Last modified: 22/09/2022
1. Overview information
2. Data Controller’s information
Coherent Solutions, Ltd., with registered address: 40 Tsarigradsko shose Blvd., Sofia, 1750, Bulgaria, together with Coherent Solutions subsidiaries (“Coherent Solutions”) are personal data Joint Controllers (“Controller”) and are responsible for compliance with the provisions of the Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR” or “General Data Protection Regulation”). More information on how to contact us is available under No.13 below.
An agreement has been concluded between us, which establishes our responsibility for the fulfillment of the obligations set out in the GDPR (we will provide access to the essential provisions of this agreement upon written request). In any case you may exercise your rights under the GDPR in respect of each of the Controller.
3. Legal grounds for processing, Processing Purposes
3.1. Legal ground for processing
Coherent Solutions only processes personal data if it is absolutely necessary. The purposes of processing and the legal grounds for doing so are the following:
When data processing is based on “explicit consent”, on the grounds of Article 6(1)(a) and Article 7 of the General Data Protection Regulation, the provision of personal data for this purpose is optional. However, lack of consent may result in Coherent Solutions not being able to respond to your request or an application.
Coherent Solutions as personal data Controller follows the following principles when processing your personal data:
3.2. Purpose for processing
Coherent Solutions as Controller executes the following operations and processes personal data for the following purposes:
The type of data that we can collect for the listed purposes are:
4. Information We Collect from our Website
When you consent to use our Website, we collect information about you as you use the Website or as you provide it to us, including:
5. Recipients of personal data
Personal data collected may be stored and processed within and outside the EEA. Coherent Solutions provides personal data to persons outside the European Union only with the explicit consent of the data subject and (or) only using an adequately high level of protection of personal data, by requiring standard contractual clauses or other instruments to ensure adequate protection of such data under the GDPR. We share data within the Coherent Solutions subsidiaries insofar as necessary to enable the decentralization of business operations, support ongoing business activities and to achieve business continuity.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
6. Rights of data subjects
You, as the data subject, have all rights specified in the applicable legal acts, including indicated down below.
6.1 Right to information. You may at any time request from us information about your personal data that we store and process, as well as about the origin, recipients or categories of recipients to whom we transmitted it, the purpose of processing it as well as any other information as indicated in the applicable legal acts.
6.2 Right of withdrawal. If you have provided us with your consent to process your data, you can withdraw your consent at any time without giving any reasons (withdrawal of the consent shall not affect the lawfulness of the processing of personal data based on the consent before its withdrawal).
6.3 Rectification right. If your personal data processed by Coherent Solutions is incorrect (inaccurate), you can ask us to correct it at any time.
6.4 Erasure and restriction of processing rights. You have the right to request the deletion of your personal data that Coherent Solutions processes or obtain restriction of processing. Deletion can be done at any time by contacting us. Your data will be deleted without undue delay after exercising this right as a data subject. If deletion is contrary to legal, contractual, criminal or commercial law, or other legitimate reasons, instead of deletion, only restriction of your data may take place. After deleting your data, it is no longer possible for us to recover it.
6.5 Right to data portability. If you require us to provide you with your personal data, we will transfer the data to you or another controller in a structured, widely used and machine-readable format. We will only transfer the data directly if it is technically feasible and we have your request.
6.6 Right of objection. You have the right at any time and without giving any reason to object to our processing of your data, including if we process it for the purposes of marketing.
6.7 Advanced rights in automated data processing, including profiling. Coherent Solutions does not perform automated data processing, including profiling. Notwithstanding the above, with respect to automated data processing, including profiling, you have the additional right to request human intervention from the Controller, the right to challenge the decision and the right to express your point of view.
6.8 Contact (for the exercise of your rights as a data subject). When contacting us by e-mail at firstname.lastname@example.org or by mail at: 40 Tsarigradsko shose Blvd., Sofia, 1750, Bulgaria, the reported data (including e-mail address, name and telephone number, if any) are stored by us in order to respond to your questions and respond to your case. We will delete the retained data as soon as the storage is no longer necessary or will restrict its processing if there are statutory obligations.
6.9 Right of Complaint. You are entitled to file a complaint against the processing of personal data before the competent control body if you believe that your personal data protection rights have been violated.
We will respond to all your requests related to the implementation of your, as the data subject, rights without undue delay and no later than within 1 (one) month after receiving the request. That period may be extended by 2 (two) further months by informing you in advance.
7. Retention period
The received personal data is stored and processed for the following terms:
8. Data security
Coherent Solutions uses technical and organizational security measures to provide the most comprehensive protection of personal data from unauthorized access. We make every reasonable effort to protect your personal information. All our internal and client data is stored in secure cloud servers and managed in accordance to the best practices quoted in “ISO/IEC 27001 Information Security Management Systems. Requirements”. Data encryption is used for more critical data or by customer’s request.
Personal data for marketing purposes is stored in the Pardot Marketing Automation platform. Coherent Solutions also uses Google’s Universal Analytics tracking on our Website.
9. Use of Coherent Solutions’ website by children
We do not intend our Websites or online services to be used by anybody under the age of 14. If you are a parent or guardian and you think we may have collected information about a child, please contact us at email@example.com.
10. Competent supervisory authority
11. Your Access and Control Over Your Information
You can opt-out of receiving targeted ads served by our advertising partners:
Coherent Solutions Ltd.
40 Tsarigradsko shose Blvd.,