Privacy policy

Please read our Privacy Policy carefully as it describes our collection, use, disclosure, retention and protection of your personal information. This Policy applies to any website or service which references this Privacy Policy. Where you provide us with your personal information in any of the ways described in section 2 below, you agree that we may collect, store and use it (a) in order to perform our contractual obligations to you, (b) based on our legitimate interest for processing (i.e. for internal administrative purposes or for the detection or prevention of crime) or (c) based on your consent, which you may withdraw at any time, as described in this Privacy Policy.

1. Who we are

Our Privacy Policy applies to all products and services offered by Titan Gate AD (a company incorporated in Bulgaria with VAT number BG204039974 and whose registered office address is ZPZ, Administrativna sgrada Pivovaren zavod, et.3, Varna 9000, Bulgaria), but excludes any products or services that have separate privacy policies which do not incorporate this Privacy Policy.

2. How we collect information

To the extent permissible under applicable law, we collect information about you and any other party whose details you provide to us when you:

• complete online forms, take part in surveys, enter any competitions or prize draws, download information such as white papers or other publications or participate in any other interactive areas that appear on our website;
• interact with us using social media;
• provide your contact details to us when accessing any websites or services we make available or when you update those details; and
• contact us offline, for example by telephone, email or post.

We also collect information from your devices (including mobile devices) and browsers you use to access and use any of our websites or services (for example, we may collect location information and connection information such as statistics on your page views, traffic to and from the sites, referral URL, and your IP address) and we will ask for your permission before we do so.

If you intend on giving us personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws. In so far as required by applicable data protection laws, you must ensure that beforehand you have their explicit consent to do so and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Policy.

3. How we use your information

To the extent permissible under applicable law, we use your information to:

• provide any information and services that you have requested;
• compare information for accuracy and verify it with third parties;
• manage our relationship with you (for example, customer services and support activities);
• monitor, measure, improve and protect our content, website, and services and provide an enhanced, personal, user experience for you;
• provide you with any information that we are required to send you to comply with our regulatory or legal obligations;
• detect, prevent, investigate or remediate, crime, illegal or prohibited activities or to otherwise protect our legal rights (including liaison with regulators and law enforcement agencies for these purposes);

We may monitor and record our communications with you, including e-mails and phone conversations. Information which we collect may then be used for training purposes, quality assurance, to record details about our website and services you order from us or ask us about, and in order to meet our legal and regulatory obligations generally.

4. Sharing your information

We may share your information with:

• customer relationship management software to provide you with any information, products or services that you have requested;
• our service providers and agents (including their subcontractors) or third parties which process information on our behalf (e.g. internet service and platform providers, advertising agencies, agency trading desks, supply side platforms and data management platforms) so that they may help us to provide you with the products, services and information you have requested or which we believe is of interest to you;
• third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);
• law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
• any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
• any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;

We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.

5. Marketing

From time to time, we may use your information to contact you with details about our services which we feel may be of interest to you. You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights you can do so by selecting your contact preferences at the point where you provide us with your information on our websites by sending us an email to privacy@titangate.com.

6. Your information and your rights

If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:

• the right to be told how we use your information and obtain access to your information;
• the right to have your information rectified or erased or place restrictions on processing your information;
• where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• the right to object to any decisions based on the automated processing of your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in Bulgaria, the Commission for Personal Data Protection).

If we hold any information about you which is incorrect or if there are any changes to your details, please let us know, so that we can keep our records accurate and up to date.

If you withdraw your consent to the use of your personal information for the purposes set out in our Privacy Policy, we may not be able to provide you with access to all or parts of our website and services.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with our data retention, marking and destruction policy or as otherwise permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

7. Changes to our privacy policy

We may change our Privacy Policy from time to time. However we will not reduce your rights under this Privacy Policy. We will always update this Privacy Policy on our website, so please try to read it when you visit the website (the ‘last updated’ reference tells you when we last updated our Privacy Policy).

8. Transfers outside of the European Economic Area

Personal information in the European Union is protected by data protection laws but other countries do not necessarily protect your personal information in the same way. Our website and some of our applications or services or parts of them may also be hosted in the United States or otherwise outside of the EEA (which means all the EU countries plus Norway, Iceland and Liechtenstein) (“EEA”) and this means that we may transfer any information which is submitted by you through the website or the application or service outside the EEA to the United States or to other territories outside of the EEA. When you send an email to us, this will also be stored on email servers which are hosted with Google and therefore may be outside of the EEA.

We take steps to ensure that where your information is transferred outside of the EEA by our service providers and hosting providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. In each case, such transfers are made in accordance with the requirements of Regulations (EU) 2016/679 (the General Data Protection Regulations or “GDPR”) and may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.

By using our website, products or services or by interacting with us in the ways described in this Privacy Policy, you consent to the transfer of your information outside the EEA in the circumstances set out in this Privacy Policy. If you do not want your information to be transferred outside the EEA you should not use our website, applications or services.

9. Other sites and social media

If you follow a link from our website or service to another site or service, this Policy will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy policies appearing on those sites or services.

Our websites or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. You should be able to manage your privacy settings from within your own third party social media account(s) to manage what personal information you enable us to access from that account.

10. Further information

If you have any queries about how we treat your information, the contents of this Policy, your rights under local law, how to update your records or how to obtain a copy of the information that we hold about you, please write to our Data Protection Officer at privacy@titangate.com