PRIVACY STATEMENT
Effective Date: 01.10.2024
I. INTRODUCTION
We are committed to protecting your privacy. This privacy statement describes why and how we collect, use and disclose personal information collected from individuals themselves or from other third parties, and provides information about individuals’ rights with respect to their personal information. We may use personal information provided to us for any of the purposes described in the relevant section of this privacy statement or as otherwise stated at the point of collection.
We process personal information as necessary for our legitimate business purposes in a transparent manner. If you have any questions regarding our privacy practices, please contact us as set forth in the Contact Us section of our website.
The Company, or we, us, our, refers to „Universum Energy Project Development“ EOOD, а solely owned limited liability company, registered in Bulgaria, company number 207967704, with registered seat and address of management: 1797 Sofia, Musagenitsa (Mladost-1) residential area, blok 98Б, entrance A, floor 6, ap. 13.
II. WHAT INFORMATION WE COLLECT, USE AND WHY
Our approach is to collect only the personal information necessary for agreed purposes, and we ask our clients, partners, suppliers, web visitors to share personal information with us when it is needed for those purposes. When we need to process personal information to provide our services, we ask our clients to provide the necessary information to the data subjects concerned as our clients are typically in the appropriate position to communicate this information to the data subjects (e.g., our clients’ employees).
We collect or use the following information to provide services: names and contact details, identification documents, information relating to compliments or complaints.
We collect or use the following information to prevent and detect fraud: names and contact details; identity information, KYC/KYB information.
We collect or use the following information for service updates or marketing purposes: names and contact details, marketing preferences, website and app user journey information, records of consent, where appropriate.
We collect or use the following information to comply with legal requirements: names, contact information, identity information, financial information, KYC/KYB information.
We collect or use the following personal information for dealing with queries, complaints or claims: names and contact details, correspondence.
III. WHAT LAWS APPLY TO US?
When handling personal data, we will comply with the European Data Protection Regulation (the GDPR) and other applicable laws and regulations (herein referred to as the applicable data protection laws). Such laws vary among countries, with some providing more protection than others. Regardless of where your information comes from, we apply appropriate safeguards as described in this statement.
The data protection principles are designed to ensure that individuals’ personal information is protected throughout the information lifecycle – that is, from the time the information is collected through to its destruction.
VI. PURPOSES FOR PROCESSING
We use the personal information for the following purposes:
V. OUR LAWFUL BASES FOR THE COLLECTION AND USE OF PERSONAL DATA
Our lawful bases for collecting or using personal information to provide services are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: providing services to businesses.
Our lawful bases for collecting or using personal information to detect and prevent fraud is:
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: updating our existing customers for upcoming projects or new services as part of our portfolio.
Our lawful bases for collecting or using personal information for complying with legal requirements is:
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Consent – we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
VI. WHERE WE GET PERSONAL INFORMATION FROM
Directly from you or someone authorised by you to share your information with us.
Publicly available sources.
VII. WHO WE SHARE INFORMATION WITH
As a general rule, we do not disclose personal data to any third parties, except if it is otherwise required by the applicable data protection laws or to third parties engaged to provide services in connection with the purposes described in this statement (e.g. cloud or marketing and communication tools providers, etc.).
Personal information may be disclosed to auditors and other advisors as necessary in connection with the products and services they have been engaged to provide. We also may need to disclose personal information to an insurer, for example, in the event of a claim.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfill requests for personal information where we are permitted to do so in accordance with applicable law or regulation.
VIII. INTERNATIONAL DATA TRANSFERS
We may change our business model from time to time. Therefore, in the future we may collect your personal data within the country you are located and then transfer and process it to another area. If we initiate transferring of personal data to countries not deemed adequate as per the applicable laws, we put contractual arrangements and security mechanisms in place as appropriate to protect the information and to comply with our information protection, confidentiality and security standards.
IX. INDIVIDUAL RIGHTS
Based on your jurisdiction, you have certain rights. For example, under the GDPR, you have the following rights:
Your right of access – You have the right to ask us for copies of your personal data.
Your right to rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.
You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.
To make a data subject request, please contact at compliance@universum-energy.com.
X. APPROPRIATE SAFEGUARDS
Information security has always been central for the protection of confidentiality, integrity and availability of personal data. To help protect the privacy of personal data, we maintain technical and organisational security measures. We update and test our measures on an ongoing basis. We restrict access to your personal data to those employees who need to know that information for the purpose described in this statement. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
XI. DATA RETENTION
We retain the personal information processed by us for as long as is considered necessary for the purpose(s) for which it was collected. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights.
XII. HOW TO COMPLAIN
If you have a concern or complaint about your privacy or data protection, let us know and we’ll try to fix it. If you’re not satisfied with how we handle your complaint, there are other things you can do. You can also contact the data protection authority in your jurisdiction. Here is a list of the data protection authorities in the EEA.
XIII. UPDATES
WE may update this privacy statement at any time by publishing an updated version here. You can access the most current version of this privacy statement at any time on this site.
XIV. HOW TO CONTACT US
If you have questions about this privacy statement or about our privacy practices, please contact us by completing our general form here: https://universum-energy.com/#contact-us.
