Voden Horizont OOD (hereinafter “Voden Horizont“ or “We“ or “Us”) is delighted about your visit to our internet pages and mobile applications (together also referred to as “Online Offers”). We thank you for your interest in our company and our products.
1. Voden Horizont respects your privacy
The protection of your privacy throughout the course of processing personal data as well as the security of all business data is an important concern to us. We process personal data that was gathered during your visit of our Online Offers confidentially and only in accordance with statutory regulations.
Data protection and information security are included in our corporate policy.
2. Data Controller
Voden Horizont OOD is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
Water Horizon Ltd.
Sofia, Mladost 1A, 23 Alexander Malinov Blvd., City Point Center building, 2nd floor, office 71
1729 Sofia
Email: [email protected]
Phone: 00359 894 774 910
3. Collection, processing and usage of personal data
3.1. Processed data categories:
- Communication data (e.g. name, telephone number, e-mail address, address, IP address) are processed.
3.2. Principles
Personal data consists of all information related to an identified or identifiable natural person, this includes, e.g. names, addresses, phone numbers, email addresses, contractual master data, contract accounting and payment data, which is an expression of a person’s identity.
We collect, process and use personal data (including IP addresses) only when there is either a statutory legal basis to do so or if you have given your consent to the processing or use of personal data concerning this matter, e.g. by means of registration.
3.3. Processing purposes and legal bases
We as well as the service providers commissioned by us, process your personal data for the following processing purposes:
- Provision of this online offer
Legal basis: Justified interest in direct marketing on our part, as long as this is carried out in compliance with data protection regulations and competition law regulations - In reply to user inquiries in the framework of a contact form
Legal basis: Justified interest in direct marketing on our part and in the enhancement of our products and services, as long as this is carried out in compliance with data protection regulations and competition law regulations resp. contractual performance resp. consent - Legal basis: Justified interest in direct marketing on our part and in the enhancement of our products and services, as long as this is carried out in compliance with data protection regulations and competition law regulations resp. contractual performance resp. consent
- Determination of malfunctions and for safety reasons
Legal basis: Fulfilment of our legal obligations in the field of data security and predominantly, justified interest in the rectification of malfunctions and the security of our offers. - Our own and third party advertising as well as market research and reach measurement in accordance with the legally permissible extent resp. consent-based
Legal basis: Consent or predominantly, justified interest in direct marketing on our part, as long as this is carried out in compliance with data protection regulations and competition law regulations. - Safeguarding and defending our rights
Legal basis: Justified interest on our part in the assertion and defense of our rights. - Sale of an ordered product or service
Legal basis: Consent expressed
3.4. Log files
Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.
We store log files to determine service disruptions and for security reasons (e.g., to investigate attack attempts) for a short period of time and delete them afterwards. Log files which need to be maintained for evidence purposes are excluded from deletion until the respective incident is resolved and may, on a case-by-case basis, be passed on to investigating authorities.
Log files are also used for analytical purposes (without or without the complete IP address) under the prerequisites of section 3.3. point 4 for our own and third party advertising as well as market research and reach measurement in accordance with the legally permissible extent resp. consent-based.
The following information, in particular, is stored in the log files:
- IP address (Internet protocol address) of the end device from which the online offer is accessed;
- Internet address of the website from where the online offer has been accessed (so-called origin or referrer URL);
- Name of the service provider through which access to the online offer is achieved;
- Name of the retrieved files or information;
- Date and time as well as duration of the access;
- Transferred data volume;
- Operating system and information on the Internet browser used, including add-ons (e.g. for the flash player);
- http status code (e.g. “Inquiry successful” or “Requested file not found”).
4. Transfer of data
4.1. Data transfer to other controllers
Principally, your personal data is forwarded to other controllers only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal basis and the recipients or categories of recipients can be found in the section “Processing purposes and legal bases” (see no. 3.3.).
Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.
4.1.1. Transfer of data to service providers
We involve external service providers with tasks such as sales and marketing services, contract management, payment handling, programming, data hosting and hotline services. We have chosen those service providers carefully and monitor them on a regular basis, especially regarding their diligent handling of and protection of the data that they store. All service providers are obliged to maintain confidentiality and to comply with the statutory provisions.
4.2. Duration of storage; retention periods
Principally, we store your data for as long as it is necessary to render our Online Offers and connected services or for as long as we have a legitimate interest in storing the data (e.g. we might still have a legitimate interest in postal mail marketing after fulfillment of our contractual obligations). In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g. due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).
5. Usage of cookies
In the context of our online service, cookies and tracking mechanisms may be used. Cookies are small text files that may be stored on your device when visiting our online service. Tracking is possible using different technologies. In particular, we process information using pixel technology and/or during log file analysis.
5.1. Categories
We distinguish between cookies that are mandatorily required for the technical functions of the online service and such cookies and tracking mechanisms that are not mandatorily required for the technical function of the online service.
It is generally possible to use the online service without any cookies that serve non-technical purposes.
5.1.1. Technically required cookies
By technically required cookies we mean cookies without those the technical provision of the online service cannot be ensured. These include e.g. cookies that store data to ensure smooth reproduction of video or audio footage.
Such cookies will be deleted when you leave the website.
5.1.2. Cookies and tracking mechanisms that are technically not required
We only use cookies and tracking mechanisms if you have given us your prior consent in each case. With the exception of the cookie that saves the current status of your privacy settings (selection cookie). This cookie is set based on legitimate interest.
We distinguish between two sub-categories with regard to these cookies and tracking mechanisms:
5.2. Comfort cookies
These cookies facilitate operation and thus allow you to browse our online service more comfortably; e.g. your language settings may be included in these cookies.
5.3. Marketing cookies and tracking mechanisms
General
By using marketing cookies and tracking mechanisms we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behaviour:
- Statistics: By using statistical tools, we measure e.g. the number of your page views.
- Conversion tracking: Our conversion tracking partners place a cookie on your computer (“conversion cookie”) if you accessed our website via an advertisement of the respective partner. Normally these cookies are no longer valid after 30 days. If you visit certain pages of our website and the cookie has not yet expired, we and the relevant conversion partner can recognize that a certain user clicked on the advertisement and thereby was redirected to our website. The information obtained by means of the conversion cookie serves the purpose of compiling conversion statistics and recording the total number of users who clicked on the respective advertisement and were redirected to a website with a conversion tracking tag.
- Social plugins: Some of the pages of our online service involve content and services of other providers (e.g. Facebook, Twitter) which also may use cookies and active modules. For more details regarding social plugins please refer to the section on “social plugins” (see no. 7).
- Retargeting: These tools create user profiles by means of advertising cookies or third-party advertising cookies so called “web beacons” (invisible graphics that are also called pixels or tracking pixels), or by means of comparable technologies. These are used for interest based advertising and to control the frequency with which the user looks at certain advertisements. The relevant provider is the controller responsible for the processing of data in connection with the tool. The providers of the tools might disclose information also to third parties for the purposes mentioned above. Please note the data protection notices of the relevant provider in this context.
5.4. Management of cookies and tracking mechanisms
You can manage your cookie and tracking mechanism settings in the browser and/or our privacy settings.
Note: The settings you have made refer only to the browser used in each case.
5.4.1. Deactivation of all cookies
If you wish to deactivate all cookies, please deactivate cookies in your browser settings. Please note that this may affect the functionality of the website
5.4.2. Management of your settings with regard to cookies and tracking mechanisms not required technically
When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any marketing cookies or tracking mechanisms, respectively.
In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.
6. Google
6.1. Google Maps
This page uses the map service Google Maps via an API. The provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
For the use of the functions of Google Maps it is necessary to store your IP address. This information is usually transmitted to a server of Google in the USA and saved there. The provider of this page does not have any influence on this transmission of data.
The use of Google Maps is in the interest of an appealing presentation of our online offers and an easy retrievability of the places listed by us on the website. This represents a predominant legitimate interest on our part within the meaning of article 6 section 1 lit. f GDPR.
Please see the privacy notice of Google for more information on the handling of user data: https://www.google.de/intl/en/policies/privacy/.
6.2. Google web fonts
This site uses so-called web fonts of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for the uniform display of fonts. When you access a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly.
For this purpose, the browser you are using has to connect to the servers of Google. This informs Google that our website was accessed via your IP address. The use of Google web fonts is in the interest of a uniform and appealing presentation of our online offers. This represents a predominant legitimate interest on our part within the meaning of article 6 section 1 lit. f GDPR.
Your computer will use a standard font if your browser does not support web fonts.
For more information about Google web fonts please see https://developers.google.com/fonts/faq and the privacy notice of Google: https://www.google.de/intl/en/policies/privacy/.
7. Social plugins
In our online offer, we use so-called social plugins of different social networks; these will be described individually in this section.
When using plugins, your internet browser creates a direct connection to the respective social networks’ server. Hereby the respective provider receives the information that your internet browser accessed from the respective site of our Online Offers – even if you do not have a user account with this provider or are currently not logged into your account. Log files (including the IP address) are, in this case, directly transmitted from your internet browser to a server of the respective provider and might be stored there. The provider or its server may be located outside the EU or the EEA (e.g. in the United States).
The plugins are standalone extensions by social network providers. For this reason, we are unable to influence the scope of data collected and stored by them.
Purpose and scope of the col-lection, the continued processing and usage of data by the social network as well as your respective rights and setting options to protect your privacy can be found by consulting the respective social network’s data protection notices.
In case you do not wish social network providers to receive and, if applicable, store or use data, you should not use the respective plugins.
7.1. Social plugins with 2-click solution
With a so-called 2-click solution, we protect you from having your visits to our websites recorded and evaluated by social network providers as standard. When you access a page of our internet offer, which contains such plugins, these are initially deactivated. The plugins are not activated until you click the provided button.
7.2. Social plugins of Facebook
Facebook is provided under www.facebook.com by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). You will find an overview of the plugins from Facebook and their appearance here: https://developers.facebook.com/docs/plugins/?locale=en_EN; you will find information on data protection at Facebook here: http://www.facebook.com/policy.
8. YouTube
Our Online Offers use the Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland („YouTube”). YouTube is a platform which allows the playback of audio and video files.
When you access a respective site of our Online Offers that contains an embedded YouTube player, this creates a connection to YouTube so that the video or audio file can be transmitted and played back. In doing so, data is transferred to YouTube as a data controller. We are not responsible for the processing of such data by YouTube.
Additional information on the scope and purpose of collected data, on further processing and usage of data by YouTube, on your rights and the privacy options available to be chosen by you, can be found in YouTube’s data protection notice.
9. External links
Our Online Offers may contain links to internet pages of third parties, in particular providers who are not related to us. Upon clicking on the link, we have no influence on the collecting, processing and use of personal data possibly transmitted by clicking on the link to the third party (such as the IP address or the URL of the site on which the link is located) as the conduct of third parties is naturally beyond our control. We do not assume responsibility for the processing of personal data by third parties.
10. Security
Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws.
We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change or unauthorized disclosure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.
11. User rights
To enforce your rights, please use the details provided in the “Contact” section (see no. 14). In doing so, please ensure that an unambiguous identification of your person is possible.
11.1. Right to information and disclosure
You have the right to obtain information from us concerning the processing of your data. For this purpose, you can enforce a right to information in relation to the personal information that we process from you.
11.2. Right of rectification and deletion
You can demand from us the rectification of false data and – insofar as the legal prerequisites are fulfilled – the completion or deletion of your data.
This does not apply to data which are necessary for invoicing or accounting purposes or are subject to the statutory retention obligation. Insofar as the access to such data is not required, the processing thereof will be restricted (see below).
11.3. Restriction of processing
You can demand from us the restriction of the processing of your data insofar as the legal prerequisites are fulfilled.
11.4. Data portability
As far as statutory requirements are fulfilled you may request to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible – that we transfer those data to a third party.
11.5. Right of objection
11.5.1. Objection to data processing based on the legal basis of “legitimate interest”
In addition, you have the right to object to the processing of your personal data at any time, insofar as this is based on “legitimate interest”. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.
11.5.2. Objection to direct marketing
Additionally, you may object to the processing of your personal data for direct marketing purposes at any time. Please take into account that due to organizational reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.
11.6. Withdrawal of consent
In case you consented to the processing of your data, you have the right to revoke this consent at any time with effect for the future. The lawfulness of data processing prior to your withdrawal remains unchanged.
11.7. Right to appeal to the supervisory authority
You have the right to submit an appeal to a data protection supervisory authority. For this purpose, you can refer to the data protection supervisory authority, which is competent for our group or to the data protection supervisory authority which is competent for your place of residence. This is:
Commission for Personal Data Protection
Address: 2 Prof. Tsvetan Lazarov Bvd, 1592 Sofia
Email: [email protected]
12. Children
This online offer is not directed at children under an age of 16 years.
13. Change of the data protection notice
We reserve the right to make modifications to our security and data protection measures, insofar as this is necessary due to the technical development. In these cases, we will also adapt our data protection notice accordingly. Therefore, please note the currently valid version of our data protection notice.
14. Contact
If you wish to contact us, please find us at the address stated in the “Controller” section (see no. 2).
To assert your rights please write to:
To notify data protection incidents please please write to:
For suggestions and complaints regarding the processing of your personal data we recommend that you send an email to:
Effective date: 01.01.2020
