Welcome to our site and Privacy Policy. Thank you for taking the time to read it

Commitment

At Binerals, your privacy is a top priority. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.

  • We do not compromise with your privacy.
  • We strive to be transparent in the way we process your data
  • We work hard to keep your information secure

This Privacy Policy was last updated on 12 Feb 2021.

Binerals Ltd., a limited liability company under Bulgarian law with registered office at Triaditsa region Manastirski Livadi Housing Estate, bl. 30, entr. A, ap. 4, Sofia, Bulgaria, registered under company registration number 205520779, with trade name “Binerals” (hereinafter: “Company”, “us”, “we”, or “our”) operates https://www.binerals.com (the “Site”). This privacy policy applies to all of Binerals services and products. You should be aware that Binerals cannot be held responsible for the privacy policy of other sites and sources.

This privacy policy ("Privacy Policy") describes the information collected by us, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures. By using our site, mobile apps, and/or other services we provide (collectively, "Binerals"), you agree to the practices set forth in this Privacy Policy. If you do not agree with this policy, then you must not access or use Binerals.

This privacy policy applies to all information Binerals collect from current and former users and visitors.

We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

We process personal data of individuals (data subjects) in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”), the Bulgarian Personal Data Protection Act (“PDPA”), the Internal Rules of the Company for personal data protection, as well as the information security practices of the ISO 2700 Information Security Standard

Binerals will act as the data controller in the framework of this Privacy Policy. The Company has appointed a designated data protection officer (“DPO”) that data subjects can contact directly with any inquiries relating to data protection at email: dpo@binerals.com.

Introduction

PERSONAL DATA: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

PERSONAL DATA PROCESSING: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

PERSONAL DATA SUBJECT/USER: Every physical person whose Personal Data is being processed.

PLATFORM: Software or software modules that operate jointly, being Company ownership that service the website www.binerals.com .

Categories of Data Subjects and Data we process

In connection with its services and business activities, the Company processes personal data of the following categories of data subjects:

  • Existing, former and prospective clients, suppliers, agents, and representatives, as well as other professional experts and commercial counterparties, with whom we have business relations;.
  • Complainants and enquirers, as well as individuals who contact us in any way, including via mail, phone, or via the contact form provided on our website, or provide review or feedback on our website;
  • Individuals who have fallen within the scope of the video surveillance performed by the Company for safety and security purposes, as well as for the protection of property;
  • Employees and job applicants.

One and the same person could file simultaneously in more than one of the abovementioned sub-divisions.

We process personal data of the above categories of data subjects. This data may include:

  • Personal details, such as the name of the person, contact information (email, phone, and address);
  • Business activities of the data subject, information about his or her relationship with us or with other data subjects
  • Services provided;
  • Financial details;
  • Education details;
  • Employment details.
  • Comments. When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
  • Media. If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

We may also collect other information regarding your use of our website through cookies and other similar technologies. You can find out more about this below.

We take seriously the protection of your privacy and confidentiality. We understand that you are entitled to know that your personal data will not be used for any purpose unintended by you, and will not accidentally fall into the hands of a third party.

We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.

Except as set out below, we do not share, or sell, or disclose to a third party, any information about you.

The basis on which we process information about you

We aim to process data, whether personal data or not, only to the extent necessary for us to provide our clients with our services and for other agreed purposes.

Often we may aggregate information in a general way and use it to provide class information. If we use it for this purpose, you as an individual will not be personally identifiable.

We process data on the basis of legitimate interests for purposes that include:

  • Managing and developing our business or services
  • Informing clients and prospective clients about our services
  • Determining relationships between clients and our partners and employees
  • Analyzing whether we provide clients with a high level of service
  • Information we process for the purposes of legitimate interests. We may process the information on the basis there is a legitimate interest, either to you or to us, in doing so. Where we process your information on this basis, we do after having given careful consideration to:
    • Whether the same objective could be achieved through other means
    • Whether processing (or not processing) might cause you harm
    • Whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

  • Record-keeping for the proper and necessary administration of our business.
  • Responding to unsolicited communication from you to which we believe you would expect a response
  • Protecting and asserting the legal rights of any party
  • Insuring against or obtaining professional advice that is required to manage business risk, protecting your interests where we believe we have a duty to do so.
  • Information we process because we have a legal obligation in the field of labor, accounting, tax, and social security legislation, as well as any other legal obligations applicable to the business activity of the Company;
  • Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal or tax authorities if they so request or if they have the proper authorization such as a search warrant or court order. This may include your personal information.

Specific uses of information

Job application and employment

If you send us information in connection with a job application, we may keep it for up to one year in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment and will be retained for six years after the end of your employment. Thereafter, we will retain only minimal information to satisfy reference requests where we believe that there is a legitimate interest to provide these.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment and will be retained for six years after the end of your employment. Thereafter, we will retain only minimal information to satisfy reference requests where we believe that there is a legitimate interest to provide these.

Office visitors

To ensure the security of customers, employees, visitors, and company’s property through video surveillance, and access control;

If you visit our office you will be required to sign in at reception. We keep a record of your visit in order to maintain the security of our premises, your safety and the safety of other visitors. We keep the record of your visit only for as long as necessary, and in any case, for less than one year.

Closed-circuit television (CCTV) may be used at our premises and the surrounding area in order to deter and to help investigate a crime.

We may process personal information captured from CCTV, including images and behaviors, on the basis of legitimate interests.

This information may be shared with the data subject, our employees and agents, and the police. Our landlords and their agents may also use CCTV.

Communicating with you

When you contact us, whether by telephone, through our website, or by e-mail, we collect the data you have given to us in order to reply with the information you need.

have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business

We keep personally identifiable information associated with your messages, such as your name and email address so as to be able to track our communications with you to provide a high-quality service.

Dealing with complaints

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do share this information, and if we do, what that information is.

We may also compile statistics showing information obtained from complaints to assess the level of service we provide, but not in a way that could identify you or any other person.

More specific purposes

The data subject has given their explicit consent to the processing of his or her personal data for one or more specific purposes, such as for direct marketing, participation in activities organized by the Company, etc. Please, note, that any consent granted may be withdrawn by the data subject at any time;

Use of information we collect through automated systems when you visit our website

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalized experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

We use cookies in the following ways:

  • to track how you use our website
  • to record whether you have seen specific messages we display on our website
  • to record your answers to surveys and questionnaires on our site while you complete them

You may read our Cookie Policy for more information on why we use them

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record reported information such as your geographical location and your IP address. We also record reported information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

This data cannot be used to identify you personally.

Our use of re-marketing

Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Links

We may keep track of how you interact with links available on Binerals including third party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.

Third-Party Sites

Binerals may contain links to other websites and services. If you choose to click on a third-party link, you will be directed to that third party's website or service. The fact that we link to a website or service is not an endorsement, authorization, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites or services. These third parties may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites and services you visit.

Disclosure and sharing of your information

At no moment in time will we directly sell or rent out your personal data to third parties.

We may share your personal data with third parties who process your data on our behalf when they provide services to us, such as video surveillance services, insurance, legal services, audit, consultancy, development, and maintenance of IT systems (including but not limited to data storage), or other services necessary for our business activities. In the performance of these services the third-party suppliers may have access to your personal data but are only authorized to process such data strictly on our behalf and in accordance with our instructions.

We may also disclose your personal data to third parties, if we reasonably believe that disclosure of such personal data is necessary to comply with valid legal obligations such as court orders, governmental requests, and as otherwise authorized by law, to protect our rights or property, or the safety of our customers or employees, to advance or defend against complaints or legal claims or proceedings, as well as during mergers & acquisitions, provided that the prospective buyer or seller agrees to respect your personal data in a manner consistent with GDPR and PDPA.

You share your personal data with third parties when you publish reviews and feedback on our website. Within Binerals, personal data is only available to people who need to have access to it in relation to their job.

Transfer of Personal Data

We do not transfer your personal data outside the European Economic Area (“EEA”). In case we are required to undertake any transfer of personal data outside the EEA, we take all reasonable necessary steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy and an adequate level of protection is applied to it, in particular through the implementation of standard contractual clauses approved by European Commission or contractual clauses previously authorized by the relevant authority.

How long we keep your data

Except as otherwise mentioned in this privacy policy, we keep your personal information only for as long as we need it for legitimate business purposes (as set out below) and as permitted by applicable law

  • to provide you with the services you have requested;
  • to comply with applicable law, including for the period demanded by our tax authorities (for instance, some "traffic data" is kept for one year to comply with statutory data retention obligations);
  • to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy, and other similar consents are kept for five years);
  • there is an outstanding issue, claim, or dispute requiring us to keep the relevant information until it is resolved; or
  • the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents.

Please note: If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

We do regular status checks to review when personal data needs to be deleted and have strict data retention periods determined in our Internal rules for personal data protection.

Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.

Security of Processing

As the Controller, the Company has implemented technical and organizational measures to ensure personal data processed remains secure and is certified under the ISO 2700 information security standard. However, absolute security cannot be guaranteed, but we maintain security and incident response plans in the event of a physical or technical incident to handle this in a timely manner and limit any negative effect of such incident.

Rights of the Data Subjects

GDPR and PDPA afford data subjects the following rights summarized below:

  • Right to access your personal data: you have the right to obtain confirmation from us as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and information.
  • Right to rectification of personal data: if you find that personal data that we process about you is inaccurate, you have the right to have us correct such personal data.
  • Right to erasure of personal data (right to be forgotten): under certain circumstances, such as if your personal data has been unlawfully processed or you have withdrawn your consent (if the processing of your personal data is based on consent), you have the right to request and obtain the erasure of your personal data from us.
  • Right to restriction of processing: under certain circumstances, such as if you question the accuracy of your personal data or you have objected to our legitimate purpose to process your personal data, you have the right to request that we restrict the processing of your personal data until a solution has been found.
  • Right to object to processing: under certain circumstances, such as if you question our legitimate interest to process your personal data, you have the right to object, on grounds relating to your particular situation, to such processing.
  • Right to data portability: if your personal data is processed by automated means based on your consent or for the fulfillment of our contractual relationship, you have the right to request that we provide you with personal data in a machine-readable format for transmission to another data controller.
  • Right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint regarding our processing of your personal data with the supervisory authority, which is the Bulgarian Commission for Personal Data Protection with address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Website: www.cpdp.bg, Е-mail: kzld@cpdp.bg.

In order to assert any of the above rights, data subjects can contact our DPO using the contact details provided above, or any other employee of the Company at any time. We will use commercially reasonable efforts to respond to your request within 30 days of receiving such a request. If we cannot honor your request within the 30-day period, we will let you know the reasons why and when we expect to be able to fulfill your request.

How You Can Access, Erase, Correct, or Restrict Your Personal Data

All requests to access, erase, correct, or restrict your Personal Data should be made in writing to: dpo@binerals.com

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

When we receive any request to obtain a copy of your personal information, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

Case of Data Breach

In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority competent in accordance with Article 55 of GDPR, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons (in Binerals’ sole opinion). Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay.

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

How you can complain

If you are not happy with our privacy policy or if you have any complaints, then you should inform us by email. Our address is dpo@binerals.com

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied with how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done athttps://ico.org.uk/concerns/

Review of our privacy policy

We may update this privacy notice from time to time as necessary.

The most current version of the policy will govern our use of your information and will always be at https://binerals.com/privacy-policy

By continuing to access or use our services after those changes become effective, you agree to be bound by the revised Privacy Policy.

When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy.

We recommend that you check our Website from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies.

If you have any questions regarding our privacy policy, please email dpo@binerals.com.