This mobile application or website collects personal data only with the
knowledge and consent of the users.
If you would like more information about the data collected and the
treatment of personal data, you can read this Privacy Policy as well as the
Legal Notice and the Cookie Policy.
Basic information:
(These can be placed at the top or bottom)
Company - VIBY ltd
Address registration - Sofia, Yanko Sakazov str 20
Correspondence address - Sofia, Yanko Sakazov str 20
Phone - +359889181955
E-MAIL - viby.music.project@gmail.com
This privacy policy provides information about the processing of personal
data of our Users ("Users"), job applicants, social media users who interact
with us and users of the contact form on our website, as provided for in the
General Regulation. for data protection ("DPO").
3.1 Processed data
(a) Information provided directly by consumers:
• The information
provided by Users when creating an account on our website or in the VIBY
("Platform") application: username and email.
• The information added
by the Users of the Platform in order to be able to use the VIBY service;
i.e. email. Personal data can be viewed and edited by users in their
personal profile at any time. Consumer debit / credit card details are
provided to licensed electronic payment service providers who receive, store
and process the included data in order to facilitate the payment process for
consumers required for their orders. VIBY does not store Debit / Credit Card
Data of Users. This information is under no circumstances stored on VIBY's
servers. The debit / credit card details associated with each user's account
can be deleted at any time by the user. The service provider will then
delete the information that will need to be re-entered or selected to place
new orders through the Platform. The privacy policies of these providers may
be requested and received by users at any time.
• Any information that
the user may provide to VIBY on his own initiative for other purposes.
Examples include a photo of the user or the billing address in the case of
users who have requested to receive invoices from VIBY.
• The
information provided by users to resolve any inquiries or complaints about
the use of the platform, whether through the contact form, email or phone
through the customer service department will be available to VIBY.
•
Information on incidents involving one of the parties involved in the
provision of services through the Platform for the purpose of filing
insurance claims or performing any other actions with the insurance
companies concluded by VIBY.
b) Information indirectly provided by consumers:
- Each time users
interact with the Platform, VIBY collects data arising from the use of the
Platform.
- VIBY stores data on the device and the Application used by
users to access the services. These data are:
• The IP address used by
each user to connect to the Internet using their computer or mobile phone.
• Information about the user's computer or mobile phone, such as his
Internet connection, browser type, version and operating system and device
type.
• The complete Unified Resource Locator (URL) Clickstream,
including the date and time of access to the Platform.
• Information
about the orders made by each User, as well as feedback and / or comments
made about them by such User.
• The history and preferences of the
User's browsing.
- VIBY collects data on the source from which the VIBY
user came if the user found himself on the VIBY platform through an external
source (such as a link from another website or social network).
- VIBY
will collect the received messages in the form used by the user and may use
and store them to manage current or future incidents if the user connects to
the VIBY platform via the contact form or the VIBY telephone number.
-
To facilitate browsing by its users and for statistical purposes (for more
information on the data we collect through cookies and how to manage cookie
control, see the Cookie Policy - this link leads to the explanation of
cookies) VIBY uses its own cookies and cookies. third parties.
- VIBY
may only access personal information and data if the user has authorized
external third parties to share personal data collected by them and other
information about the user. For example, if a user creates an account
through their Facebook account, Facebook may disclose to us that user's
personal information that may be found in his / her account. Facebook
account (such as name, gender, or age), but only if the user's Facebook
account privacy settings allow sharing.
If the privacy settings of the user's browser and / or Google account allow
sharing and the user accesses VIBY through products and services offered by
Google, Google may send VIBY user's browsing data to the platform via links
created by Google.
In accordance with the third party's own privacy policy, the User may
control VIBY's access to the User's information provided by the external
third party.
- VIBY will collect user data related to their location,
including the real-time geographical location of their computer or mobile
device, provided that this is permitted by Users
Purpose of personal data processing
- To use the VIBY platform and our
services,
In accordance with the procedure described in the "Terms of Use", VIBY uses
the data collected by Users to enable them to access and communicate with
the VIBY platform and to provide the services requested by them through
their personal account on the VIBY Platform. .
- To send messages
related to the services provided,
When communicating via e-mail and / or sending Push messages related to the
operation of the service, VIBY uses the personal data of the Users.
VIBY can send Push messages on the User's mobile phone with information
related to the status of the requested order. When the order is completed,
VIBY can send an e-mail to the User summarizing the order and its price.
- To detect and investigate fraud and possible crimes
VIBY uses the information internally for statistical purposes to analyze
user behavior and trends, understand how Users use the VIBY platform and
manage and improve the services offered, including the ability to add new,
different services to the Platform. VIBY uses the information to research
and analyze how to improve the services it provides to users, as well as to
develop and improve the characteristics of the service it offers. VIBY can
monitor all actions that may lead to fraud or the commission of a crime
related to the means of payment used by consumers.
In any case, all data will be processed by VIBY for the sole purpose of the
company to carry out its fraud prevention, detection and monitoring
activities (VIBY may request users a copy of their ID card, as well as
certain debit / credit card information used for the execution of the
order), and they will be kept as long as its relationship with the consumer
remains in force, and even thereafter until the consumer's right to sue or
take legal action to pay for the products or services ordered through VIBY,
has expired. Until the incident is resolved, the data related to the used
debit / credit card will be stored for 120 days thereafter. VIBY reserves
the right to retain the data provided and to share it with the competent
authorities in order to carry out an appropriate investigation if
irregularities are found in its use, which could be considered illegal
activities. In such cases, VIBY may share the data with the authorities on
the basis of the legal obligation to prosecute actions contrary to
applicable law.
- For promotional and commercial offers (online and
offline)
VIBY may use third party technology integrated into its Platform to collect
data and user preferences and use that data with CRM systems and advanced
technology for the benefit of users with the prior express consent of users.
Therefore, the following information will be processed through the collected
information with the consent of the user:
• VIBY may evaluate and
customize advertising in accordance with the preferences of its users and
may send emails with promotional messages and / or offers related to its
service, which may be of interest to users. In the event that a VIBY user no
longer wishes to receive this information and / or commercial
communications, he / she may at any time choose to “Unsubscribe” from the
email through which this information was sent, and VIBY will immediately
stop sending the above. information.
• Users may also receive
commercial messages from third parties related to the Platform, such as
Facebook and Google as a result of using the VIBY platform. The User may
manage the receipt of such messages in accordance with the privacy
preferences set by each User on the specified platforms.
To unsubscribe from online marketing If they do not wish to receive samples
of their orders through VIBY, users can use their account privacy management
center at any time.
- For the purposes of statistical analysis and
service analysis
To analyze the behavior and trends of users, to understand how Users use the
VIBY platform and to manage and improve the services offered, including the
ability to add new, different services to the Platform, VIBY can use
information related to users and their orders, for statistical purposes.
Legal basis of the processing
The processing of consumer data is done in accordance with the following
legal bases:
• To fulfill the contractual relationship after
registration of users in the Platform (eg processing of their data in
connection with the processing of orders, for the execution of an order,
communication between the Platform, users and the site or location, etc.).
In order to fulfill our contractual and pre-contractual obligations, we may
need to process some or all of the above categories of data.
• Based on
and to protect our own legitimate interest (such as ensuring the proper
functioning and use of the Website and the Platform, monitoring to prevent
fraud through the platform, communication with users, including
electronically on important issues related to their orders , processing of
received signals, complaints, requests and other correspondence, etc.). When
carrying out activities based on a legitimate interest, it may be necessary
to process some or all of the above categories of data. In such cases of
personal data processing, we put the fundamental rights and freedoms of
users first and try not to affect them.
• To fulfill our legal
obligations (for example, when competent state or judicial authorities and /
or national regulatory authorities request information in connection with
judicial investigations and / or the submission of the necessary actions to
protect the interests of VIBY). This may require the processing of some or
all of the above categories of data.
• In order to make commercial
communications when disclosing data to third party users, we may, after
explicit consent, process personal data provided by users for marketing and
promotional purposes for voluntary participation in surveys, information
from which may be used to monitor or improve the performance of our Website
and Platform, and improve our services. In this regard, with the consent of
the User, we or our partners - third parties, may send him / her any kind of
messages through various electronic communication channels (email / SMS /
web buttons, etc.), which may contain general or specific information about
our services, promotional and other offers. To this end, some or all of the
above categories of data may need to be processed. In such cases, the data
processing we perform is within the scope provided for in the relevant
consent of the User, who may at any time manage and withdraw it in the
messages received from VIBY.
Recipients of the data
We will not disclose your personal data to any third party who does not act
in accordance with our instructions, and no communication will include
selling, renting, sharing or in any other way disclosing personal
information to customers for commercial purposes in violation of the
commitments made in this Privacy Policy. VIBY ensures that all trading
partners or independent third parties whose services and assistance we use
to achieve the above purposes for which we process personal data are bound
by contractually binding promises (data processing agreements) to process
the information shared with them in accordance with with the guidance of
VIBY, this Privacy Policy and applicable data protection law.
- When executing an order, the data or part of them to the Users can
be shared with:
• The site or place that performs the task to approve
and perform the service.
• The site or place responsible for performing
the service, if the User has requested the purchase of a service or product.
If a User contacts the above-mentioned providers directly and provides them
with their data directly, VIBY will not be responsible for the processing
and use of such data by the providers.
• Customer service services
concluded by VIBY in order to warn the User of any possible incidents
related to the services provided or to inquire and analyze why negative
feedback has been given about the service by dissatisfied Users. VIBY may
process and use the data provided to manage any incidents that may occur
during the provision of the services, including through the use of our
assistance. Artists who have undertaken to process data provided by VIBY in
accordance with VIBY guidelines, this Privacy Policy and applicable data
protection law.
• The payment platform and the payment service
providers that partner with VIBY, so that the amounts due by the users can
be charged to the respective account of the User.
• Telecommunication
service providers when used to send messages about orders or order-related
incidents.
• Providers providing satisfaction survey services on behalf
of VIBY.
- Sharing user data with third parties
VIBY may share certain personal data of Users with the following third
parties in order to continue to provide the services offered through the
Platform:
• The payment service providers with which VIBY partners are
selected according to their security measures and in any case comply with
the security measures provided for in the payment services legislation, as
they comply with PC1 according to the payment card or PCI data protection
standard. DSS. When a user enters his debit / credit card number on the VIBY
platform, it will be stored directly by the payment platforms that have
concluded a contract with VIBY, which will allow the payment to be charged
to the user's account. VIBY does not store such data under any
circumstances.
• To assess the risk of transactions, VIBY will share
user data with fraud control service providers.
• In order to prevent
the misuse of user data by third party service providers, VIBY may disclose
data of third party users who provide data anonymisation services in order
to anonymise them so that they can be used solely to provide the service to
consumers. For example, VIBY may assign e-mail to third-party users to
anonymize them and provide them in this format to providers used to perform
services agreed by users.
• VIBY may disclose personal information and
account information to its customers if it deems such disclosure necessary
to comply with the law, enforce or enforce the Platform's "Terms of Use" or
protect the rights, property or safety of VIBY, its users or third parties.
Therefore, the above includes the exchange of information with companies and
organizations involved in the field of security, information security
control and payment transactions, as well as with law enforcement and
anti-fraud and credit risk mitigation agencies. In accordance with statutory
procedures, VIBY may, upon request, share information with law enforcement
and / or legally authorized third parties regarding requests for information
related to criminal investigations and alleged illegal activities.
•
VIBY may disclose the data of the Users of companies located outside the
European Economic Area ("EEA") provided that it is authorized to do so and
take appropriate additional safeguards in accordance with the requirements
of the ORD, such as: a) access to the data will be in accordance with the
requirements and security systems established by the European Commission and
the ORD in the countries for which the European Commission has recognized an
adequate level of personal data protection and / or b) by including in the
contracts with relevant service providers standard contractual clauses
approved by the European Commission, and / or (c) by selecting service
providers that have an approved code of conduct within the meaning of the
CRPD to provide quality customer service and customer call centers and to
measure customer satisfaction and the provision of administrative support
services. The implementation of such transfers must also be in accordance
with the current guidelines and recommendations of the European institutions
responsible for the control of personal data protection with regard to the
lawful transfer of personal data to third countries.
• If a User
connects his VIBY account with other social media or a third party platform,
VIBY may process the information provided by Users of such social media or a
third party, provided that it has been provided to VIBY in accordance with
the privacy policy of the social media or third party platform in question.
• Provided that the User has given his explicit informed and
unambiguous consent to the transfer of data and is aware of the purpose and
identity of the recipient of such transfer, VIBY may transfer his personal
data to third parties related to VIBY.
• Users are informed that VIBY
will transfer their data to the acquiring organizations in order to continue
to provide the services that are subject to data processing if they own
VIBY's assets have changed or most of its assets have been acquired by a
third party. The new file (data) administrator will inform Users of their
credentials. VIBY states that it will inform Users of the change of file
administrator if and when this happens and that it will fulfill its
obligation to provide information to the relevant supervisory authority in
the event of such circumstances. This processing is carried out in
accordance with the contract concluded with VIBY and the subsequent transfer
of rights.
• VIBY may provide data to the Users of those insurers and
insurance brokers with whom it has concluded insurance or other agreement
for management and processing of claims and losses arising from the
activities carried out by VIBY and the parties cooperating with it for the
purposes of the services provided.
VIBY users' data will not be disclosed to third parties unless: (i) this is
necessary in order to provide the requested services, if VIBY cooperates
with third parties for the purposes of these services and their provision;
(ii) if VIBY has the explicit and unambiguous permission of the User; (iii)
where requested to do so by a competent authority in accordance with its
legal functions (in order to investigate, prevent or take action in
connection with illegal activities); or (iv) finally, when required by law.
Processing of Job Candidates' data related to VIBY using the forms in the
VIBY Jobs section
These clauses will apply to those who contact VIBY through their website in
order to apply for a vacancy ("Applicants").
- Administrator
Administrator
Name VIBY Ltd
Address Sofia, Yanko Sakazov 20
Phone number +359889181955
Contact email address viby.music.project@gmail.com
- Purpose
In order to consider the current or future suitability of the Applicant for
any of the available positions in VIBY, as well as to consider the
possibility of establishing a contractual relationship with the Applicant,
VIBY processes personal data of the Job Applicant. In addition, VIBY at its
discretion processes the Candidate's data for the purpose of conducting
interviews it deems necessary for the position, checking the Candidate's
knowledge, contacting companies for which he / she has previously worked,
checking the recommendations and assessing the skills and abilities of the
Applicant as a whole.
- Processed personal data of the Applicants
-
Legal basis for processing the Candidates' data
Applicants must be informed of the terms of this Privacy Policy and consent
to the processing of their data on the recruitment procedures carried out by
VIBY before submitting their application. In view of the fact that such an
examination has been requested by the applicants themselves, VIBY may also
process their data in order to examine the possibility of establishing a
contractual relationship.
- Storage of the Candidate's data
The Applicant's data will be stored during the selection process and if the
applicant is not selected, for three (3) years after the end of this
process, and the applicant may exercise any of the rights set out in point 7
of this Policy. privacy at all times.
International data transfers
VIBY may transfer User data outside the European Economic Area when
selecting service providers. In such cases, VIBY will ensure that, prior to
the transmission of the data, such service providers comply with the minimum
security standards established by the European Commission and the competent
European and national data protection authorities and in accordance with the
requirements of the DPA, and that they always process data in accordance
with VIBY instructions. VIBY has a contractual relationship with them
regarding the respective data processing, in which the service providers
agree to follow the instructions of VIBY and to introduce the necessary
security measures to protect the data of the Users.
Storage periods
During the implementation and maintenance of the contractual relationship
between the Users and VIBY the user data will be preserved; i.e. while they
are VIBY users, or while exercising their right to restrict the processing
of their data.
VIBY will retain the User's data after he / she cancels his / her
registration in the Platform, including information on past orders and
performed services, for the time established in the tax, health, criminal
and any other applicable legislation for the purposes of maintaining files
and defending any action or claim to which VIBY may be a party, as well as
the fulfillment of our legal obligations and the exercise of our right of
defense in disputes and in all proceedings. The period of storage of these
data will be 10 years, starting from January 1 of the next year of
preparation of the respective document, according to the requirements of
Bulgarian the Law on Accounting, when the personal data of the Users are
contained in accounting documents on paper or technical media, which may be
legally required by VIBY for the purposes of tax control. During this
period, VIBY will in any case block the data of the Users and will store
them in full confidentiality, so that they can be consulted only at the
request of the User and / or in order to resolve any disputes with the User
and / or third parties. in connection with the services of VIBY and / or who
need the assistance of competent authorities, institutions and persons who
have the legal authority to request the provision of personal data and have
exercised this authority properly.
In particular, but without prejudice to other applicable legislation, the
data will be retained after termination by the User, as indicated in the
table in Annex II.
• Exercise of rights
The form available in the Platform will be available to Users to exercise
their rights at any time and free of charge. They and others who may contact
VIBY through our website or the Platform may also exercise their personal
data rights by sending an application email to the following email address:
viby.music.project@gmail.com. The email in the application must indicate
which right he wishes to exercise and, where applicable, the identification
data registered on the Platform or other identification data provided by
law, as well as the preferred response format, signature subject data, date
of submission of the application and address for correspondence. If we need
additional data, in addition to those provided, we will contact the User to
confirm his identity.
With regard to VIBY, you can exercise the following rights:
• Access to
your personal data to know which data are processed and the processing
operations performed with them;
• Correction of any inaccuracies or
incomplete information regarding your personal data;
• Deletion of
your personal data where possible and for any of the following reasons: (a)
Your personal data is no longer needed for the purposes for which it was
collected or otherwise processed; (b) if you withdraw your consent on which
the data processing is based and there is no other legal basis for the data
processing; (c) if you object to the processing of personal data relating to
you, including for direct marketing purposes, and there are no overriding
legal grounds for processing; d) if your personal data has been processed
illegally; (v) Your personal data must be deleted in order to comply with a
legal obligation under EU law or the law of an EU Member State applicable to
VIBY.
• When the accuracy, legality or necessity of data processing is
in question, request a restriction on the processing of your personal data,
in which case we may retain the data for the purpose of filing or defending
claims.
• You have the right to withdraw consent at any time if the
processing of your personal data is based on your consent (as this will not
affect the processing based on your consent before withdrawal). For this
purpose you can contact us by sending a request by e-mail to
viby.music.project@gmail.com, in which case VIBY may ask you to confirm your
identity
• If there is a legal basis for this, you may object to the
processing of your data, for example you may object at any time to the
processing of your personal data for direct marketing purposes by
withdrawing your consent to receive commercial communications at any time by
the user profile of the Platform, by sending an email or by using the link
provided for this purpose in any commercial communication.
• You have
the right to request that we provide you with your personal data in a
machine-readable format for transfer to another data controller if your
personal data is processed automatically by your consent or for the purpose
of fulfilling our contractual relationship.
You can contact us if you believe that VIBY violates the data protection
law, at the e-mail address viby.music.project@gmail.com, by telling us about
the case so that we can solve the problem as soon as possible. In any case,
you can report it to the Bulgarian Commission for Personal Data Protection
and file a claim with the designated body for protection of your rights.
• Security measures
VIBY has taken the necessary steps, recommended by the European Commission
and the competent data protection authority, to maintain the necessary level
of protection of the security and confidentiality of the personal data it
processes, in accordance with the nature of the personal data processed and
the processing circumstances. avoid, as far as possible and always in
accordance with the latest technologies, their alteration, loss or
unauthorized access or processing.
• Notices and changes
This Privacy Policy, Cookie Policy and Terms of Use are subject to and
change due to the constant development of VIBY's activities. We publish all
relevant changes on our website, where you can follow regularly to stay
informed. VIBY will send users notifications of significant changes and
modifications to such documents by e-mail or other method that ensures their
receipt.