Capital Resource Solutions
Capital Resource Solutions Ltd. understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;
“Our Site” means this website, www.ExcluCV.com;
“Bulgaria and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and
“We/Us/Our” means Capital Resource Solutions, a limited company registered in Bulgaria under 200744061, whose registered address is 35 Trakia Str., Sofia 1504, Bulgaria.
2. Information About Us
2.1 Our Site, www.ExcluCV.com, is owned and operated by Capital Resource Solutions Ltd., a limited company registered in Bulgaria under 200744061, whose registered address is 35 Trakia Str., Sofia 1504, Bulgaria.
2.2 Our contact for data protection officer is Aneta Naydenova who can be contacted at info@ExcluCV.com or +359879 410141
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.2 Business/company name
4.3 Job title
4.4 Contact information such as email addresses and telephone numbers
4.5 IP address (automatically collected)
4.6 Web browser type and version (automatically collected)
4.7 Operating system (automatically collected)
4.8 A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible services to you. This includes:
5.2.1 Providing and managing your access to Our Site;
5.2.2 Personalising and tailoring your experience on Our Site;
5.2.3 Supplying Our services to you;
5.2.4 Personalising and tailoring Our [products and] services for you;
5.2.5 Responding to communications from you;
5.2.6 Supplying you with email Insert Type of Email e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by Insert Description of Unsubscription Method;
5.2.7 Market research for the needs of Our Company only;
5.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.
5.6 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies requires annual data review, and purchase data retention of 5 (five) calendar years, unless law stipulates any other regulatory requirements.
6.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.2.1 Encrypted data transmitting over secure networks;
6.2.2 Emails encryption;
6.2.3 Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it is securely deleted and disposed of. Hardcopies are shredded;
6.2.4 Personal data is not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
6.2.5 Personal data contained in the body of an email, whether sent or received, is stored securely;
6.2.6 All temporary files are being deleted;
6.2.7 No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested;
6.2.8 All hardcopies of personal data, along with any electronic copies stored on physical, removable media are stored securely in a locked box, drawer, cabinet or similar;
6.2.9 No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of the owners;
6.2.10 Personal data is handled with care at all times and is not left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
6.2.11 If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user locks the computer and screen before leaving it;
6.2.12 No personal data is be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
6.2.13 All personal data stored electronically is encrypted;
6.2.14 All passwords used to protect personal data are changed regularly and do not use words or phrases that can be easily guessed or otherwise compromised. All passwords contain a combination of uppercase and lowercase letters, numbers, and symbols;
6.2.15 Under no circumstances any passwords are to be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
6.3 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.1 We may share your data with other companies in Our group. This includes Our subsidiaries.
7.2 We may contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of services, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
7.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
9. How Can You Control Your Data?
9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails or by sending us a message through the contact form in the website.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access Our Site without providing any data at all. However, to use our services you will be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible services to you.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at info@ExcluCV.com, or using the contact details below in section 15.
12. What Cookies Do We Use and What For?
12.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We do not use third party Cookies on Our Site. For more details, please refer to section 5, above, and to section 12.6 below.
12.3 All Cookies used by and on Our Site are used in accordance with current Bulgarian and EU Cookie Law.
12.4 Before Cookies are placed on your computer or device, you will be shown an Insert description of prompt e.g. pop-up, message bar etc. requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; which would mean that you would have to leave our site.
12.5 [Certain features of Our Site depend on Cookies to function. [Your Country] and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
12.6 The following first party Cookies may be placed on your computer or device:
- Remembering previous actions when navigating back to a page in the same session (strictly necessary)
- Managing and passing security tokens to different services within a website to identify the visitor’s status (e.g. logged in or not) (strictly necessary)
- Routing - To route customers to specific versions/applications of a service, such as might be used during a technical migration (strictly necessary)
- Multimedia content player session cookies (such as flash player cookies) for the duration of a session (strictly necessary)
- Load balancing session cookies for the duration of a session (strictly necessary)
and the following third party Cookies may be placed on your computer or device:
- Web analytics—where the data collected is limited to the website operator’s use only, for managing the performance and design of the site. These cookies can be third-party cookies but the information must be for the exclusive use of the publisher of the website visited
- Ad response rates—where the data is used exclusively for calculating response rates (click-through rates) to improve the effectiveness of advertising purchased on a site external to the destination website. If the same cookie is used to retarget adverts on a third-party site this would fall outside the performance category
- Error management—Measuring errors presented on a website, typically this will be to support service improvement or complaint management and will generally be closely linked with web analytics.
- Detecting if a service has already been offered, such as offering a tutorial on future visits to the website.
- Fulfilling a request by the user such as submitting a comment
12.7 Our Site uses analytics services provided by Google, SerpStat, CustomerLabs. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
12.8 The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
12.9 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.10 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.11 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14. Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorised by law; or
c) You have given you explicit consent.
14.3 Where We use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
15. Contacting Us
© Capital Resource Solutions 2018 All Rights Reserved