Introduction
CoMantis LTD owns and operates this website www.co-mantis.com. We are committed to protect your personal data and to respect your privacy.
This privacy notice explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible data controller with whom you may exercise your rights and who to contact if you have questions or complaint.
Why and how do we process your personal data?
We process your personal data only for the following purposes:
To conduct our business and pursue our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, in particular:
to communicate with you to keep you up-to-date on the latest developments, announcements, and other information about our services and solutions (including briefings, blogs, newsletters, and other information), events and initiatives; to send you details of client surveys, marketing campaigns, market analysis, or other promotional activities;
to collect information about your preferences to personalize and improve the quality of our communications with you;
to administer and manage our relationship with you, including accounting, auditing, and taking other steps linked to the performance of our business relationship including identifying persons authorized to represent our clients, suppliers or service providers;
to analyze and improve our services and communications and to monitor compliance with our policies and standards;
to respond to your queries;
to protect the security of our communications and other systems and to prevent and detect security threats, frauds or other criminal or malicious activities;
to exercise or defend our legal rights or to comply with court orders;
statistical analysis, internal reporting and research purposes;
to investigate any complaint you make;
to provide evidence in any dispute or anticipated dispute between you and us;
to host, maintain and otherwise support the operation of our website;
for business and disaster recovery (e.g. to create back-ups); and
for document retention/storage.
Please note that we will only provide you with marketing related information when we have your consent to do so or a previous contractual relationship or a business relationship with you. You have the opportunity to opt-out at any time as explained in the "Right to withdraw consent" section of this Notice.
To fulfill a contract, or take steps linked to a contract, with you or your organization. This includes:
to register you as a client of CoMantis;
to provide and administer services or solutions, as agreed with you or your organization;
to process payments, billing and collection; and
to exercise our rights and meet our obligations.
For purposes required by law, including maintaining records, compliance checks or screening and recording (e.g. anti-money laundering, financial and credit checks, fraud and crime prevention and detection, trade sanctions and embargo laws). This can include automated checks of personal data you provide about your identity against relevant databases and contacting you to confirm your identity, or making records of our communications with you for compliance purposes.
In addition, we may use your personal data for further specific purposes made clear at the point of collection on particular pages of our website.
If you choose not to provide personal data requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfill the purpose(s) for which we have asked for the personal data. Aside from this, your visit to our website will remain unaffected.
Your personal data will not be used for an automated decision-making, including profiling, other than as described above.
How do we collect your personal data?
The circumstances in which we process personal data about you include:
when you or your organization browse, complete a form, use the chat function or make an inquiry or otherwise interact on our website or other online platforms;
when you attend our seminars, webinars or other events or sign up to receive information from us, including training;
when you correspond with us by phone, email or other electronic means, or in writing, or when you provide other information directly to us, including in conversation with our consultants, partners, suppliers and staff;
when you or your organization request information from us or use any of our online client services;
by making inquiries from your organization, other organizations with whom you have dealings, or from third party sources such as government agencies, a credit reporting agency, information service providers or from publicly available records;
when it is provided to us by a third party because you are the subject of, or your data is otherwise included in, services we are asked to provide to that third party client (for example, where we are asked to provide services to your employer);
when it is provided to us by a third party because you are the subject of, or your data is otherwise included in, services we receive from that third party client (for example, where a third party provides us a list of potential prospects and their contact details);
when you post information on social media sites if have opted to connect to or otherwise link us with social media accounts including LinkedIn and Twitter or if you send us a private or direct message via social media.
We use HubSpot as our marketing, sales, and services software that helps our business grow. We use HubSpot Forms, HubSpot Landing Pages and HubSpot Live Chat to collect your personal data.
In case of an opt-in, your data are collected via the form you have completed on our website or through the use of the chat function on our website (the forms and the chat function on our website are hosted on HubSpot servers) and subsequently automatically copied on HubSpot, stored on HubSpot servers.
On what legal ground(s) do we process your personal data?
We process your personal data, because you have given consent to the processing of your personal data for one or more specific purposes. In other cases, we process your personal information where we need to do so:
to perform a contract, with you or your organization;
to comply with our legal and regulatory obligations;
for our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms in:
responding to your queries;
providing services and/or information to you; and
our business purposes.
Which personal data do we collect and further process?
We collect and process the following personal data from you:
Identity and Contact Data, including your name, surname, business email, telephone mobile number, job title and function (if they appear on your email signature), your company name or the name of the company you work for, your interests in connection with our website and services (if you select to provide them to us and/or subscribe to our newsletter) and other personal data concerning your preferences relevant to our services;
Financial and Payment Data, including your bank account and other data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
Business Information, including information provided in the course of the contractual or client relationship between you or your organization and CoMantis, or otherwise voluntarily provided by you or your organization;
Profile and Usage Data, including your preferences in receiving marketing information from us, your communication preferences and information about how you use our websites(s), including the services you viewed or searched for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks, and mouse hovering). To learn more about our use of cookies or similar technology please check our Cookies Policy;
Technical Data, including information collected during your visits to our website(s), the Internet Protocol (IP) address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform. To learn more about our use of cookies or similar technology please check our Cookies Policy;
When we use analytic cookies, Profile and Usage Data and Technical Data (as defined above) are collected and used.
Information about other people
If you provide information to us about any person other than yourself, your employees, counter-parties, your advisers or your suppliers, you must ensure that they understand how their information will be used, and that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use it.
How long do we keep your personal data?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for CoMantis to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled.
If you want to learn more about our specific retention periods for your personal data established in our retention policy you may contact us at comantis@co-mantis.com.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations.
How do we protect and safeguard your personal data?
In order to protect your personal data, we have put in place a number of technical and organizational measures in place. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorized access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organizational measures include restricting access to the personal data solely to authorized persons with a legitimate need to know for the purposes of this processing operation.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to CoMantis staff responsible for carrying out this processing operation according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
We share your personal data, in the following circumstances:
with third party providers that we use to host, maintain and otherwise support the operation of our website such as HubSpot, Squarespace, and Google.
third parties including certain service providers we have retained in connection with the services we provide, such as consultants, companies for obtaining specialist or solutions, couriers, or other necessary entities;
if we have collected your personal data in the course of providing services to any of our clients, we may disclose it, where permitted by law, to others for the purpose of providing those services;
on a confidential basis with third parties for the purposes of collecting your feedback on our service provision, to help us measure our performance and to improve and promote our services;
with companies providing services for money laundering and terrorist financing checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared;
with courts, law enforcement authorities, regulators, government officials or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process;
with service providers who we engage within or outside of CoMantis, domestically or abroad, e.g. shared service centers, to process personal data for any of the purposes listed above on our behalf and in accordance with our instructions only;
if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets to whom we assign or novate any of our rights and obligations.
Our website provides share buttons that you can click on in order to share content from our website on social media channels, e.g., LinkedIn. We do not use these buttons to share your personal data with social media providers. When you click on a sharing button the relevant social media provider will gather personal data directly from you. Please read the privacy notice of any social media provider with which you intend to share content before clicking on the corresponding sharing button.
When we transfer your information to other countries, we will use, share and safeguard that information as described in this notice. To provide services, we may transfer the personal information we collect to countries outside of the EEA which do not provide the same level of data protection as the country in which you reside and are not recognized by the European Commission as providing an adequate level of data protection. We only transfer personal information to these countries when it is necessary for the services we provide you, for the hosting, maintaining and otherwise support of the operation of our website, or it is necessary for the establishment, exercise or defence of legal claims or subject to safeguards that assure the protection of your personal information, such as European Commission approved standard contractual clauses.
What are your rights and how can you exercise them?
You have various rights with respect to our use of your personal data:
Access: You have the right to request a copy of the personal data that we hold about you. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal data about another person, or if we are legally prevented from disclosing such information. You are entitled to see the personal data held about you. If you wish to do this, please contact us using the contact details provided below.
Accuracy: We aim to keep your personal data accurate, current, and complete. We encourage you to contact us at comantis@co-mantis.com to let us know if any of your personal data is not accurate or changes, so that we can keep your personal data up-to-date.
Objecting: In certain circumstances, you also have the right to object to processing of your personal data and to ask us to block, erase and restrict your personal data. If you would like us to stop using your personal data, please contact us at comantis@co-mantis.com.
Porting: You have the right to request that some of your personal data is provided to you, or to another data controller, in a commonly used, machine-readable format.
Erasure: You have the right to ask/require us to erase your personal data when the personal data is no longer necessary for the purposes for which it was collected, or when, among other things, your personal data have been unlawfully processed.
Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy through the courts. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here. Contact details of the Bulgarian data protection authority (CPDP) are available here and are as follows:
for complaints in person – at the CPDP’s Registry at: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592 (see location).
for complaints by post to: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Commission for Personal Data Protection (CPDP).
for complaints by fax: +3592/91-53-525.
for complaints by e-mail to the CPDP’s e-mail address. In this case, your complaint should be submitted in the form of a signed electronic document with an electronic signature (not scanned!).
for complaints via the CPDP’s website – using the electronic form provided here.
You may, at any time, exercise any of the above rights, by contacting comantis@co-mantis.com.
Right to withdraw consent
If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.
To opt-out of receiving our marketing communications, please follow the opt-out links on any marketing message sent to you or contact comantis@co-mantis.com. Opting out of receiving marketing communications will not affect the processing of personal data for the provision of our services.
If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to comantis@co-mantis.com. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Effect of this privacy notice and changes to this cookie policy
This privacy notice does not form a contract between an individual and us. The privacy notice may also be subject to change from time to time. Whenever we change our privacy notice, we will publish the updated notice on our website. Please check this privacy notice regularly. Subject to applicable law, all changes will take effect as soon as we publish the new privacy notice, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our cookie policy and may request that you agree to these changes. However, please be assured that if this privacy notice changes in the future, we will not use the personal data you have submitted to us under this privacy notice in a manner that is materially inconsistent with this privacy notice, without your prior consent.
If you do not agree to the terms of this privacy notice, please do not provide us with any personal information.
Who are we?
Your personal data is process by CoMantis LTD, a limited liability company duly organized under the laws of the Republic of Bulgaria, registered in the Commercial Register and register of NPLE under UIC 206170584, having its business seat and registered address at 110, Simeonovsko shose blvd., zh.k. Gradina, bldg. 28, fl. 1, Sofia, 1700, Bulgaria.
Contact us
If you have any concerns, questions, complaints about the processing of your personal data by CoMantis LTD, or would like to exercise your rights, please contact us at comantis@co-mantis.com.
Adopted: 05 August 2021