Privacy Policy

All references in this Privacy Notice to “Tzar.Tech“, “our“, “us” or “we” refer to Tzar.Tech Ltd. or our group companies and suppliers which provide services to us, as appropriate. All references in this notice to our “Website” are to the website https://www.tzar.tech. We value your privacy and want to be transparent with you in the way that we collect and use your personal information.

This notice applies to visitors to our website and people who contact us with enquiries. What this notice contains Collection of your personal information and how we use i.

When you visit our Site, we may automatically collect some basic information about you and your visit to our Site, including your internet service provider’s domain name and which pages you access on the Site, and when.

We may use this information to analyse how our Site is used and to help guide improvements to our Site to ensure that content is presented in the most effective manner for our users. We do not collect any personal information, unless you specifically provided this to us.

If you register for our email alert service, the information you may give us may include your full name and email address.

We will use this information to provide you with the services you have requested. We may also provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about. By registering for our email alert service, you consent to this use of your name and email address. You may choose not to receive future promotional, advertising, or other Site-related emails from us by selecting the unsubscribe link at the bottom of each email that we send, or you may send us an email to contact@tzar.tech.

How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

• To allow you to access and use our Website;
• To receive enquiries from you through the Website;
• For improvement and maintenance of our Website and to provide technical support for our Website;
• To ensure the security of our Website;

To evaluate your visit to the Website and prepare reports or compile statistics to understand the type of people who use our Website, how they use our Website and to make our Website more intuitive. Such details will be anonymized as far as reasonably possible and you will not be identifiable from the information collected.

If you have provided a personal email address or mobile phone number and consented or, otherwise, if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by email or post) with information about our Services which either you request, or which we feel will be of interest to you (including newsletters).

Further information on how we use personal information

Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

• To deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
• For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
• To comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
• To establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

Cookies

Cookies are small pieces of information that we store on your browser or the hard drive of your computer, which allow us to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site, for example, by detecting what kind of device you have in order to present content in the best way, for a language switch and/or for other purposes.

We use the following cookies:

• Google Analytics

Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website operators analyze how users use our Site. The information generated by the cookie about your use of our Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluate use of our Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using our Site, you agree to the processing of data about you by Google in the manner and for the purposes set out above.

You may block these cookies at any time. To do so, you can change the settings on your browser. The following links will help you to set your cookies settings on your browser:

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web and iOS

Our Legal basis for use of your personal information

We consider that the legal bases for using your personal information as set out in this Privacy Notice are as follows:

• Our use of your personal information is necessary for complying with our legal obligations; or
• We will process your personal information in some cases on the basis of your consent, including where you have provided a personal email address or mobile phone number to us and we request your consent to use these details for marketing purposes.

If we rely on your consent for us to use your personal information you may withdraw your consent at any time by contacting us at contact@tzar.tech.

Where none of the above apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are to:

• Operate our Website;
• Select appropriately skilled and qualified suppliers;
• Marketing, market research and business development;

How and why we share your personal information with others

We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of our Services to our customers, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

We will share personal information with the following third parties or categories of third parties:

• Our service providers and sub-contractors, including but not limited to, suppliers of technical, software and support services, insurers, legal advisers, logistic providers, and cloud service providers;
• Any legal, regulatory or governmental body that we are required to disclose information to;
• Companies that assist us in our marketing, advertising and promotional activities;
• Group companies, who may have access to shared databases.

Any third parties with whom we share your personal information are limited by law in their ability to use your personal information for any purpose other than to provide services for us. In addition, we take steps to ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy notice and applicable laws.

We will also disclose your personal information to third parties where it is in our legitimate interests to do so to run, grow and develop our business, such as:

• If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets; and
• If substantially all of Tzar.Tech’s or any of its affiliates’ assets are acquired by a third party, in which case personal information held by Tzar.Tech will be one of the transferred assets;
• If we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, any lawful request from government, regulator or law enforcement officials or prevent illegal activity;
• In order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party or to prevent any illegal activity; or
• To protect the rights, property, or safety of Tzar.Tech, our staff, our customers or other persons.

Except as expressly set out above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent.

How long we store your personal information

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. We only hold personal information for marketing purposes for 10 months after the latter of the date we acquired it or our last communication with you. Aside from this, the length of time for which we retain personal information for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Your rights

You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at contact@tzar.tech at any time. You have the following rights:

Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area (“EEA“).

Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.

Right to delete your information. You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us. We will pass your request on to other recipients of your personal information unless that is impossible or involves disproportionate effort.

Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. We will pass your request on to other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are.

Right to stop marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.

Right to data portability: You have a right to ask us to provide your personal information to a third- party provider of services. This right only applies where we use your personal information on the basis of your consent or performance of a contract and where our use of your information is carried out by automated means.

Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). It may be necessary to ask you to verify your identity.

Certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

Marketing

We will collect and use your personal information for undertaking marketing by email. We will always obtain your consent to direct marketing communications where we are required to do so by law (for example, if you have provided a personal email address to us) and if we intend to disclose your personal information to any third party for such marketing.

We will send you certain marketing communications (including electronic marketing communications to existing customers), which may include content offers, surveys event details, where it is in our legitimate interests to do so for marketing and business development purposes.

If you wish to stop receiving marketing communications, you can do this by clicking the “unsubscribe” link at the bottom of any email from us, or by contacting us by email at contact@tzar.tech.

Where we may transfer your personal information.

Your personal information may be used, stored and/or accessed by staff operating outside of the European Economic Area (EEA) working for us, other members of our group or suppliers. If we provide any personal information about you to any such non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy notice. These measures may include:

• In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome);
• In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them; or
• The transfer is necessary for the performance of a contract with you (e.g., to implement a payment instruction).

Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting us by email at contact@tzar.tech at any time.

How we keep your personal information secure

Tzar.Tech is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organizational and technical measures.

In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information between you and us over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information while it is transmitted in this way and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.

Where we have given you (or where you have chosen) a password which enables you to access our app, you are responsible for keeping this password confidential. We require you not to share a password with anyone.

Social media and links to other websites

Our Website includes social media features, such as the Facebook, Twitter, Instagram or LinkedIn “sharing” or “follow” buttons; and may contain links and pages to other websites operated by third parties.

Please note that this privacy notice applies only to the personal information that we collect through our Website and Services and we cannot be responsible for personal information that third parties may collect, store and use through third party features and websites. You should always read the privacy notice of each website you visit carefully.

Changes to our privacy notice

We may update our privacy notice from time to time. Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy notice.

Further questions or how to make a complaint

If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact contact@tzar.tech, Tzar.Tech Ltd., whose registered office address is at 16 Blaga Dimitrova, 1505, Sofia, Bulgaria. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.