Privacy Policy – GDPR

General

1. Please read this document carefully. It contains the User Personal Data Protection Policy (the “POLICY”) and is an integral part of the Terms of Use (the “TERMS”).  If you do not agree with the TERMS, you will not be able to use the WEBSITE.
2. Amendments to the POLICY will be posted here.
3. In view of providing the Services (the SERVICES) on the www.actauni.com (the WEBSITE), IDEIN LTD with UIC 117630912, with headquarters and registered office at: Bulgaria,  Ruse,  Druzhba 3,  N. Y. Vaptsarov St. 11, performs personal data processing (Data subjects/USERS) in compliance with the present POLICY.
4. In the processing of personal data, IDEIN LTD  shall comply with all applicable data protection regulations, including, but not limited to, Regulation (EU) 2016/679 (the “Regulation”).
5. According to the Regulation, personal data is any information pertaining to you and through which you can be identified.  Personal Data Processing (“Processing”) is any action or a set of actions that may be performed in relation to personal data by automatic or other means.

II. Groups of Data Subjects

In connection with the SERVICES provided, IDEIN LTD  processes information concerning the following Data Subjects:

1. USERS – natural persons using the WEBSITE, with registration;
2. USERS – natural persons using the WEBSITE, without registration;
3. USERS – natural persons who have made inquiries (including by calls), requests, alerts, complaints or other correspondence to IDEIN LTD ;
4. USERS – natural persons, information about whom is contained in inquiries (including by calls), requests, alerts, complaints or other correspondence addressed to IDEIN LTD .

III. Data processed in connection with the provision of the Services

1. Information submitted by USERS: USERS decide by themselves whether and in what manner to use the SERVICES provided through the WEBSITE. The forms through which personal data are submitted shall clearly indicate the mandatory or voluntary nature of the data submission.  The mandatory data are data without which the provision of the respective SERVICE or part of it is impossible.
2. Registration / Building a User profile: the use of some of the SERVICES is only possible after registration of the user. To create individual User Profile, the USER shall enter:  User profile type, given and family name, email address and password. In addition to that, information about the registration and agreement with the TERMS (date, time and IP address) is stored.
3. Data stored in the User profile: Except for the mandatory data needed to create a user profile, the USER decides whether and what additional data related to him/her  he/she should submit in compliance with the WEBSITE functionality.
4. Uploading a picture in the User profile depends completely on the USER’s discretion.  The saved picture can be seen by all other WEBSITE users.
5. In order to resolve complaints, alerts, disputes, inquiries, requests or other questions communicated to IDEIN LTD , received via electronic forms on the WEBSITE, by telephone calls, by regular mail or e-mail, IDEIN LTD  shall store and processes such information as well as the result of that processing.
6. The services of IDEIN LTD  and the functionalities provided on the WEBSITE are not intended to store or process any special categories of data in the meaning of Art.  9 and  Art. 10 of the Regulation.
7. The USER undertakes not to store or transmit via the WEBSITE, in any form, information containing specific data categories and sensitive data such as: data revealing his/her racial or ethnic origin, political views, religious or philosophical beliefs, union membership, genetic data, biometric data, health status, sexual life or sexual orientation; data related to his/her convictions and violations, identity documents or personal identification number, passport / ID number, etc.
8. IDEIN LTD  has no responsibility to and does not monitor the presence of the data under Art.  6 and 7 on the WEBSITE. The provision of such information is entirely the risk and the responsibility of the person providing it.
9. The USER should not store any of the above data in the user profile, neither should he/she send such data to other users through the functionality of the WEBSITE.
10. IDEIN LTD  may process additional data related to the USER in cases where the USER voluntarily provides such data by filling in relevant electronic forms on the WEBSITE, adding preferences, settings, etc.

IV. Data related to the process of Service use

1. Remembering a logged-in user (automatic login): a functionality enabling the remembering of a logged-in user is implemented in the WEBSITE. The functionality refers to a specific device and is activated by the USER by ticking the “remember me” checkbox.  The functionality is disabled when logging out, as well as by unchecking the “remember me” checkbox.
2. Logs related to security, technical support, development, etc.  Logs with the following purposes are used in the WEBSITE: to ensure the reliable functioning of the SERVICES and to identify technical problems; to ensure the security of the SERVICES and detect malicious actions; journals where required by law (such as electronic statements logs).
3. Account logging log: this log enables identification and automatic blocking of unauthorised attempts at access to accounts. It is maintained for a period not longer than 1 (one) year;  it contains login date and time, the status, whether login was via mobile version, application or desktop browser, IP address.
4. Cookies:  The functioning of the WEBSITE requires the use of cookies.  A detailed description of the cookies used and their purpose can be found in the Cookie Policy.

V. Personal data processing purposes

1. IDEIN LTD  collects, uses and processes the information described above for the purposes set out in this POLICY and in the TERMS and CONDITIONS for the use of the SERVICES, which may be:
   1. For the purposes of conclusion and implementation of the contract between the USER and IDEIN LTD  for the provision of the SERVICES;
   2. For the purpose of protection and enforcement of the legitimate interests of other users of the SERVICES, third parties and IDEIN LTD ;
   3. Purposes for which the USER has given his/her explicit consent;
   4. For the purpose of enabling IDEIN LTD  to perform their legal responsibilities.
2. Contract conclusion and performance: this purpose is related to the steps that should be taken for a contract between the PROVIDER and the USER to be concluded and performed, including the data processing needed to do the registration, create a user profile, and the activities concerning the provision of the SERVICES accessible via the WEBSITE.   Furthermore, such purposes include the communication with the USER, including email that is needed in order to provide the SERVICES and/or inform the USER about any changes of the provided SERVICES.  For that purpose, it may be necessary to process part of or all data categories mentioned above.
3. Legitimate interest:  purposes related to the legitimate interests of IDEIN LTD  and / or third parties such as others. Such purposes include:
   1. to ensure the proper functioning and use of the WEBSITE by the USER and by other users, the maintenance and administration of the SERVICES, the settlement of disputes, the identification and prevention of harmful actions.
   2. to identify and resolve technical problems or problems related to functionality.
   3. to communicate with the USER, including via email, on important matters concerning the SERVICES.
   4. To receive and process alerts, complaints, requests and other correspondence;
   5. To effect and protect the rights and legitimate interests of IDEIN LTD , including in court, and assist in exercising and protecting the rights and legitimate interests of other users of the WEBSITE and / or third parties concerned.
   6. For that purpose, it may be necessary to process part of or all categories mentioned above.
4. Legal responsibilities:  the purposes related to IDEIN LTD  fulfilling their statutory obligations include the fulfilment of  their statutory obligations to retain or provide information upon receiving an order from any competent state or judicial authorities, while making sure that such competent state authorities  are able to exercise their supervisory powers, and the fulfilment of IDEIN LTD ‘s legal obligations to notify the USER about different circumstances related to the USER’s rights, the provided SERVICES or the protection of the USER’s data, etc.  For that purpose, it may be necessary to process part of or all categories mentioned above.
5. Explicit consent:  the USER’s data may be processed on the basis of his/her explicit consent; the processing in such case being specific and to the extent and scope provided for in the respective consent.

VI. Retention period

Regarding data retention, IDEIN LTD  applies the general principle of retaining data in the smallest quantity for a period not exceeding the time needed for the provision of the SERVICES, while ensuring their safety and reliability, and observation of the legal requirements:

1. Registration data (such as name, surname, e-mail address) and information on the registration and agreement with the TERMS (date, time, IP address):  for the whole duration the profile on the WEBSITE and not longer than 1 (one ) year after termination of the registration.
2. Language preference data: throughout the active USER session.
3. Login log (contains logon date and time, status, whether logon is via mobile version, application or desktop browser, IP address):  for not longer than 1 (one) year of latest logon or until the USER account is closed.
4. System logs (may contain information such as:  date and time, IP address, URL, browser and device information: for a period not longer that 1 year.
5. Correspondence, complaints and alerts, requests, incoming phone calls:  correspondence data, complaints and alerts are retained for not longer than 5 (five) years.  Data for incoming telephone calls are retained for not longer than 1 (one) month.
6. In case of a legal dispute or proceedings requiring the retention of data and / or a request from a competent public authority, it may be possible to retain data for longer than the specified periods until the final settlement of the dispute or proceedings with all authorities involved.
7. These retention periods may be modified in case a different requirement to retain information is established under the effective regulations.
8. Backup.  In order to guarantee and ensure the reliability of the SERVICES and to prevent data loss for technical reasons, a back-up policy is in place on the WEBSITE. The longest update period (including data deletion) of all backups is 7 (seven) days.

VII. PROVIDING INFORMATION

1. IDEIN LTD  does not provide any personal user data to third parties in any other way but as described in this POLICY, the CONDITIONS and the cases as arranged by the law.

2. USER’s personal data may be provided to third parties only in the following cases:

1. if arranged by the law;
2. if duly requested by a competent public authority;
3. when we have received the explicit consent of the USER
4. where necessary for the protection of the rights and legitimate interests of IDEIN LTD  and / or other SERVICE users.
5. In case of change of ownership such as merger, acquisition or sale of assets affecting personal data processing, the USER will be notified in advance.
6. With regards to personal data under the Regulation, the USER’s rights are as follows:
   1. the right of being informed: the present POLICY aims to inform the USER in detail about the processing of his/her personal data in connection with the SERVICES provided
   2. The right of access: The USER has the right to receive confirmation whether his/her personal data are processed; to have access to them, and to be informed regarding their processing and the USER’s rights concerning such data. Such access is possible any time using the functionalities provided for that purpose.
   3. Right of correction: The USER has the right to correct his/her personal data if incomplete or inaccurate.
   4. Right of erasure: The USER has the right to request the erasure of data, except when there is a substantial reason and / or legal obligation to process them.
   5. Closing a profile: if desired, the USER has the possibility to close his / her profile at any time through the functionality provided for that purpose.
   6. Right of limitation concerning data processing: The Regulation provides for the possibility of limiting personal data processing by the USER, if there are grounds for it provided for therein.
   7. Right to notify third parties: where applicable, the USER has the right to ask the Administrator of his/her personal data to notify the third parties when he/she has provided such data in connection with correcting, erasing or limiting the processing of USER’s personal data.
   8. Right of data transfer: The USER has the right to receive the personal data that he/she has provided and that relate to him/her, in a structured, popular machine-readable format, and to use such data for another administrator at the discretion of the USER.
   9. The right not to be the subject of a decision based solely on automated processing involving profiling, which entails legal consequences for the USER or similarly affects him/her to a significant degree, unless there are grounds for this under the applicable personal data protection legislation and appropriate guarantees are provided for the protection of the rights, freedoms and legitimate interests of the USER: technologies falling into this category are not used when providing the SERVICES on the WEBSITE.
   10. Right of consent withdrawal: The USER has the right to withdraw at any time his / her consent for the processing of personal data performed on the basis of his / her consent: such withdrawal does not affect the lawfulness of processing on the basis of the given consent prior to the moment of withdrawal. In the case of services such as subscription to e-mail advertisements, the subscription to which is based on the USER’s consent,  a possibility is provided to terminate the subscription any time (consent withdrawal).
   11. Right of objection: The USER has the right to object to data processed on the basis of legitimate interest.  In case such objection is received, IDEIN LTD  will consider the request of the USER and, if justified, will fulfil it. If it is considered that there are convincing legal grounds for processing, or that it is necessary in order to establish, exercise or defend legal claims, IDEIN LTD  will inform the USER about this.
   12. Right of complaint to a supervising authority The USER has the right to file in a complaint with a supervising authority in case he/she believes that the processing of personal data concerning him/her infringes the applicable legislation on personal data protection. The Supervisory Authority in the Republic of Bulgaria is the Commission for the Protection of Personal Data, with the following address: Sofia 1592, Prof. Tsvetan Lazarov Blvd. 2.
   13. Information accuracy: IDEIN LTD  is not responsible for the accuracy of data provided by the USER, neither does IDEIN LTD  perform any inspection in this aspect, or guarantee the actual identity of the natural persons submitting such data. Whenever the USER  has any suspicions, or has identified a fraud and/or violence, the USER shall immediately inform IDEIN LTD . The USER, when providing whatever information on the WEBSITE, shall not infringe in any way whatsoever anybody else’s rights regarding personal data protection or any other of their rights.
7. Contact information:

IDEIN LTD, UIC 117630912
Address: Bulgaria, Ruse 7000, Zaychar Str. 9
Tel. + 359 82 831183
E-mail: office@idein.eu
The present POLICY was last updated on 14.10.2020.

Cookies Policy

To make ActaUni working properly, we sometimes place small data files called ‘cookies’ on your device.

What are cookies?

A cookie is a small text file that a website stores on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

• First-party cookies are cookies set by the website you’re visiting. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies.
• Persistent cookies are cookies that are saved on your computer and are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you leave your browser.

Every time you visit the Platform, you will be prompted to accept or refuse cookies.

Cookies can also be used to establish anonymized statistics about the browsing experience on our sites.

How do we use cookies?

ActaUni mostly uses ‘first-party cookies’. These are cookies set and controlled by Idein LTD, not by any external organisation.

However, to view some of our pages, you will have to accept cookies from external organisations.

You can delete or block these cookies, but if you do that some features of this site may not work as intended. These cookies are used to remember:

• your display preferences, such as browsing language, contrast colour, font size, device used, search results preferences and notification preferences;
• your latest visit to the website (for statistical purposes) and the three most recent pages visited (to help our helpdesk if you send a request);
• if you have agreed (or not) to our use of cookies on this site.

Visitor preferences

These are set by us and only we can read them. They remember if you have agreed to (or refused) this site’s cookie policy.

Operational cookies

There are some cookies that we have to include in order for certain web pages to function. For this reason, they do not require your consent. In particular:

• authentication cookies ;
• technical cookies required by certain IT systems.

Authentication cookies

These are stored when you log in to ActaUni, using our authentication service (ActaUni Login). When you do this, you accept the associated privacy policy.

The names of these cookies may change, for technical reasons.

Technical cookies

Analytics cookies

We use these purely for internal research on how we can improve the service we provide for all our users.

The cookies simply assess how you interact with our website — as an anonymous user (the data gathered does not identify you personally).

Also, this data is not shared with any third parties or used for any other purpose. The anonymized statistics could be shared with contractors working on communication projects under contractual agreement with Idein LTD.

However, you are free to refuse these types of cookies —via the cookie banner you’ll see on the first page you visit.

Third-party cookies

Some of our pages display content from external providers, such as YouTube, Facebook and Twitter.

To view this third-party content, you first have to accept their specific terms and conditions. This includes their cookie policies, which we have no control over.

But if you do not view this content, no third-party cookies will be installed on your device.

Third-party providers on ActaUni

These third-party services are outside of the control of IDEIN LTD. Providers may, at any time, change their terms of service, purpose and use of cookies, etc.

Private data

The cookie-related information is not used to identify you personally and the pattern data is fully under our control. These cookies are not used for any purpose other than those described here.

How can you manage cookies?

You can manage/delete cookies as you wish

Removing cookies from your device

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited.

Be aware though that you may also lose some saved information (e.g. saved login details, site preferences).

Managing site cookies

For more detailed control over site cookies, check the privacy and cookie settings in your preferred browser.

Blocking cookies

You can set most modern browsers to prevent any cookies being placed on your device, but you may then have to manually adjust some preferences every time you visit ActaUni. And some services and functionalities may not work properly at all (e.g. logging in to your profile).

• I accept cookies
• I refuse cookies (*) (except the one that remembers this choice)
• I refuse all cookies (*) (in this case you will see our cookie banner each time you come to our website)

(*) You can only refuse cookies that are not strictly necessary. Some cookies are strictly necessary in order to enable you to use this website. Without these cookies, we will not be able to provide certain features.