Consent(Required) I agree to the privacy policy.
LEGALCOIN PRIVACY POLICY
Updated January 2021
GENERAL
In this privacy policy (this "Policy"), we describe:
• the information that we collect and process about you (that you provide directly to us or is provided to us by third parties);
• the purposes for which we collect and process information about you; and
• the basis on which we collect and process information about you, when you use this website (our “Website"), in connection with our services available through our Website, our mobile website, our Mobile Application or otherwise and/or when we facilitate the processing of your payments on other platforms or websites operated by our users.
In this Policy, the term "personal information" or "personal data" means personal information or data that relates to an identified or identifiable person.
We recommend that you read this policy carefully in order to understand what ILATS EOOD and its subsidiaries, ("we", "us", "ILATS") do with your personal information. Your use of our Website and services and any dispute over privacy, is subject to this Policy and any of our applicable Terms and Conditions for use of our services.
HOW, WHEN AND WHAT WE COLLECT?
How does ILATS EOOD collect my personal information?
We collect personal information directly from you, about you from third parties such as our marketing affiliates and service providers used to verify your identity and prevent fraudulent activity, other ILATS EOOD users and other ILATS EOOD clients or customers, for the purpose of providing the ILATS EOOD services to you or to facilitate the processing of your payments on other platforms or websites operated by our users, or as part of a customer referral program, and automatically as you use our Website and/or our services.
When does ILATS EOOD collect my personal information?
• When you apply for and use our services, when we facilitate the processing of your payments on other platforms or websites operated by our users, when you contact us with questions, and when you otherwise choose to provide personal information to us.
• We may receive personal information about you from banking references, credit reporting agencies, affiliates, other ILATS EOOD users, and other third parties (e.g., entities that assist us in validating your identity, for risk assessment purposes, for fraud prevention, etc.). We may combine this information with other information that we collect about you.
• We, and our third party service providers, automatically collect the following information about your use of our Website and/or our services through cookies, web beacons, log files and other technologies (subject to your consent where required by applicable law): your domain name, your browser type and operating system, webpages you view, links you click, your IP address, the length of time you visit our Website and/or use our services, your activities on our Website, and the referring URL or the webpage that led you to our Website. If you are a registered user using our Mobile Application, we also may collect the following information about you: mobile device ID; device name and model; operating system type, name, and version; your activities within the Mobile Application, the length of time that you are logged into our Mobile Application, and, with your permission, your precise geo-location information. Please see our Cookies Policy for more information.
• When you apply for a job with ILATS EOOD.
What personal information does ILATS EOOD collect?
The types of personal information we collect about you depends on your particular interaction with our Website and/or our services or when we facilitate the processing of your payments on other platforms or websites operated by our users, and includes, where permitted by applicable law:
Categories of Personal Information Collected Specific Personal Information Source of Personal Information
Identifiers Name, email address, phone number, billing or mailing address, IP address, date of birth, national identification numbers and documents that may include your photograph. Directly from you, third parties on your behalf and as instructed by you, other ILATS EOOD users and customers, our service providers and affiliates.
Financial Information Bank and credit account information, Credit history as applicable, Details of any transactions carried out using any of our services Directly from you, third parties on your behalf and as instructed by you, other ILATS EOOD users and customers, our service providers and affiliates.
Internet or Other Simliar Network Activity Your interaction with our website
Other information collected through Cookies and other tracking technologies as listed above and as described in our Cookies Policy From you directly and our third party and/or analytic tools and cookies usage (See our Cookies Policy for more information).
Commercial Information Information about your business Directly from you, third parties on your behalf and as instructed by you, other ILATS EOOD users and
customers, our service providers and affiliates.
Geolocation Data Geolocation Directly from you and/or through your use of the Mobile Application and/or our third party analytic tools and cookies usage (See our Cookies Policy for more information).
Professional or Employment Information (for Job Candidates) Name and contact information, professional credentials and skills, educational and work history, salary, evaluations, references, interviews, certifications, disciplinary matters and other information of the type included on a resume, curriculum vitae or cover letter. Directly from you or when another party, such as a recruiter or external website, provides it to us.
Other categories Any other information that you choose to provide to us (e.g., when you send us an email/otherwise contact us).
Calls/emails/other
correspondence. Directly from you, third parties on your behalf and as instructed by you.
Special categories of Personal Data Biometric Data in the form of 'selfies' (self-photographs) processed for the purposes of identity verification when you become a customer. Directly from you, third parties on your behalf and as instructed by you, or from our service providers.
HOW AND WHY WE USE YOUR INFORMATION?
o To validate your identity (including via SMS or Voice Call, if applicable) and verify your access and control over bank accounts you associate with our services.
o To register you and provide our services to you, to facilitate the processing of your payments on other platforms or websites operated by our users, to communicate with ILATS EOOD
you in connection with our services and KYC verification processes (including via SMS, messaging applications, or, for users of our Mobile Application, via "push" notifications) or any changes in our Terms and Conditions or this Policy that apply to you.
o For the purpose for which you specifically provide the personal information to us, including, to respond to your inquiries, to provide any information that you request, and to provide customer support (including via SMS, messaging applications, as applicable).
o To tailor the content and information that we may send or display to you, to offer location customization (where permitted by applicable law), personalized help and instructions, and to otherwise personalize your experiences while using our Website and/or our services, such as developing and offering you with new and/or additional ILATS EOOD services to the services we are providing you or new and/or additional features to existing services, based, where appropriate, on your eligibility for such new and/or additional services or features, as would be evaluated by us from time to time.
o For marketing and promotional purposes, for example, we may use your personal information, such as your email address, phone number (including via SMS, messaging applications, as applicable), or mailing address to send you newsletters, special offers and promotions, or to otherwise contact you about services or information we think may interest you (unless you are opted-out from our marketing communications), or to conduct draws for campaigns and the like and deliver prizes and rewards.
o As permitted by applicable law, to assist us in advertising our products and services in various mediums including, without limitation, sending you promotional emails, advertising our services on third party sites and social media platforms, sending you direct mail, and by telemarketing (unless you are opted-out from our marketing communications).
o To better understand how users, access and use our Website and/or our services, both on an aggregated and individualized basis, to administer, monitor, and improve our Website and/or services, for our internal purposes, and for other research and analytical purposes. Please see our Cookies Policy for more information.
o To protect us, our customers, employees, partners or property — for instance, to investigate fraud and prevent fraudulent activity, abuse of the services, harassment or other types of unlawful activities involving us or other companies that we do business with, to enforce this Policy, as well as our Terms and Conditions.
o We process personal data, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as evaluating a job candidate for a position with us and communicating with you regarding your application and future opportunities.
WHEN DO WE SHARE YOUR INFORMATION?
We share your personal information with third parties, including service providers, regulated institutions (e.g., financial institutions), affiliated entities, and business partners as set out in the table below. In the table below, we also list the reasons why we share information.
How and Why We Share Your Information Does
ILATS EOOD
Share?
With our service providers and affiliates - for our business purposes, such as to assist us with the provision of our services and to verify your identity, prevent, detect and protect against fraudulent activity or abuse of our services, conduct internal research and analytical assessments, process your transactions, maintain your account(s) and provide you with customer care services. These include internet service providers, data and cyber security services, banks, financial institutions, payment processors, financial services providers, remote access services; service providers that help us verify your identity and help us comply with our legal and regulatory obligations; and our business, legal, tax, financial and other advisors, on a confidential basis. Such service providers may differ based on the services provided to you and your jurisdiction. Yes
With fraud prevention and detection service providers - which provide fraud prevention, detection, protection services, or other similar services, on our, or our service provider's, behalf. Such service providers may keep records of information provided and use it when providing fraud detection and prevention services to other users of their databases. Yes
For marketing purposes:
1. With our service providers and our affiliates - to market our own products and services; and
2. With non-affiliated third parties for joint marketing purposes. Yes*
With ILATS EOOD clients, customers or third parties using our services - to perform our services, assist in carrying out your transactions with such clients, customers or third parties or for purposes of our refer-a-friend program(s). In addition, where a ILATS EOOD card is issued to you as an expense card under a Corporate Client expense card program (in accordance with our Terms and Conditions) - we may share information related to usage and balance of the card with such client. Yes
In response to legal process - to comply with the law, a judicial proceeding, subpoena, court order, or other legal process. Yes
In connection with business transfers - to another entity if we are acquired by or merged with such other entity, if substantially all of our assets are transferred to such other entity, or as part of a bankruptcy proceeding. Yes
To protect the rights, property, or safety of us and others - we may disclose personal information to our business partners, service providers and other third parties when we believe it is necessary or appropriate. This includes exchanging and/or jointly using information with other companies, businesses and organizations when you use our services in connection with such third parties' or their affiliates' services and/or when we facilitate the processing of your payments on other platforms or websites operated by our users, for the purpose of us and/or them investigating, preventing, or taking actions regarding suspicious or high risk transactions, illegal activities, suspected fraud or fraudulent operations connected to such other entities' businesses and/or our services, situations involving potential threats to the safety of any person, violations of our or their Terms and Conditions or this Policy, or as evidence in or otherwise connected to litigation in which we or they are involved. Yes
Aggregated and de-identified information - we may disclose aggregate or de-identified information about users for marketing, advertising, research, or similar purposes. Yes
With consumer reporting agencies, as permitted by law, with respect to users from the United States. Yes
ILATS EOOD
If you do not want us to use your details for marketing purposes, and/or to pass your details on to third parties for joint marketing purposes, please contact us through the various communication channels available, as listed under the Section titled "CONTACT US, QUESTIONS. UPDATING YOUR INFO, OPTING OUT" below. You will also be able to unsubscribe from any marketing emails sent to you by ILATS EOOD using a link provided in such emails.
We do not sell your personal information.
WHERE WE STORE YOUR DATA?
All information you provide to us is stored on our secure servers or our third-party cloud service providers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent un-authorized access.
CHANGES TO OUR PRIVACY POLICY
We keep this Policy under regular review and may update it from time to time. You will be notified of changes to this Policy via the posting of an updated version on our Website and, where appropriate, via email and/or message to "My Account". Changes will take effect upon the date on which an updated Policy is posted on our Website. We recommend that you regularly check for updates or changes to our Policy and that you review this Policy when visiting our Website. We will not materially reduce your rights under this Policy without taking steps to bring such changes to your attention.
CONTACT US, QUESTIONS, UPDATING YOUR INFO, OPTING OUT
If you are not a ILATS EOOD customer but have provided us with personal information or if your personal information was provided to us by third parties, and you would like to update your personal information, you may contact us through the phone number or email address listed below.
ILATS EOOD, UIC 206624421, Sofia, Bulgaria, 123 Knyaz Boris 1st Str.
Privacy Matters:
• For requests related to deleting your personal data or receiving a copy of your personal data, you can contact us at any time by using the email dpo@dpa.bg
• For additional queries related to privacy and personal data you can contact our Data Protection Officer at dpo@dpa.bg
GOVERNING LAW & JURISDICTION
This Policy shall be exclusively governed by and interpreted in accordance with the laws of Bulgaria, and any dispute hereunder shall be brought exclusively in the courts of the Bulgarian Sofia regional court, except where prohibited by bulgarian law.
DATA RETENTION
We retain your personal data for at least such period required in order to meet our obligations under applicable laws or regulations and, to the extent not prohibited under applicable law, such additional period in accordance with our internal policies and procedures for purposes of prevention of fraudulent activities, risk management and security.
DISCLAIMER
Any and all content provided on our Website in relation to our services or otherwise, including links to other websites is provided for information purposes only and does not constitute advice, recommendation or support of such content or website. ILATS EOOD makes every effort to provide true and accurate content on its Website. However, ILATS EOOD provides no warranty, express or implied, of the accuracy, completeness, timeliness, or applicability of such content. ILATS EOOD accepts no responsibility for and excludes all liability in connection with information provided on the ILATS EOOD website, including but not limited to any liability for errors, inaccuracies or omissions.
The information below is required pursuant to EEA/UK law regarding privacy and data protection. The terms below apply to ILATS EOOD customers (which include our EEA and UK customers and Website visitors), in addition to the terms in the rest of the Policy.
For the purposes of the General Data Protection Regulation ("GDPR"), the data controller is ILATS EOOD, a company established in Bulgaria and regulated for data protection purposes by the Data Protection Commission. If you have any questions about this Policy, please contact our Data Protection Officer (DPO) at dpo@dpa.bg
If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to the Irish Data Protection Commission (DPC) or your local supervisory authority. You can find more details about how to contact the DPC on their website https://www.cpdp.bg/
WHEN DO WE SHARE YOUR PERSONAL INFORMATION?
The table headed "Howand Why We Share Yourlnformation"in the main part of the Policy under the heading "WHEN DO WE SHARE YOUR INFORMATION?" lists who we may share your information with, which include transfers for reasons of legal compliance and necessity in order to provide you with our services.
You should be aware that when sharing your information, it can be transferred to, and stored in, countries outside the EEA or the UK, as applicable, including the USA and Israel.
Please note that where data is transferred outside of the EEA/UK, these countries may not offer the same level of protection for personal data as is available in the EEA/UK. ILATS EOOD will take various measures to ensure that your data is treated securely, which may include, but not be limited to:
- assessing the security measures taken at any place your personal data is transferred to;
- having suitable contract terms in place that oblige a data processor to only process in accordance with our instructions;
- having monitoring, reporting and resolution procedures in place with regard to ongoing security; and
- only transferring your data via an appropriate safeguard as described in Article 46 of GDPR, including Standard Contractual Clauses adopted by the European Commission (Article 46.2).
The State of Israel has been assessed by the European Commission as offering an adequate level of data protection and a copy of the adequacy decision is available here.
Please contact us at dpo@dpa.bg if you require more detailed information about international transfers of your personal information, and the safeguards applied.
ILATS EOOD
LEGAL BASES FOR PROCESSING YOUR PERSONAL DATA
We process your personal information based on the following legal bases, as recognized by and in compliance with the applicable data protection laws:
• the processing is necessary to perform our contract with you (i.e. the Terms and Conditions that apply as applicable with respect to our services, for the provision of our services), or to take steps requested by you before entering into said contract;
o you are obliged to provide us with personal data as it is necessary to enter into and perform our contractual agreements. In the event that you do not wish to provide us with your personal data for the purposes outlined above in the "HOW AND WHY WE USE YOUR INFORMATION?" section, we will not be able to perform our contractual agreement with you;
• the processing is in ILATS EOOD's or someone else's legitimate interests, and these interests are not overridden by your interests or rights in the protection of your personal data. This may include processing your data for identification or prevention of suspicious or high-risk transactions or fraudulent activity, internal research and analytics assessments, for purposes of communication with you, and informing you about new products and services we are offering or to promote new products and services of other parties which we think may be of interest to you, etc.;
o before we process your personal data to pursue our legitimate interests for the purposes outlined above in the "HOW AND WHY WE USE YOUR INFORMATION?" section, we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. On balance, we have determined that such processing is necessary for our legitimate interests and that the processing which we conduct does not adversely impact on these rights and freedoms.
• you have given your consent to the processing of your data;
• the processing is necessary to meet a legal obligation which applies to ILATS EOOD.
Sometimes we process data about you which the law considers to fall within special categories (see section "HOW, WHEN AND WHAT WE COLLECT?" for more details), in which case, we use one of the following grounds:
• the processing is necessary for the establishment, exercise or defence of legal claims;
• you have freely given your informed, specific consent to the processing; or
• the processing is necessary for reasons of substantial public interest, based on applicable law.
If you would like more information about the legal grounds used to process your information, or about the legitimate interests referred to above, please contact us.
O ILATS EOOD
In cases where we have asked for, and you have given, your consent to our processing of your personal data, you have the right to withdraw such consent at any time. You can do this by contacting our DPO at dpo@dpa.bg.
DO YOU HAVE TO GIVE US YOUR PERSONAL INFORMATION?
In most cases, providing your personal data to us is optional, however, if you do not provide it, you will not be able to use our services. For example, we need details such as your name, address and bank account details so that we can make payments to you and receive payments from you. In other cases, you have a choice over whether we collect your personal data, for example, you can turn off cookies on your browser and we will not place any cookies on your device or computer (although in this case you may not be able to use all parts of our Website).
PROFILING AND AUTOMATED DECISION MAKING
We may use automated decision making as part of our process to evaluate eligibility for the use of the ILATS EOOD services. We use these tools as a measure of fraud prevention and for the purposes of security and risk assessment relating to the performance of the ILATS EOOD services, and to verify your identity when you become a customer:
(i) Automated tools incorporated in our process of approval of your registration application: based on the information you provide, the tool may advise if additional information is required for purpose of approval of your application.
(ii) Automated tools incorporated in our process of approval of certain payment transaction of registered users: such tools may advise if additional information is required for purpose of performance of the payment transaction.
(iii) Automated tools used to verify your identity to enable us to comply with “Know Your Customer" (KYC) rules applicable to us as a financial services provider: we carry out this process using selfies (self-photographs) and other forms of ID when you register to open an account with us.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
ILATS EOOD retains your personal data for the duration of your engagement with us and for a period following termination of your engagement with us, as required by applicable laws or regulations and/or in accordance with ILATS EOOD's internal policies and procedures for purposes of prevention of fraudulent activity, risk management and security. ILATS EOOD will periodically review the necessity of retention of your personal data.
YOUR RIGHTS UNDER GDPR
You have several rights in relation to your personal data which are described in more detail below. You can exercise your rights at any time.
O ILATS EOOD
For requests related to deleting your personal data or receiving a copy of your personal data, you can contact us at any time by using our DPO email at dpo@dpa.bg
For additional queries related to privacy and personal data you can contact our Data Protection Officer at the above mentioned email.
Accessing your data
You can ask us to:
• Confirm whether we are processing your personal data.
• Give you a copy of that personal data.
• Provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it outside of the EEA/UK and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we carry out any automated decision making or profiling. We aim to give you all this information in this Policy, although if anything is unclear, please contact our Data Protection Officer at dpo@dpa.bg
You do not have to pay a fee for a copy of your personal information unless your request is unfounded, respective or excessive, in which case we will charge a reasonable amount in the circumstances. We will let you know of any charges before completing your request.
Correcting your personal data
You can ask us to correct any personal data which is inaccurate or incomplete. This is free of charge.
If we have shared the personal data with anyone else, we will tell them about the correction wherever possible.
If we cannot action a request to correct your personal data, we will let you know and explain why this is.
Erasing your personal data
This right is sometimes referred to as "the right to be forgotten". This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances.
You can ask for your personal data to be erased where:
• it is no longer necessary for the purpose for which it was originally collected or processed;
• we are processing your personal data based on your consent, and you withdraw that consent;
O ILATS EOOD
• you object to the processing and we do not have an overriding legitimate interest for continuing;
• your personal data has been unlawfully processed;
• your personal data must be erased to comply with a legal obligation;
• the personal data was processed to offer information society services to a child.
There are some exceptions to this right. If one of these applies, we do not have to delete the personal data.
If we have shared your personal data with third parties, we will tell them about the erasure of your data unless this is impossible or would involve disproportionate effort.
Please note, in connection with such requests, that personal data may be either deleted or retained in an aggregated manner without being linked to any identifiers or personal data, depending on technical commercial capability.
Restricting the processing of your personal data
You can ask us to restrict the processing of your personal data in some circumstances, free of charge. This is not an absolute right. If processing is restricted we can store the personal data and retain enough information to make sure the restriction is respected unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or for reasons of important public interest, but we cannot further process your personal data.
You can restrict the processing of your personal data in the following cases:
• if you contest the accuracy of your personal data, we will restrict processing until we have made sure the personal data is accurate;
• if you object to our processing pending the verification of whether or not our legitimate interests override your interests, rights and freedoms or in connection with legal proceedings;
• if the processing is unlawful but you do not want us to erase your personal data;
• if we no longer need the personal data but you require the data to establish, exercise or defend a legal claim.
If we have disclosed the data to a third party, we will inform them about the restriction unless it is impossible or would require a disproportionate effort. We will tell you if we decide to lift a restriction on processing your personal data.
Objecting to the processing of your personal data
You have a right to object to the processing of your personal data at any time. This request will befree of charge. It is not an absolute right, but you can object to our processing of your personal data where it is:
• based on the legitimate interest ground; or
• for the purposes of scientific/historical research and statistics.
We will stop processing your personal data unless we have compelling legitimate grounds for the processing which override your interests and rights, or unless we are processing the personal data for the establishment, exercise or defence of legal claims.
You can require us to stop using your personal data for direct marketing purposes. We will stop as soon as we receive your request. There are no exemptions or reasons for us to refuse.
Data Portability
This allows you to obtain and reuse your personal data for your own purposes across different services. It applies where the following conditions are met:
• you provided the personal data to us yourself;
• we are processing the personal data either based on your consent or because it is necessary for the performance of a contract; and
• the processing is carried out by automated means.
We will provide your personal data free of charge in a structured, commonly used and machine-readable form.
Automated decision making and profiling
You have the right not to be subject to a decision which is based solely on automated processing and which produces a legal (or similarly significant) effect on you.
We will tell you about any automated decision making that affects you. You have the right to:
• request human intervention;
• express your point of view;
• ask for the decision to be explained; and
• challenge the decision.
These rights are not absolute. We may not be able to comply with this request if the processing of personal data is:
• necessary for us to enter into or perform a contract with you;
• authorized by law (e.g. for fraud prevention) and which also lays down suitable measures to safeguard your right, freedoms and legitimate interests; or
• based on your explicit consent.
Dealing with requests to exercise your rights
We will respond to your request without undue delay at the latest within one (1) month of receiving your request unless it is particularly complicated or you have made several requests, in which case we may extend this by two (2) months. We will let you know if we are going to take longer than one (1) month in dealing with your request. If we have a lot of information about you we might ask you if you can tell us what exactly you want to receive. This will help us action your request more quickly.
For the purpose of complying with your requests to exercise the rights listed above, we shall perform the necessary internal processes to identify you.