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Globawise.com Data Privacy Policy

Last revision: February 2024

We, at Fourth Color Group, respect and value the privacy of individuals and are committed to process personal data in accordance with applicable laws. Please read this Policy so that you understand how we collect and use your personal data. If you have any questions regarding privacy data, you may contact us on our registered office address: Fourth Color LLC (FCG), company № 130480684, 15 “Tsarigradsko shose” Blvd. 1504 Sofia, BULGARIA, , or by email to our Data Protection Office via [email protected].

This Privacy Policy (“Policy”) describes how we process personal data for the purposes of conclusion, performance and execution of contracts; of recruitment and selection of employees and professionals; and of use of all our websites including globawise.com and fourthcolor.com (“Website”).

Data We May Process

Usually, we receive personal data directly by you. Anyway, in certain cases we may receive data for you from third parties, such as for instance from references, from public registers and websites, from social media for your public profiles in professional social networks, from third parties, such as recruitment agencies, our partners or customers. We may process the following types of personal data:

  • for the conclusion and performance of a contract and for recruitment purposes we may process your: names, id number and id document’s data, address, contact details including phone number and email, CV, education, professional experience and skills, work preferences and expectations, invoice, bank account, tax and social security details, references, interviews information, your public profiles in professional social networks (such as LinkedIn), business card and other relevant data. If you are a business, we will also collect personal data about your authorised representatives and how to contact them;
  • in your communication or interaction with us through any kind of contact (such as telephone, email, forms on our Website and other) we may receive and process only information you provide us, such as names, email, phone number, social network profile, CV, preferences, photos, addresses and other data you provide us;
  • when you access and use our Website we may collect and process information about your device (including, where available, your IP address, operating system, browser type, location) and how you use our Website. We may also receive cookies data and you may control your cookies preferences through your browser or our cookies tools.
Purposes of Processing

The main purpose of collecting and processing your personal data is to enter into and to perform a contract for services between us (such as to identify you, including through online profile, invoicing, payment, performance, delivery, communication, exercise of rights and obligations under the contract; etc.). We may also process your personal data for the following specific purposes:

  • to communicate with you and to provide you requested information with respect to our Website, services, projects and other opportunities;
  • for recruitment and selection purposes in recruitment campaigns;
  • to send you administrative information, for example, information regarding our Policies;
  • to send you newsletters and similar materials upon your subscription and in such case we will give you the opportunity to object receiving such messages in free and easy manner;
  • to comply with or fulfil obligations arising from law, regulations, act of the authorities or of the court, such as for the purposes of accounting, control, reporting, auditing and tax purposes;
  • for safety and security purposes, when you access our buildings or systems, or to verify accounts and activity, for protection of information, code, materials and documents;
  • to exercise our rights or protect yours, ours, third parties or public legitimate interests, such as investigation and prevention of theft, crime, fraud, misuse of services or of the Website and other offenses, to exercise rights under contracts, including before court, etc.;
  • for statistics and analysis and for the purpose to improve our products, services, procedures and policies, our Website and its functionality.
Legal Basis of Processing

When we process your personal data, we may do that on:

  • the basis that it’s necessary for the conclusion or performance of a contract to which you are party;
  • when you consent to receive newsletters or other information and materials from us. In such case you will always have the right to withdraw your consent as provided in this Policy;
  • the basis of our legitimate interest or the legitimate interests of a third party, where such interest is not outweighed by your interests or fundamental rights and freedoms
  • where that is necessary for compliance with our legal obligations, such as for instance for tax, accounting purposes or to maintain records.
Your Rights

You have the following rights with respect to your personal data and as provided under applicable laws:

  • the right to withdraw your consent at any time if we process personal data based on your consent. In the event that you withdraw your consent we will, without undue delay and to the extent provided under applicable laws, erase the relevant data from our systems;
  • right to access – at any time you may request information about the personal data we have for you and the purposes of processing;
  • right to object – in particular the right to object includes that you may object at any time to processing of your personal data which is based on: the performance of a task carried out in the public interest or in the exercise of official authority vested to us; or pursuing our or third party’s legitimate interests; or the purposes of direct marketing;
  • right to erasure, “the right to be forgotten”. You should keep in mind that this is not an absolute right and applies in accordance with applicable laws. For example, you have the right to request the deletion of your personal data if it is no longer necessary for the purposes for which it was collected or otherwise processed;
  • right to restriction of processing – this is your right to request that we limit the processing operations with your personal data as provided under applicable laws, such as for instance if you dispute the accuracy of your data;
  • right to data portability – you may request that data provided directly by you and processed by automated means by us is transferred to you or to another controller. This right only being applicable where our processing of your data is based on your consent or on a contract with you;
  • right to rectification – you have the right to ask to rectify your data if they are inaccurate;

In order to exercise your rights, you may contact us at any time by sending us an email to [email protected] or by post to our registered office. We may need to verify your identity or to contact you with respect to your requests.

In the event that you are established in the European Economic Area, you also have the right to lodge a complaint with a supervisory authority, in particular in the EEA country of your habitual residence, place of work or place of the alleged infringement. For Bulgaria, the supervisory authority is the Commission for Protection of Personal Data, having its website at www.cpdp.bg. 

Your Responsibility

When you provide us personal data, you:

  • represent that you have the authority to do so and permit us to process such data as set out in this Policy and this will not violate any rights of third parties, including the right to privacy, copyrights, related rights, intellectual property rights and other rights;
  • are encouraged not to submit us unnecessary personal data (such as for instance photos of your family);
  • shall be aware that when you contact us in our Website or social media, such as Facebook or LinkedIn, our and/or your profiles may be public and your interaction or posting may appear to be public. Please note that we do not control and assume responsibility for the use of your social media profile, account or other websites;
Recipients of Personal Data

Your personal data may be disclosed to third parties in the following ways:

  • to our customers, employees and consultants in the event it’s necessary for the particular purpose and only on need-to-know basis;
  • to our service providers who support our business and in particular such as providing us technical infrastructure services, hosting or cloud services, Website maintenance, software and product licenses, email and cloud services, payment services, professional advisers, accountants, etc.;
  • to third parties, including public authorities, if we are required to do so pursuant to applicable laws or legal, or court process, or in connection with an investigation of illegal activity or under lawful request from public or government or regulatory authorities; we may also share your data when we have a good-faith belief that this is necessary to prevent death or harm or financial loss, or in connection with an investigation of actual or suspected fraud or illegal activity, including violation of our or third party rights, such as for instance copyrights, intellectual property rights or privacy rights;
  • to public, when you make certain interactions to our Website or social network profiles;
  • to third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business.
Transfer of Data to Third Countries

In certain cases, for the purposes under this Policy we may need to transfer personal data to third countries outside the European Union, that may have different data protection laws. In such event we will transfer personal data to third country only on the basis of: (a) an European Commission decision on an adequate level of protection for that third country; or (b) appropriate safeguards, including by utilizing the Standard Contractual Clauses approved by the European Commission as amended or exchanged over time or other appropriate safeguards, including subject to specific permission of a competent supervisory authority; or (c) binding corporate rules approved by the supervisory authority. In other events we may rely on and request your consent for particular transfer to third country.

Storage Period

We will retain personal information for as long as necessary for the respective purposes of the processing and to comply with our obligations under applicable laws. In particular we may retain personal data: for 5 years regarding data for the purposes of concluding and executing a contract, provision of services and accounting and control purposes; until you withdraw your consent or object to processing when you have given us such consent; for 1 year (or less if provided by law) for data we process for safety and security reasons. The data processed with respect to other legal obligations will be retained until the respective obligation cease to apply.

Third-Party Links

Our website may contain links to third-party websites. Please be aware that we do not control and are not responsible for the content and any privacy practices of these websites. We encourage you to review the privacy policies of each site you visit.

Changes to This Policy

We may change this Policy from time to time and you may see the last revision date of this Policy at the end of the document. Where the changes in the Policy affect processing of your data on the basis of your consent, we will notify you of the new Policy and request your consent on it.

Adopted: May 2018