Policy
to protect customer personal data 
collected by Viewpoint Ltd.
 
   This privacy policy describes the ways in which Viewpoint Ltd. collects, processes, stores and protects personal data of individuals who are customers of the company.
  By using the services of the company, including when you register on our website, you agree to the collection and use of your personal data in accordance with this privacy policy, which meets the requirements of Regulation 2016/679, the Personal Data Protection Law (PDPL) and the by-laws on its implementation, the guidelines and directions of the Commission for Personal Data Protection (PDPA) and the Working Group under Art. 29 of the European Data Protection Board.
   When you register on our website, you consent to the processing of your personal data for the purpose for which you register and for the period specified in item 4 of this Policy.
  Viewpoint Ltd. may without notice amend, supplement, revoke or otherwise update this Privacy Policy, in accordance with the requirements of Regulation 2016/679, the Personal Data Protection Law (PDPL) and the by-laws on its implementation, the guidelines and directions of the Commission for Personal Data Protection (CPDP) and the Working Group under Art. 29 of the European Data Protection Board. We will process your personal information in accordance with this Policy, which is in effect at the time of collection. We will publish the changes in the Policy in due time. The privacy policy is published on our website www.viewpoint.bg and is available wherever personal data is required. Where personal data are collected, additional explanations may be provided, if necessary, about the purposes for which the personal data will be used.

   I. Viewpoint Ltd. collects, processes and stores your personal data when:
       1. we must generate a service order for you - for acceptance or return of equipment for service, invoice, warranty card or other necessary document;
       2. we must send you a product ordered by you or our employee should visit you, for the purposes of the service we provide to you, this personal data is inevitably necessary;
       3. register on our website;
       4. you contact our employees, through public information or through the contact information with us from our website (phone / email) or the Internet space;
       5. fall within the scope of video cameras in or near our offices;
       6. give us your consent and provide your personal data for processing.

   II. Viewpoint Ltd. may process your personal data on the basis of:
       1. a legal obligation for the administrator, such as generating invoices and other accounting documents;
       2. concluding or executing a contract, for example to perform warranty service under a contract with manufacturers;
       3. consent to the processing of personal data if one of the above two grounds is not present, in which case:
         * consent is freely expressed and unconditional, specifically - separate consent for each specific purpose, informed - given on the basis of complete, accurate and easily understandable information, unambiguous and explicitly clearly confirming action;
            * the consent is documented so that it can be used as evidence before the
CPDP and the court;
            * provides a practical opportunity for the data subject to withdraw his consent at any time, as well as to exercise his other rights contained in this Policy and Regulation (EU) 2016/679;
            * if there is a direct offer of information society services to a child under 16 years of age, to certify that the consent has been given or authorized by the person who bears parental responsibility for the child;

    III. Types of personal data of clients processed by Pointpoint Ltd.:
       1. for concluding a contract, issuing an invoice / warranty card - names, address and
UCN;
       2. for service orders - names, phone, e-mail if possible;
       3. when within range of a camcorder - video recordings.

    IV. Terms within which personal data are stored and processed are in compliance with the specific purposes for which they are collected or determined by law:
       1. the criteria for setting deadlines that are not legally regulated depend on the purpose of the data collection and its implementation or the grounds, such as in the case of consent, it can be withdrawn at any time.
       2. according to the legal provisions applicable to our activities, contractual obligations and internal rules, the terms for storage and processing of personal data are:
           * for accounting documents - 10 years;
           * for warranty service orders - until the expiration of the warranty period of the device.
           * for out-of-warranty service orders for which no accounting document has been generated - 1 year, if the consent has not been withdrawn.
           * for videos - 20 to 30 days.
           * for our website in the absence of a valid order - 6 months.
    V. You may access your personal data that we process, object to their processing, request a restriction on the processing, or supplement, correct or delete the data by expressing this wish in writing to the e-mail address: office @ viewpoint.bg or at our address: 1421 Sofia, 81A Arsenalski Blvd.

     VI. Access to personal data of clients may have:

        1. personal data subjects - to their data.
        2. authorized employees of Viewpoint Ltd., who according to their roles and job responsibilities must have access.
        3. processing personal data of clients on behalf of Viewpoint Ltd. subcontractors - an accounting company, a courier company, companies hosting our site and a mail server.
        4. organizations for which the disclosure of personal data is prescribed in a normative act - NSSI, NRA, Ministry of Interior, court, Prosecutor's Office, etc.).
        5. we do not sell or provide personal information in any way to anyone other than those mentioned above.


     VII. You can exercise your legal right to the portability of your personal data by requesting this from us and, if technically possible, we will do so. You have the legal right to receive your personal data, which is processed by us, in a structured, widely used and machine-readable format and you have the right to transfer this data to another administrator, under conditions specified by law.

     VIII. The security measures we apply to protect the personal data of customers are:
        1. strict organizational and technical, in full compliance with the Personal Data Protection Law and Regulation 2016/679.
        2. to ensure the continued confidentiality, integrity, availability and sustainability of processing systems.
        3. for timely recovery of personal data and access to them in case of a physical or technical accident.
        4. regular inspection and evaluation of the effectiveness of the measures, in order to ensure the security of processing.
        5. requirements for full compliance with the Personal Data Protection
Law and Regulation 2016/679 in the selection of our operators to whom we provide personal data for processing.

    IX. Customer rights information
        1. Your personal data will be processed for the period specified by you in the Declaration of Consent for the processing of personal data. Outside this period, your personal data will be stored by us, as an administrator, for the period specified in item 4 of this Policy.
        2. We would like to inform you that as a data subject, according to Article 15 of the Regulation, you have the right to request from us as an administrator access to your personal data. Upon your request for access to your personal data, we will provide you with a copy of all data that we currently process. If you wish to receive additional copies, you may be charged a reasonable administrative fee. Your request for access to your personal data as a customer / user can be made verbally or in writing - by request, as well as by electronic means (email, fax, etc.). In the application, specify the form in which you wish to receive a copy of your personal data. If you have submitted the request by electronic means and have not indicated in what form you wish to receive the copy, you will receive them in a widely used electronic form, namely in one of the following forms: word / pdf / excel file or others.
       3. Under the Regulation, you, as a data subject, have the right to ask us - as an administrator - to correct inaccurate personal data relating to you without undue delay. You have the right to request that incomplete personal data be filled in, including by adding a declaration, taking into account the purposes of the processing.
       4. Pursuant to Art. 17, § 1 of Regulation (EU) 2016/679 you have the right to ask us as an administrator to delete your personal data when any of the grounds mentioned in the same paragraph exist, for example: your personal data are no longer needed for the purposes for which they were collected or processed, you may also withdraw the consent given with the Declaration of Consent, and you may withdraw your consent to the processing of your personal data when we, as the controller, have no legal grounds to continue processing, including when you consider that your personal data has been processed illegally by us. You can request the deletion of your personal data (or the "right to be forgotten") by oral or written request, as well as by electronic means.
       5. You have the right to request a restriction on the processing of your personal data from us - as an administrator on the grounds specified in Art. 18, para. 1 of Regulation (EU) 2016/679 by oral or written request, as well as by electronic means. You will be notified by the administrator before the restriction on the processing of your personal data is lifted.
        6. You have the right to object to the processing of your personal data.
        7. If your personal data is processed on the basis of explicit consent or on the basis of a contractual obligation to process and if at the same time the processing is performed in an automated manner (ie through automated electronic systems and not in a paper archive version) you have the so-called . right to portability of your personal data - ie. the right to require us to transfer some or all of the personal data we process to another administrator. This right of portability, according to Art. 20 of the Regulation, includes both your right to receive personal data concerning you and which you have provided to us - the controller in a structured, widely used and machine-readable format, but also the right to request the transfer of this personal data to another controller. .
        8. You have the right to withdraw your consent for the processing of your personal data, given with a Declaration - consent under Art. 6 or under Art. 9 of the Regulation at any time or upon registration on our website. Subsequent withdrawal will not affect the lawfulness of the processing carried out on the basis of the consent given.
        9. You have the right to know that we do not make automated decisions, including profiling, regarding your personal data that we process.
      10. We inform you that the legitimate interests we pursue in connection with the processing of your personal data as our client / user is to provide the highest possible standard of services.

     X. At your discretion you can file a complaint to the Commission for Personal Data Protection - 1592 Sofia, 2 Tsvetan Lazarov Blvd., tel. +359 2 915 3580, e-mail: kzld@cpdp.bg, website: http://www.cpdp.bg/, which is the competent authority for Bulgaria.
 
    XI. For questions about personal data protection you can contact us at: 1421 Sofia, 81A Arsenalski Blvd., tel. +359 2 988 9170, e-mail: office@viewpoint.bg
 
    XII. We are Viewpoint Ltd., UIC 831629853, registered office and address of management: 1421 Sofia, 35A Arsenalsky Blvd., tel. +359 2 988 9170, e-mail: office@viewpoint.bg, website: www.viewpoint.bg
ADDRESS
1421 Sofia,
81A Arsenalski Blvd.

tel:
(+359 2) 988 9170 , 988 9171 ,
(+359 2) 963 128 , 963 1705 ,

Working hours:
9.00 - 18.00 on all official working days in Bulgaria