Privacy Policy

Raytron Group Ltd. respects the privacy of its customers and guarantees the maximum protection of their personal data. This Privacy and Personal Data Protection Policy (hereinafter referred to as the "Privacy Policy") has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection.

 This Privacy Policy regulates the processing of personal data of individuals or representatives of legal entities of our customers or potential customers, as well as users of our websites: www.raytron.eu, www.hotellobg.eu и www.smartisimo.eu , referred to as the ("Site"), in relation to the services provided by Raytron Group, including those provided by, through and available on the Site

This Privacy Policy, together with the General Terms of Use of the Site and the Policy on the use of "Cookies" and any other documents that are mentioned on the Site, sets out the rules that Raytron Group will follow when processing personal data that we collect from you either about you or that you provide to us. This Privacy Policy does not affect, limit or waive your rights under the Personal Data Protection Act (“PPA”) or other corresponding legislation..

If you have any questions or comments about this Privacy Policy, please contact us at:  info@raytron.eu

Please read this Policy carefully before using the Site or providing your Personal Data, whether electronically on the Site or on paper, as by providing your Personal Data you agree to its terms. If you do not wish us to process your personal data in the manner described in this Privacy Policy, please do not provide it to us. The provision of personal data by you is voluntary, in view of the use of certain services provided by us and the use of the Site and/or access to it. Please note that in some cases we will not be able to provide you with the service or goods you have requested if you do not provide us with the necessary information. 

 

Raytron Group EOOD ("Raytron Group", "we") is the commercial company registered in the Commercial Register at the Registration Agency with EIK 131186415, which collects, processes and stores your personal data under the terms of this Privacy Policy. Raytron Group is a personal data controller within the meaning of the Personal Data Protection Act (PDPA). You can contact us at any of the following coordinates:

 Office: Sofia, 1527, Hristo Kovachev Street #3

 phones: 02 /492 8885; 0899188819

 e-mail: info@raytron.eu

 1. Raytron Group may process publicly available personal data and/or personal data provided by you. The main types of personal data that are processed are: 

• Personal identification information (including name, social security number, identity document number, residence, citizenship, language of communication and others);
• Information about the field of activity (incl. education, educational institution, workplace, position held and others);
• Contact details (including postal and email addresses, telephone and fax numbers and others);
• Financial information (bank account and others);
• Information about a representative (legal representative or proxy) of a legal entity client;
• Data from the communication between us and you, your habits, preferences, satisfaction with our services (activity when using the services, complaints, requests, etc.);
• Information about visits to the Site and use of the Site, including operations and history of use of the Site;
• The data obtained in the performance of the obligations arising from the normative acts (i.e. data arising from inquiries, regulations, investigative bodies, notary public, tax authorities, court, bailiff);
• The data obtained during the fulfillment of the contractual obligations (including name, social security number, address, telephone and/or e-mail address and others).
• Data when creating a profile on the Site (Name, email address, phone, address). 
  

2. Raytron Group may process data prepared and generated by Raytron in the process of providing the services: 

• Data about the end electronic communication device used, device type, operating system used, IP address, location;
• Data about your preferred goods and services. 
  

3. In order to ensure the good performance of services and the obligations arising from customer contracts, Raytron has the right to process any information that is available in public registers (including public databases and data published on the Internet) as well as information received from third parties. on the occasion of the implementation of legal regulations, regarding customers. 

4. Raytron Group has the right and obligation to verify the accuracy of the personal data recorded in the database, and for this purpose requires you to verify the data and, if necessary, correct it or confirm the accuracy of your data.

5. Different types of personal data can be processed independently or in combination with each other. 

1.   Processing of personal data that is necessary for the conclusion or performance of contracts with us or in connection with the preparation for the conclusion of contracts with u.

Raytron Group processes your data for the following purposes: 

• Customer identification when: concluding a new or amending an existing contract with us; explanations about the services used; performance of a concluded contract.
• Preparation of proposals for concluding contracts, sending pre-contractual information and draft contract;
• Data received from you in the performance of obligations arising from contracts concluded with you or a company represented by you, exercise of rights and ensuring the performance of contracts by our customers;
• Handling and responding to customer complaints/queries/complaints/complaints;
• Technical assistance for creating an account/s and recovering a forgotten password for access to our Site, for electronic service of electronic invoices.
• Technical support and troubleshooting and any technical problems - on-site and through remote access to your equipment.
• Payment of obligations, rescheduling of amounts due;
• Warranty and service. 
  

2. In fulfillment of legal obligations, Raytron Group processes your data for the following purposes:

• Invoices issuing;
• To carry out tax-insurance control by the relevant competent authorities;
• Obligations provided for in the Accounting Act and the Tax and Insurance Procedural Code and other related legal acts, in connection with keeping correct and lawful accounting. 
  

3. Raytron Group processes the relevant data provided with the express written consent of the client for their processing for the following purposes: 

• Data when creating a profile on the Site;
• For direct marketing of products and services;
• Electronic newsletter;
• Data provided by you when participating in raffles, surveys, games, etc. 
  

4. The processing is necessary for the purposes of Raytron Group's legitimate interests. 

• Evaluating and ascertaining user satisfaction as well as advertising effectiveness;
• Analysis of data on purchase history, preferences and customer behavior.  

1. Transport/courier companies, postal operators with a view to fulfilling our contractual obligations, sending correspondence and communications, in connection with the contract between us;
2. Persons who, on behalf of Raytron Group, maintain equipment and software used to process your personal data;
3. Debt collection service providers, notary, solicitor, bailiff or other third party if the customer has breached an obligation arising from a contract with us;
4. The banks servicing the payments made by you;
5. Persons to whom Raytron Group has outsourced the performance of part of the activities or obligations related to a specific service that we owe to you;
6. Persons performing consulting services in various fields - lawyers, accountants, etc.;
7. Authorities, institutions and persons to whom we are obliged to provide personal data under the current legislation.   

The duration of storage of your personal data depends on the processing purposes for which they were collected:

 1. The personal data processed for the purpose of concluding/amending and executing contracts between Raytron Group and you or a company represented by you - for the duration of the contract and until the final settlement of all financial relations between the parties. Raytron may store some of your personal data for a longer period until the relevant statute of limitations expires in order to protect against possible customer claims in connection with the performance/termination of contracts with us, as well as for a longer period in the event of legal dispute that has already arisen until its final resolution with an effective court/arbitration decision. 

2.  Personal data processed for the purpose of issuing accounting/financial documents for the implementation of tax-insurance control, such as but not limited to invoices, debit, credit notices, handover protocols, contracts for the provision of services/goods are stored for at least 11 years after expiration of the limitation period for repayment of the public claim, unless the applicable legislation provides for a longer period. 

3. Personal data processed for the purpose of direct marketing - until the express withdrawal of the given consent for direct marketing or receiving an objection to the processing of personal data for direct marketing. 

4. Personal data when creating a profile on the Site - until the express withdrawal of the given consent or receiving an objection to the processing of personal data from the profile on the Site. 

5. Photo and/or video data provided by you when participating in raffles, surveys, games, etc. - until the express withdrawal of the given consent or receipt of an objection to the processing of personal data.   

1.General rights 

In relation to the processing of personal data, you have the following rights, which you may exercise at any time while we store or process your personal data, by sending a request to Raytron Group's address indicated above or electronically to email: info@raytron.eu 

• A copy of your personal data and access to it at any time;
• To correct, without undue delay, your inaccurate personal data, as well as data that is no longer current;
• Your personal data in a form convenient for transfer to another personal data controller, or to request that we do so without being hindered by us (right to portability);
• Your personal data to be deleted without undue delay where there is any legal basis for doing so;
• To limit the processing of your personal data, in which case your data will only be stored, but not processed. Our refusal to limit will be expressly only in writing, and we are obliged to motivate it with the lawful reason. 
  

You have a right too: 

• To withdraw your consent to the processing of your personal data at any time with a separate request addressed to Raytron Group, when processing is based on consent;
• To object to the processing of your personal data;
• To object to automated processing, including profiling;
• Not to be subject to a decision based solely on automated processing involving profiling. 
  

2. You have the right to appeal to the supervisory authority 

You have the right to file a complaint directly with the supervisory authority, the competent authority being the Commission for the Protection of Personal Data, address: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2 (www.cpdp.bg). 

In the event that you wish to lodge a complaint regarding Raytron Group's processing of your personal data, you may do so at the specified contact details of the Administrator (at the above contact details). 

3. Automated decision making

The administrator does not use your personal data for automated decision-making. In the event that we intend to use your personal data for automated decision-making, you have the right to be informed and therefore, as well as to receive information about the logic of any automated processing of personal data concerning you. 

4. Objection to use for direct marketing
You have the right to object to the future processing of your personal data for the purposes of direct marketing and advertising, as well as to their disclosure to third parties and their use on their behalf for the purposes of direct marketing and advertising, by withdrawing your consent under anytime. For this purpose, you can send an electronic message with the corresponding request to stop using your data for direct marketing purposes atс: info@raytron.eu 

5. Can you refuse to provide personal data to Raytron Group and what are the consequences?
ЗIn order to enter into a contract with you and/or to provide you with the requested products and/or services and/or to deliver the ordered goods in accordance with our legal and subsequently contractual obligations, Raytron needs certain data that identifies the party to the contract , her proxy, contact details, details of payment of obligations. Failure to provide such data prevents us from entering into a contract with you.  

Raytron Group implements organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and the monitoring of the processing of personal data. Among other things, such security measures include the following activities: 

• Raytron Group has established rules for processing, registration and storage of personal data with internal procedures, compliance with which is constantly monitored;
• Raytron Group employees' access to personal data and permission to process personal data in the Raytron Group database is limited, depending on their duties;
• Access to Raytron Group office equipment and each employee's computers is restricted and is subject to identification;
• We apply all the necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as the best practices of international standards;
• In order to ensure maximum security when processing, transferring and storing your data, we may use additional protection mechanisms such as encryption, anonymization, etc.. 
  

The security measures we apply are subject to constant improvement and adaptation to the latest technologies. 

Sometimes the Site may contain links/references (hyperlinks) to other sites. We do not operate the linked sites and do not endorse the content, services or products of those sites. We advise you to use the linked sites carefully and with due regard to their content and terms of use. Raytron Group is not responsible for the privacy policy or content of these sites and we advise you to review their privacy policies. However, as soon as Raytron Group receives information about illegal activities or illegal information on such Internet pages, we will take immediate measures to remove electronic references (links) to them..  

  To familiarize yourself with the Cookie Policy, please visit the page Cookie Policy 

  We do not knowingly collect personal information from children under the age of 16. If we learn that we have collected personal information from a child under the age of 16, we will take steps to delete the information as soon as possible or obtain the consent of the person with parental responsibility for the child.