PRIVACY POLICY FOR “ASERTIVA SOLUTIONS” LLC

1. GENERAL
1.1. “Asertiva Solutions“ LLC, having UIC 207792831, having its seat and registered address at Republic of Bulgaria, city of Sofia, 1680, “Vitosha” Region, No: 102 “Bulgaria” Blvd.. 4th fl. (hereinafter “ASERTIVA”) provides you (hereinafter “You”) with various information technology services, among which services of implementation of specific cloud ERP software (hereinafter together referred to as “Service”). This privacy policy explains ASERTIVA’s practices regarding its collection, use and disclosure of certain information, including Your personal information when we provide the Service to You. It serves to inform You about our processing of Your personal information and ensure You that Your personal information is treated with respect and in accordance with the applicable data protection legislation when using the Service. 

1.2. You should always feel safe when sharing Your personal information with ASERTIVA. ASERTIVA has taken the technical and organizational security measures that are required to ensure that Your personal information is protected from unauthorized access, use, modification and deletion.

2. PERSONAL DATA CONTROLLER
2.1. ASERTIVA is the data controller for the processing of Your personal information handled by ASERTIVA. Information on how to contact us can be found in section 11.

3. WHEN DOES ASERTIVA COLLECT PERSONAL DATA?
ASERTIVA collects personal information about You when:

• You enter into pre-contractual relation with ASERTIVA in order to use the Service;
• You use the Service, providing us with access to personal data of your employees, required for the provision of the Service;
• You voluntarily fill in the test forms, provided by us;
• You voluntary contact us through the contact form, available at our corporate website;
• You voluntarily subscribe for our newsletter or;
• It is otherwise necessary to manage the relationship between You and ASERTIVA.

4. WHAT PERSONAL DATA DOES ASERTIVA PROCESS?
4.1. When You enter into contractual relation with ASERTIVA, it collects personal information about You. Basic data that ASERTIVA collects includes Your (or your employees’) name, e-mail address, phone number, username to the ERP software. When using the Service and when visiting ASERTIVA’s website, ASERTIVA may also collect data concerning usage, viewing and technical data, including Your IP address.

4.2. Further ASERTIVA may also collect and process Information that You provide in order to contact us through ASERTIVA's website, ASERTIVA's sites on third-party platforms such as social networking sites.

5. HOW LONG IS THE DATA KEPT?
ASERTIVA will keep personal information regarding You only as long as it is necessary, having regard to the purpose of the processing. This means that personal information collected and processed for marketing purposes will be stored for as long as You have an account and deleted thirty six (36) months after Your contractual relation is terminated, unless You have given ASERTIVA Your voluntary consent to continue to process such data. ASERTIVA may store data for longer if required by law or if required in order to monitor ASERTIVA's legal interests, for example if there are ongoing legal proceedings.

6. WHY DOES ASERTIVAPROCESS INFORMATION ABOUT YOU?
6.1. ASERTIVA processes Your personal information for various purposes. Primarily, ASERTIVA processes Your personal information in order to provide, manage, develop and customize the Service and its features, to manage the relationship with You and to meet security and other statutory regulatory requirements. Your personal information may also provide the basis for market and client analyses, market research, statistics, business monitoring and business and methodological development for ASERTIVA.

6.2. ASERTIVA also processes Your personal information to provide better and more personalized offers and services. Personal information may, for example, be processed, linked, segmented and analyzed in order, by means of targeted marketing, to provide information, offers or recommendations on ASERTIVA's advisory services, which are tailored to Your preferences, behaviors, needs or lifestyle.

6.3. In addition to the above, ASERTIVA processes Your personal information to prevent, detect and investigate potential prohibited or illegal activities, including fraud.

7. WHAT IS THE LEGAL BASIS FOR THE PROCESSING?
7.1. A majority of the personal information that ASERTIVA processes about You are processed in order for ASERTIVA to be able to provide and administer the Service and its features. Such is the case when ASERTIVA processes, inter alia, Your contact information such as Your e-mail address or Your phone number.

7.2. Some of the personal information which ASERTIVA processes are processed based on a balance of interest, i.e. ASERTIVA's interest of processing the data outweighs the impact and risk the processing may have on Your integrity.

7.3. To the extent that processing is carried out on the basis of a consent, it is voluntarily for You to give such a consent and You may at any time, wholly or partly, withdraw Your consent. If You choose to withdraw Your consent, and ASERTIVA's processing is such that it requires Your consent, the processing will be carried out in accordance with Your most recently given consent.

8. DATA SECURITY AND INTEGRITY
The security, integrity and confidentiality of Your personal information is all important to us. We have implemented technical, administrative and physical security measures that are designed to protect Your personal information from unauthorized disclosure, use and modification. From time to time, we review our security procedures in order to assess the need to implement additional measures or to make technical upgrades to existing procedures. Please be aware that, despite our best efforts, few security measures are impenetrable, and we therefore kindly ask that You inform us immediately of any suspicious activities that You notice in the Service.

9. WHO DOES ASERTIVA GIVE THE DATA TO?
9.1. Depending on the service that you entered a contractual relation for, ASERTIVA may disclose Your personal information to our external consultants, business partners and other third parties or to fulfill agreements with ASERTIVA's suppliers and partners.

9.2. ASERTIVA may also disclose personal information to companies that process personal information on our behalf, such as our IT system providers, client service companies and affiliates. If personal information is disclosed to such companies that process data on ASERTIVA's behalf, ASERTIVA enters into data processing agreements with such parties in order to ensure that a high level of security for Your personal information is maintained.

9.3. Personal information may also be disclosed, if needed, to comply with statutory legal requirements or requirements from regulatory authorities, to safeguard ASERTIVA's legal interests or to detect, prevent, or pay attention to fraud and other security or technical issues.

9.4. Your personal information may be transferred to or stored in a country outside the EU/EEA. If Your personal information is transferred or stored outside the EU / EEA, special safety measures will be taken, we will e.g. ensure that such transfer is carried out in accordance with this privacy policy and as permitted by the applicable laws on data protection, for example through the use of data transfer agreements that includes de standardized EU-model clauses for transfer of data adopted by the EU Commission and that are available on the EU Commission’s website.

10. CHANGES TO THE PRIVACY POLICY
This privacy policy may be revised from time to time. If ASERTIVA makes any significant changes to the privacy policy, ASERTIVA will inform You in an appropriate way before the changes take effect. The privacy policy will also be published on ASERTIVA's website. If any change requires Your consent, ASERTIVA will obtain a new consent from You.

11. RIGHT TO REQUEST INFORMATION AND CORRECTIONS ETC.
11.1. You have the right to be given free information about, inter alia, the personal information that ASERTIVA processes on You and for what purpose ASERTIVA is processing Your personal information (so-called record extract). Any such request for a record extract must be made in writing and be signed by You.

11.2. You are also entitled to have inaccurate, misleading or incomplete data corrected, anonymized or deleted. You are also entitled to request ASERTIVA to restrict the processing of Your personal information and to object to the processing. Furthermore Youmay exercise Your right to data portability, which means that You have the right to receive the personal informationprocessed about You in a structured, commonly used and machine-readable format.

11.3. Please note that some of the rights above only may be exercised in certain situations, e.g. the right to data portability, which only applies when the processing is carried out on the basis of an agreement or a consent and if the processing is carried out by automated means. In case You have any questions regarding how ASERTIVA processes Your personal information, want to exercise any of Your rights or want to know more about the rights, You may contact us as indicated below.

E-mail address: gdpr@asertivasol.com

Address: Republic of Bulgaria, city of Sofia, 1680, “Vitosha” Region, No: 102 “Bulgaria” Blvd.. 4th fl.
You are also entitled to lodge a complaint with a supervisory authority if You consider that Your personal information has been processed in contradiction with applicable data protection legislation.