Last update: July 04, 2023
This privacy notice of Abra Net Ltd. (carrying out activity such as Abra.bg, Avente.Shop, Cadabra.Host, Cadabra.Plus, OnDesk Center) ("we", "us" or "our"), describes how and why we may collect, store, use and/or share ("we process") your information when you use our services ("Services"), such as when:
Visit our website at https://cadabra.host or our other website that contains links to this privacy notice.
or
contact us in other ways, including sales, marketing or events.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at gdpr@abra.bg.
SUMMARY OF MAIN POINTSThis summary contains key points from our privacy notice, but you can find out more details about each of these topics by clicking on the link after each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about the personal information you disclose to us.
Do we process sensitive personal information? We do not process sensitive personal information.
Do we receive information from third parties? We may receive information from public databases, marketing partners, social media platforms and other external sources. Learn more about information collected from other sources.
How do we process your information? We process your information to provide, improve and administer our Services, to communicate with you, for security and fraud prevention purposes, and to comply with the law. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal reason to do so. Find out more about how we process your information.
In what situations and with which types of parties do we share personal information? We may share information in certain situations and with certain categories of third parties. Learn more about when and with whom we share your personal information.
How do we protect your information? We have organizational and technical processes and procedures to protect your personal information. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals or other unauthorized third parties will not be able to breach our security and collect, access, steal or improperly alter your information. Learn more about how we protect your information.
What are your rights? Depending on where you are located geographically, applicable data protection law may mean that you have certain rights in relation to your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting http://www.abra.bg/gdpr or by contacting us. We will consider and act on any request in accordance with applicable data protection laws.
Want to know more about what we do with the information we collect? View the full privacy notice.
CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. ON WHAT LEGAL GROUNDS DO WE RELY TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE PROCESS YOUR SOCIAL LOGINS?
7. IS YOUR INFORMATION TRANSMITTED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE PROTECT YOUR INFORMATION?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. MANAGEMENT OF TRACKING FUNCTIONS
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW YOU CAN CONTACT US IN RELATION TO THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
НIn short: We collect personal information that you provide to us.
We collect personally identifiable information that you voluntarily provide to us when you register on the Services, express an interest in receiving information about us or our products and Services, participate in activities on the Services, or otherwise contact us.
Personal information provided by you. The Personal Information we collect depends on the context of your interaction with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
telephone numbers
names
email addresses
postal addresses
usernames
passwords
contact preferences
contact or authentication details.
billing addresses
Sensitive information. We do not process sensitive information.
Payment Details. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is stored from stripe.com, paypal and epay. You can find their privacy notices through the link(s) here: https://stripe.com/en-gb-bg/privacy, https://www.paypal.com/us/legalhub/ privacy-full and https://www.epay.bg/v3main/front/declaration.
Social media login details. We may give you the opportunity to register with us using your existing social media account details, for example on Facebook, Twitter or other social media. If you choose to register in this way, we will collect the information described in the section entitled "HOW DO WE PROCESS YOUR SOCIAL ACCOUNTS?" below.
All personal information you provide to us must be true, complete and accurate and you must notify us of any changes to that personal information.
Automatically collected information
НIn short: When you visit our Services, certain information is automatically collected, such as your Internet Protocol (IP) address and/or browser and device characteristics.
We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (such as your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily necessary to maintain the security and operation of our Services, as well as for our internal analytics and reporting purposes.
Like many other companies, we also collect information through cookies and similar technologies.
The information we collect includes:
Log data and usage data. The log data and usage data are service-related, diagnostic, usage, and performance information that our servers collect automatically when you access or use our Services and that we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, as well as information about your activity on the Services (such as date and time stamps associated with your usage, pages and files viewed, searches and other actions you take, such as which features you use), information about device events (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
Device details. We collect device data, such as information about your computer, phone, tablet or other device that you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
Location data. We collect location data, such as information about the location of your device, which may be accurate or inaccurate. The amount of information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that shows us your current location (based on your IP address). You may opt-out of allowing us to collect this information by refusing access to the information or by disabling the location setting on your device. However, if you choose to opt-out, you may not be able to use certain aspects of the Services.
Information gathered from other sources
In summary: We may collect limited data from public databases, marketing partners, social media platforms and other external sources.
To improve our ability to provide you with relevant marketing, offers and services and to update our records, we may obtain information about you from other sources, such as public databases, co-marketing partners, affiliate programs, data providers, social media platforms and other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles for the purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we obtain personal information about you, such as your name, email address, and gender. Any personal information we collect from your social media account is subject to the privacy settings of your social media account.
2. HOW DO WE PROCESS YOUR INFORMATION?
In short: We process your information to provide, improve and administer our Services, to communicate with you, for security and fraud prevention purposes, and to comply with the law.
We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons depending on how you interact with our Services, including:
Make it easier to create and authenticate accounts and otherwise manage user accounts.
We may process your information to enable you to create and log in to your account and to keep your account in working order.
To provide and facilitate the provision of services to the user. We may process your information in order to provide you with the requested service.
Answering user queries/offer user support. We may process your information in order to respond to your queries and resolve any issues you may have with the requested service.
To send you administrative information. We may process your information to send you details of our products and services, changes to our terms and policies, and other similar information.
To fulfil and manage your orders. We can process your information to fulfill and manage your orders, payments, returns and exchanges made through the Services.
To send you marketing and advertising messages. We may process the personal information you send us for our marketing purposes if this is in line with your marketing preferences. You can opt-out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
To protect our Services. We may process your information as part of our efforts to keep our Services secure and safe, including monitoring and preventing fraud.
Identify usage trends. We may process information about how you use our Services to better understand how they are used so that we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to deliver marketing and promotional campaigns that are most relevant to you.
To save or protect a person's vital interests. We may process your information where it is necessary to save or protect a person's vital interest, for example to prevent harm.
3. WHAT LEGAL GROUNDS DO WE RELY ON TO PROCESS YOUR INFORMATION?In summary: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. a legal basis) to do so under applicable law, for example, with your consent, to comply with the law, to provide you with services, to enforce or perform our contractual obligations, to protect your rights, or to comply with our lawful
business interests.
The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases on which we rely to process your personal information. As such, we may rely on the following legal bases to process your personal information:
Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Find out more about withdrawing your consent.
Contract Execution. We may process your personal information where we believe it is necessary to perform our contractual obligations to you, including to provide our Services, or at your request before entering into a contract with you.
Legitimate interests. We may process your information where we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not override your interests and fundamental rights and freedoms.
For example, we may process your personal information for some of the purposes described in order to:
Sending users information about special offers and discounts on our products and services
analysing how our services are used so we can improve them and attract and retain users.
Supporting our marketing activities
Diagnosis of problems and/or prevention of fraudulent activities
To understand how our users use our products and services so we can improve the user experience.
Legal Obligations. We may process your information where we believe it is necessary to comply with our legal obligations, such as to cooperate with a law enforcement or regulatory agency, to exercise or defend our legal rights, or to disclose your information as evidence in litigation in which we are involved.
Life interests. We may process your information when we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of a person.
Legally, we are generally the "data controller" under European data protection laws for the personal information described in this privacy notice,
as we determine the means and/or purposes of the data processing we carry out. This privacy notice does not apply to the personal information we process as a "data processor" on behalf of our clients. In these situations, the client to whom we provide services and with whom we have entered into a data processing agreement is the "data controller" responsible for your personal information and we only process your information on their behalf in accordance with your instructions. If you would like to know more about our customers' privacy practices, you should review their privacy policies and direct any questions to them.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
НIn short: We may share information in specific situations described in this section and/or with the following categories of third parties.
Vendors, consultants and other third party service providers. We may share your information with third party vendors, service providers, contractors or agents ("Third Parties") who perform services for us or on our behalf and need access to such information to perform that work. We have contracts in place with our third parties to help protect your personal information.
This means that they cannot do anything with your personal information unless we have instructed them to do so. They will also not share your personal information with any organisation other than us. They also undertake to protect the data they hold on our behalf and keep it for the period we are instructed.
The categories of third parties with whom we may share personal information are:
Advertising networks
Affiliate Marketing Programs
Cloud computing services
Communication and cooperation tools
Data Analysis Services
Tools for finance and accounting
Government organisations
Payment processors
Performance monitoring tools
Product engineering and design tools
Retargeting platforms
Sales and marketing tools
Social networks
User account registration and authentication services
Website hosting service providers
We may also need to share your personal information in the following situations:
Transfer of business. We may share or transfer your information in connection with or during negotiations for a merger, sale of company assets, financing or acquisition of all or part of our business by another company.
When using the Google Maps API. We may share your information with some APIs on the Google Maps platform (e.g. Google Maps API, Places API).
Partners. We may share your information with our affiliates, in which case we will require them to comply with this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business partners. We may share your information with our business partners to offer you certain products, services or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In summary: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (such as web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
6. HOW DO WE PROCESS YOUR SOCIAL LOGINS?
In summary: If you choose to register or log into our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your account details on a third party social media site (for example, your Facebook or Twitter accounts). When you choose to do this, we will receive certain information about your account from your social media provider. The profile information we receive may vary depending on the relevant social media provider, but will often include your name, email address, friends list and profile picture, as well as other information you have chosen to make public on such social media platform.
We will only use the information we receive for the purposes that are described in this Privacy Notice or that are otherwise explained to you in the relevant Services. Please note that we do not control and are not responsible for any other uses of your personal information by your third party social media provider. We encourage you to review their privacy notice to understand how they collect, use and share your personal information and how you can set your privacy preferences on their sites and apps.
7. IS YOUR INFORMATION TRANSMITTED INTERNATIONALLY?
In short: We may transfer, store and process your information in countries other than your own.
Our servers are located in Bulgaria and France.
If you access our Services from outside of Bulgaria and France, please note that your information may be transferred to, stored and processed by us at our facilities and by those third parties with whom we may share your personal information (see above)
"WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?", in the United States, the United Kingdom and other countries.
If you are a resident of the European Economic Area (EEA) or the United Kingdom (UK), those countries do not necessarily have data protection laws or similar laws that are as comprehensive as those in your country. However, we will need to take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In summary: We retain your information for as long as necessary to fulfill the purposes described in this privacy notice, unless otherwise required by law.
We will retain your personal information only for as long as necessary for the purposes set out in this privacy notice, unless the law requires or permits a longer retention period (for example, tax, accounting or other legal requirements). None of the purposes in this notice will require us to retain your personal information for more than six (6) months after the start of the user account inactivity period .
Where we do not have a continuing legitimate business need to process your personal information, we will either delete or anonymise that information or, if this is not possible (for example, because your personal information has been stored in backup archives), we will store your personal information securely and isolate it from any further processing until deletion is possible.
9. HOW DO WE PROTECT YOUR INFORMATION?
In short: We strive to protect your personal information through a system of organizational and technical security measures.
We have put in place appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our precautions and efforts to protect your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals or other unauthorized third parties will not be able to breach our security and collect, access, steal or improperly alter your information. While we will do everything we can to protect your personal information, the transmission of personal information
to and from our Services is at your own risk. You should only access the Services in a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In short: We do not knowingly collect data from children under the age of 18 and we do not market it.
We do not knowingly solicit data from children under the age of 18 and do not market to them. By using the Services, you represent that you are at least 18 years of age or that you are the parent or guardian of such minor and consent to such minor's use of the Services. If we learn that personal information has been collected from users under 18, we will disable the account and take reasonable steps to promptly delete such data from our records. If you become aware of data we may have collected from children under the age of 18, please contact us at gdpr@abra.bg.
11. WHAT ARE YOUR PRIVACY RIGHTS?
In short: In some regions, such as the European Economic Area (EEA) and the United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You can view, change or terminate your account at any time.
In some regions (such as the EEA and the UK) you have certain rights under applicable data protection laws. These may include the right: (i) to request access to and obtain a copy of your personal information; (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You may make such a request by contacting us using the contact details set out in the "HOW CAN YOU CONTACT US IN RESPECT OF THIS NOTICE?" section below.
We will consider and act on any request in accordance with applicable data protection laws.
If you are located in the EEA or the UK and you believe that we are processing your personal information unlawfully, you have the right to lodge a complaint with your member state's data protection authority or the UK's data protection authority.
If you are in Switzerland, you can contact the Federal Data Protection and Information Commissioner.
Withdrawal of your consent: If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. You may withdraw your consent at any time by contacting us using the contact details set out in the section below.
"HOW CAN YOU CONTACT US REGARDING THIS NOTIFICATION?"
However, please note that this will not affect the lawfulness of processing prior to withdrawal, nor will it affect the processing of your personal information carried out on lawful processing grounds other than consent.
Opt-out of marketing and advertising messages:
You can unsubscribe from our marketing and advertising communications at any time by clicking the unsubscribe link in the emails we send, by replying "STOP" or "UNSUBSCRIBE" to the SMS messages we send, or by contacting us using the details set out in the "HOW CAN YOU CONTACT US AFTER YOU SUBSCRIBE?" section below.
You will then be removed from marketing lists. However, we may continue to communicate with you - for example, to send you service-related messages that are necessary to administer and use your account, to respond to service requests, or for other non-marketing purposes.
Profile Information
If at any time you wish to review or change your account information or terminate your account, you may:
-Go to your account settings and update your profile.
-Contact us using the contact information provided.
-At your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.
-Cookies and similar technologies: most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to remove cookies and reject them. If you choose to remove or reject cookies, it may affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you can email us at gdpr@abra.bg.
12. MANAGEMENT OF TRACKING FUNCTIONS
Most web browsers and some mobile operating systems and mobile apps include a Do-Not-Track (DNT) feature or setting that you can enable to express your privacy preferences so that data about your online browsing activities is not tracked and collected. At this stage, no single technology standard for the recognition and enforcement of DNT signals has been finalised. Therefore, we do not currently respond to browser DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If an online tracking standard is adopted for us to follow in the future, we will inform you of this practice in a revised version of this Privacy Notice.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In short: Yes, we will update this notice as necessary to comply with relevant laws.
We may update this privacy notice from time to time. The updated version will be marked with an updated "Revised" date and will be effective as soon as it becomes available. If we make material changes to this Privacy Notice, we may notify you either by posting a prominent notice of those changes or by sending you a notice directly. We encourage you to review this privacy notice frequently to stay informed about how we are protecting your information.
14. HOW CAN YOU CONTACT US REGARDING THIS NOTIFICATION?
If you have any questions or comments about this notice, you can email us at gdpr@abra.bg or contact us by mail at:
Abra Net Ltd.
Chiprovtsi 27-1 ul. Ruse, Ruse 7000 Bulgaria
If you are a resident of the European Economic Area, we are the "controller" of your personal information. You can contact us directly about the processing of your information, by email at gdpr@abra.bg, by visiting https://abra.bg/contact, by telephone on +359 82 540 372
or by post to
Chiprovtsi 27-1 Ruse, Ruse 7000
Bulgaria
15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws in your country, you may have the right to request access to, amend, or delete the personal information we collect from you. To request to review, update or delete your personal information, please visit: http://www.abra.bg/gdpr-.
