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Privacy Policy

Start Date January 1st, 2023

HealthySwim is the trade name of “Tengo” LTD, Tax ID Number 200235662, a company having its head office and registered office address in the city of Plovdiv, “Markovo” Logistics Park, Plovdiv Ring Road. This Privacy Policy of “Tengo” LTD, Tax ID Number 200235662 (hereinafter referred to as “HealthySwim“, “we” or “us”, and our website at https://www.healthyswim.bg will be hereinafter referred to as the “Website”) describes our practices for online collection and use of information, including the choice you can make about how we use such information.

 

  1. Introduction

This Privacy Policy is subject to the provisions of the General Data Protection Regulation (“GDPR”) and other applicable privacy laws. Our role is that of the “Data Controller” and you are the “Data Subject” entitled to certain privacy rights with respect to your “Personal Data“. We believe that the protection of your data and its confidentiality is of the utmost importance. All personal data processing operations comply with the EU General Data Protection Regulation (“GDPR”) (particularly but not limited to Article 6, paragraph 1, and Article 28).

We do not sell your data to third parties.

For the purposes of this Privacy Policy:

Personal data means any information relating to an identified or identifiable natural person.

Natural person that is identifiable is a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (“Personal Data”).

Potential Customer: A natural person that is or may be interested in our services or products.

Customer: A natural person that has hired us to provide one or more services or products.

Usage data means data such as but not limited to your software and browsing settings, type of browsing device, actions undertaken, order of pages viewed; time spent on the website.

Cookies: A cookie is a small file type aimed at processing/recording information about the way you can interact or have interacted with the website.

Legal grounds for personal data processing:

Your consent granted by you as a website visitor, in response to a question or request, Regulation (EU) 2016/679 – GDPR, Article 6

Marketing and public relations based on your consent, according to Regulation (EU) 2016/679 – GDPR, Article 6, 1 A

Legitimate interest

We rely on our legitimate interest as one of the lawful grounds for processing, as we have fully considered and protected the rights and interests of the person whose data is processed by us.

Responsibility for personal data processing

We are responsible for the lawful processing of your data on our website.

 

  1. What type of personal data is subject to processing and for what purpose?

1.1. Data related to the use of the website

When you visit our website, we store the name of your Internet service provider, the website from which you visited us, the part(s) of our website visited by you, the date and duration of your visit, as well as device information (device type, operating system, screen resolution, language, country you are located in, and web browser type) used by you during your visit.

We only record and store a shortened version of your IP address. It is captured and stored in an anonymised format by suppressing the last octet, so your full IP address never reaches our servers and we never have access to it.

We process this usage data to make it easier for you to access our services (e.g. to adjust our services/website to the device you are using) and to recognise and stop any misuse. We also process usage data in an anonymised format for statistical purposes and to improve the usability of our website.

1.2. On our website, you have the opportunity to contact us to ask questions, request brochures or appointments via email (info@healthyswim.bg), or via the contact form. In this form, we ask for your contact details (e.g. name, email address, telephone number, etc.) or information relating to the pool project you are contacting us about. We use these pieces of information solely in order to respond to your inquiries and to facilitate our future interaction regarding your project. We do not sell or transfer this data to any third parties for marketing purposes.

However, there may be cases in which we may need to interact or work with a supplier on your behalf or at your request. Under these circumstances, we may need to exchange project information necessary to perform our work.

If you receive emails from us, we may use certain analytics tools to capture data, such as when you open our email, or click on links or banners contained in our email. This data helps us evaluate the effectiveness of our communication or our marketing campaigns.

Access by and disclosure to third parties:

We use a selected number of trusted external service providers for certain offers for technical analysis, data processing and/or storage.

These service providers have been carefully selected and meet high standards for data protection and security. We share with them only the information which is necessary for the services rendered by them to us, and we contractually obligate them to maintain the confidentiality of any information we share with them and to process personal data only in accordance with our instructions.

Requested information:

We may ask for specific personal information about you on different pages of the website in order to sell products and services, add you to our email list or fulfil your requests for information. In our consumer newsletter, we may ask you for personal information (such as your name, address, phone number, email address, etc.). You may choose not to provide your personal information, but then you may not be able to take advantage of some of the features of our website. We only collect basic personal data about you, which does not include any sensitive information. The personal data types collected and stored by us may include:

Contact information such as name, email address, physical address, phone number

Information provided by you, such as feedback, comments or other messages;

Technical information collected in our logs (including standard web log entries that contain your IP address, page URL, and a time stamp).

Device-identifying information related with the browser or device used by you for access to the website or content, such as your unique device identifier and associated device type, operating system, most frequently visited pages or features, messages sent through the Website or Content, way of usage of pages or features of the Content, and other similar analytics about your use of the Website or Content.

Summarized information. We may also collect anonymous, non-identifying and aggregated information, such as type of browser used by you, type of device, your operating system, domain name of your Internet service provider, and information about your location.

 

  1. Who collects your information on our website?

We collect information from you on the website and we are responsible for protecting such information. We collect user information from the “Contact Us” form on our website and inquiries made through our call centre.

 

  1. Purposes and grounds for processing personal data

We need to collect your personal data in order to respond to your requests for information or to be added to newsletter lists, to process your requests to purchase and pay for our Products, and to process your requests for information as a consumer, potential merchant or other business partner. We send newsletters to persons included in our email list. We may also send other communications such as promotions, discounts and event announcements via email and SMS. We also collect aggregate information so that we can improve and enhance the website design and Content. We collect log information for monitoring purposes to diagnose potential problems with our servers, administer the website, calculate usage levels, and render other services to you.

 

  1. How do we use the information collected by us?

We use the personal data provided by you for the purposes for which you have provided it, namely:

Responding to your inquiries and fulfilling your requests for information.

Communicating with you about our products. We may use your personal data to send you information about new products, sales and events that may be of interest to you.

We may use the anonymous information we collect to improve the design and content of our website, and to enable us to customize your Internet experience. We may also use such information in an aggregate form to analyse the way of using our website, to analyse industry trends, and to offer programs or services to you.

 

  1. Do we disclose your personal data?

In summary of the above, we will not disclose your personal data, except: (a) for the purposes for which you provided it; (b) with your consent; (c) if required by law or as we believe necessary to protect our organization, or others from harm (e.g. in response to a court order or subpoena, in response to a law enforcement agency’s request, or when we believe someone is causing or is about to cause harm to, or interference with the rights, or property of others); or (d) on a confidential basis with persons or organizations with whom we have contracted to perform site-internal, marketing and business operations, or as necessary to provide the website or Content. With your knowledge and consent, we may disclose your personal data to our business partners. We may also disclose aggregated information to third parties, including related and unrelated organizations. We may also transfer your Personal Information to our successor in the event of an acquisition, sale, merger or bankruptcy.

 

  1. Are there any other ways in which your personal data may be disclosed?

You may choose to disclose certain Personal Information with individuals or with the public through your use of the Website. For example, the website may allow you to disclose information on a public level through social media, such as Facebook, Instagram, or LinkedIn. Please, keep in mind that when you choose to disclose information with friends or the general public, you may disclose sensitive information or information that could be inferred to be sensitive. Always be aware when sharing information through the Website. You understand and agree that we bear no responsibility for any consequences whatsoever of you sharing information through and off the Website.

If we intend to use your personal data in a manner other than for the purpose for which it was collected, then we will ask for your consent prior to such use. If we propose to use personal data for purposes other than those described in the present Privacy Policy, we will offer you an effective way to opt out of the use of personal data for these other purposes.

 

  1. How can you access and control your information?

You have the right to be informed about the personal data processed by us, the right to rectification, erasure and restriction of processing. You also have the right to receive from us in a structured, commonly used and machine-readable format the personal data you have provided to us.

In order to exercise any of the rights set out in this Privacy Policy and/or in the event of any questions or comments related to the use of personal data, you may contact us at info@healthyswim.bg.

If you have provided consent, you may withdraw it at any time without affecting the lawfulness of the processing that has taken place before withdrawing it.

Whenever you withdraw your consent, you acknowledge and accept that this may have a negative impact on the quality of the Website and/or our Services. Furthermore, you agree that we shall not be liable in respect of any loss and/or damage to your personal data if you choose to withdraw your consent.

If you wish to be removed from our database, to inform us of a change of address or otherwise, contact us and we will honour your request in accordance with applicable law. To remove your name from our email list, email us at info@healthyswim.bg.

You have the right to lodge a complaint with the Data Protection Supervisory Authority at: kzld@cpdp.bg kzld@cpdp.bg

 

  1. How do we store and protect your information?

Once we receive your personal data, we will store it on our website systems for future use. We have physical, electronic, and managerial procedures to protect and help prevent any unauthorized access, to maintain data security, and to properly use the information we collect.

We restrict the access to Personal Information only to our employees, contractors and agents who need to know that information to operate, develop or improve our products and services. These individuals are bound by a confidentiality obligation and may be subject to disciplinary measures, including dismissal and criminal prosecution upon non-compliance to these obligations.

We keep the personal data for as long as is necessary for its purpose, or for an additional period of time required by the law (if any). We may keep information for a longer period of time for legal reasons (e.g. the personal data may remain in backup copies for a reasonable period of time) or as required by the law. Otherwise, we keep your personal data until you request that we remove it from our servers. We store our logs and other technical records for an indefinite period of time.

 

  1. How do we use cookies and other network technologies?

We use “cookies” to process information, including standard information about Internet logs and details about the behavioural visitor patterns when visiting our website.

This is done in order to give you a better experience and to facilitate the use of certain features. Cookies are small data files transferred by websites to computers or devices for the purpose of storing data and improving website functionality. We store such information in a pseudonymised user profile.

We do not process this information to identify individual users or to match it with other data about an individual user.

Cookies are stored on your individual device and you have full control over their use. You can disable or restrict the transmission of cookies by changing the settings on your web browser. Cookies already stored can be deleted at any time. If you visit our site with cookies disabled, you may not be able to use all of its features to the full extent.

 

  1. Collection of information from others

The website may contain links that direct you to other websites or services having privacy practices that may differ from ours. We encourage you to get acquainted with the differences in their privacy policies.

 

  1. Information about children

We do not knowingly collect any information from minors and comply with all applicable laws for personal data protection. If you have any concerns about this Website or its Content, wish to find out if your child has accessed our Content, or wish to remove your child’s personal information from our servers, please contact us at info@healthyswim.bg. Our website will not knowingly accept personal information from anyone under the age of 13 without the consent of a parent or a guardian. If we find out that a child under the age of 13 has provided us with personal information, we will endeavour to delete the child’s information. If you believe that your child has accessed our Website without your permission, please contact us at info@healthyswim.bg.

 

  1. Changes to this Policy

We may review this Privacy Policy in accordance with changes in the best practices, the Company’s Policy, or in order to comply with new legislation. The most current version of this Privacy Policy will govern our practices for personal data collection, processing and disclosure. We will notify you of any changes by posting a written notice on our Website.

Your use of the Website and/or the Services after the entry into force of the changes to the Privacy Policy will constitute your acceptance of the Privacy Policy as modified.

 

  1. Contact us

If you have any questions about this Privacy Policy, please contact us at info@healthyswim.bg or at: “Tengo” LTD, city of Plovdiv, Plovdiv Ring Road, Markovo Logistics Park.