personal information. We may also disclose information about you if we find that, for purposes of national security, law enforcement, or other matters of public importance, such disclosure is necessary or appropriate.

 

9. Protection of personal information

Orthoteh Ltd. takes precautionary measures – including administrative, technical and physical measures – to protect your personal information from loss, theft and misuse, as well as from unauthorized access, disclosure, alteration or destruction.

The E-SHOP online service uses encryption through secure methods on all web pages where personal information is collected.

When you post on forums, chat rooms or social networking services, the personal information you share is visible to other users and may be read, collected or used by them. You are responsible for the personal information you choose to provide in those cases.

All employees of Orthoteh Ltd., who have the right to work with personal information, are obliged to protect its confidentiality, as well as to observe the applicable organizational and technical measures for its protection. Access to your data is limited on the principle of necessity to perform one’s duties.

For the cases in which Orthoteh Ltd. shares information about you with third parties – the company has mechanisms to ensure that they provide a level of data protection according to the agreed standard.

 

10. Storage of personal information

In order to determine the appropriate storage period, we take into account the amount, nature and sensitivity of the data, the potential risk of harm in the event of unauthorized use or provision, the purposes of processing and whether we can achieve these objectives by other means, as well as the applicable legal requirements regarding data storage.

We will store your personal information for the period which is necessary to meet the objectives set forth in this Privacy Policy, unless we are required by law to retain it for a longer period. According to the type of data and the purposes for which it is collected, a storage period is set, after which the information is permanently deleted.

We are required by law to store some basic information regarding our customers (such as names, contact information, financial information and transaction information) for a period of ten years.

 

11. Your legal rights in relation to the collection and use of your personal data

If you have provided your personal data to Orthoteh Ltd., the following options are available to you at any time:

• to check if you contact information is accurate, complete and up to date through your profile on the website of Orthoteh Ltd., if you have created an account there;
• right of access to your personal data processed by Orthoteh Ltd.;
• the right to request an appropriate correction, deletion or blocking of your personal data;
• the right to data portability in a structured, widely used and machine-readable format;
• the right to object at any time to the processing of your personal data when there are legal grounds for doing so;
• the right to refuse the processing of your personal data for the purposes of receiving an e-newsletter and other marketing communications, etc.;
• the right to complain to the Data Protection Commission if you believe that your data protection rights have been violated.

If you wish to exercise your rights or refuse to receive our e-newsletter and other marketing communications, you can contact us by sending an email to orthoteh@abv.bg or by sending a letter to the postal address:

Orthoteh Ltd. Personal Data Protection Officer

8 Poruchik Nedelcho Bonchev street, 6^th floor

Sofia 1528

or

1528 гр.София,

ул. Неделчо Бончев 8, ет 6 ,

ОРТОТЕХ ЕООД, За длъжностното лице по защита на личните данни.

 

You can also contact the “Personal Data Protection Officer at Orthoteh Ltd.” via telephone: 0899 140 919

We may refuse to process requests that are unreasonably repeated, require a disproportionate technical effort, jeopardize the privacy of other users, requests that are extremely impractical or otherwise not required by law.

The exercise of your rights, when they are not recurring and unfounded, is not subject to the payment of a fee.

When we receive a request to exercise any of your rights, we may need additional information from you to verify your identity in order to ensure that you have the right to access the data (or to exercise any of the other rights). This is a security measure that aims to ensure that personal data is not provided to people who are not entitled to receive it.

We will strive to respond to all legitimate requests within one month. It may take us more than a month to respond to your request if it is particularly complex or if we have received numerous requests from you. In this case, we will notify you in a timely manner and will keep you informed of any developments.

 

12. International data transfers

We do not transfer your personal data outside the European Economic Area (EEA).

 

13. Personal data of persons under 14 years of age

Personal information for persons under 14 years of age is provided only by a parent and/or legal representative.

 

14. Validity and updates of the Personal Data Protection Policy

We may periodically update our Personal Data Protection Policy. In the event of a change in this Policy, a notice will be published on our website, as well as the updated Personal Data Protection Policy.