PRIVACY POLICY

 

Introduction

 

Welcome to the Privacy Policy of Exceedia EOOD, part of Methodia Group.

Methodia respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Methodia collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, request a demo or service or take part in a any of our campaigns.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Methodia is the controller and responsible for your personal data (collectively referred to as Methodia, “we”, “us” or “our” in this privacy notice).

Methodia Group is made up of different legal entities located in European Economic Area. This privacy notice is issued on behalf of the Methodia Group so when we mention Methodia, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Methodia Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Methodia AD is the controller and responsible for this website.

You have the right to make a complaint at any time to the Commission for Protection of Personal Data, the BG supervisory authority for data protection issues (https://www.cpdp.bg/). We would, however, appreciate the chance to deal with your concerns before you approach them so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 26 February 2019.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender].
  • Contact Data includes [billing address, delivery address, email address and telephone numbers].
  • Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website].
  • Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
  • Usage Data includes [information about how you use our website, products and services].
  • Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you.

What type of information is gathered during the recruitment process?

The personal information that we may collect during the recruitment process is only limited to the information you fill in your CV. In general, it may include your name, contact information such as home address, phone number and email address, your degrees and qualifications, any previous employments, and any social media you wish to disclose such as your LinkedIn profile.

During the recruitment process we shall not gather sensitive information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, medical or criminal records or data concerning sexual orientation unless you willingly provide such information to us or you give consent for the processing of such information.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by the form on our website, phone, email or otherwise. This includes personal data you provide when you
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
    • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further
    • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from the following parties:
      • analytics providers such as Google based outside the EU;
      • advertising networks such as the following online company profiles (Directories): Crunchbase, Capterra Business Software, IoT Global Network, Datafox, PitchBook, Glassdoor, Endole Suite, Eurojobs, Zoonimfo, GSMA Marketplace based outside the EU; and
      • search information providers such as Google, Bing or Yahoo based outside the EU.
    • Identity and Contact Data from publicly availably sources, such as Companies House and the Electoral Register based inside the EU.

     

    4. How we use your personal data

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal or regulatory obligation.

    Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or other means. You have the right to withdraw consent to marketing at any time by contacting us.

    Purposes for which we will use your personal data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Performance of a contract with you

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer a. Identity

 

b. Contact

To manage our relationship with you which will include:

 

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

a. Identity

 

b. Contact

c. Profile

d. Marketing and Communications

(a) Performance of a contract with you

 

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey a. Identity

 

b. Contact

c. Profile

d. Usage

e. Marketing and Communications

(a) Performance of a contract with you

 

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) a. Identity

 

b. Contact

c. Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

 

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you a. Identity

 

b. Contact

c. Profile

d. Usage

e. Marketing and Communications

f. Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences a. Technical

 

b. Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you a. Identity

 

b. Contact

c. Technical

d. Usage

e. Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products or services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Methodia group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see below:

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Methodia Group.
  • External Third Parties as set out in our CRM tool and service suppliers. We use MailChimp as our marketing platform and some of the information you provide will be transferred to MailChimp for processing in accordance with their privacy policy and terms. For more information on how they collect and use information on our behalf, please refer to their privacy policies: https://mailchimp.com/legal/privacy/.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6. International transfers

We share your personal data within the Methodia Group. This may involve transferring your data outside the European Economic Area (EEA).

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for business purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Cookies Policy

What are cookies?

Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a site and allow a site to recognize your device.

Why do we use cookies?

Cookies do a lot of different jobs, such as letting you navigate between pages efficiently, remembering your preferences and generally improving the user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.

Do we use cookies for marketing and analytics?

Yes, we may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile, and for the other purposes described below, to the extent legally permissible in certain jurisdictions.

Some of the cookies we use don’t collect information that identifies a visitor. For instance:

  • Performance cookies (see below)
  • Targeting cookies (see below) where you are not a registered user

In other cases we can associate cookie information (including information from cookies placed via our advertisements on third party sites) with an identifiable individual. For example:

  • In case we send you a targeted email which includes web beacons, cookies or similar technologies we will know whether you open, read, or delete the message.
  • If you click a link in a marketing e-mail you receive from Methodia, we will also use a cookie to log what pages you view and what content you download from our website.
  • Combining and analyzing personal data– As described above, we may combine data from publicly available sources, and from our different e-mail, website, and other interactions with you to better assess your experience with

Cookies from third party companies

Some cookies we use are from third party companies, such as Google Analytics and Hubspot, provide us with web analytics and intelligence about our sites. These companies use programming code to collect information about your interaction with our sites, such as the pages you visit, the links you click on and how long you are on our sites. This code is only active while you are on Methodia’s website. For more information on how these companies collect and use information on our behalf, please refer to their privacy policies: Google at Google Privacy & Terms, Hubspot at Hubspot Privacy Policy

What if I don’t want cookies?

By using our site you agree that we can place cookies on your device If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this. Currently, “Do Not Track” initiatives are not recognized by our site.

Please bear in mind that deleting and blocking cookies will have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

Types of cookies and which ones does our site use?

A list of all the cookies used on Methodia’s site is set out below by category. Within these four categories, cookies are classified as either session or persistent cookies.

“Session” cookies are temporary and once you close the browser window, they are deleted from your device.

“Persistent” cookies remain on your device for a longer period and are used by the website to recognize your device when you return.

Methodia uses both session and persistent cookies.

Category Examples
Performance cookies – These cookies collect information about your visit and use of this website, for instance which pages you visit the most often, and if you get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how this website works. We categorize the following as Performance cookies:

 

· Referrer URL (internal page) – Used to store the URL of the previous page visited. Allows us to track how visitors navigate throughout our site.

· Referrer URL (external page, including if you click on links on Methodia social media pages) – Used to store the URL which refers a visitor to our site so we may understand which URLs are referring visitors to our site.

· URL history – Used to store the pages visited by a user.

· Session Management cookies – These cookies allow us to follow the actions of a user on our sites during a browser session. A browser session starts when a user opens the browser window, visits our sites and finishes when they leave our sites and close their browser window. Our Session Management cookies are created temporarily. Once you close your browser, our Session Management cookies are deleted.

Targeting cookies – These cookies are used to (1) deliver advertisements more relevant to you and your interests; (2) limit the number of times you see an advertisement; (3) help measure the effectiveness of the advertising campaign; and (4) understand people’s behavior after they view an advertisement. They are usually placed on behalf of advertising networks with the site operator’s permission. They remember that you have visited a site and quite often they will be linked to site functionality provided by the other organization. Methodia does not use third-party advertising on our site, so we do not use these Targeting cookies for advertising but we use them for gathering analytics and intelligence about the site.

 

We categorize the following as Targeting Cookies:

· Gathering analytics and intelligence cookies

· Third Party cookies. The Targeting cookies may also be used on third party websites and third parties may use them on our websites as follows:

-Social media sites – Third-party social media sites may log information about you. This may include activities such as when you click an “Add This” or “Like” button for a social media site while on our site. We do not control such sites or their activities. You may be able to find information about social media sites on the sites themselves. We recommend you read the terms of use and privacy policy of such sites before using them.

-Methodia advertisements on non-Methodia sites – Cookies may be placed on non-Methodia sites so that when you click on our advertisement located on these sites, Methodia is provided with this information to enable us to measure the effectiveness of our advertising

If you have any questions now or during your visit, please submit your request through our Contact form.