General information The European Union’s General Data Protection Regulation (“GDPR”), coming into effect on 25 May 2018, lays out a new set of rules for how the personal data of people living within the EU should be handled. It sets out the protection of personal data as a guaranteed right for all citizens across EU.
As a personal data processor when offering hosting services, Zetta Systems Ltd. is compliant with all the requirements of the regulation and meets the high standards “Data privacy by design and by default”. Only the required legal minimum of personal data is gathered, processed and kept secure with the appropriate technical and organizational measures.
GDPR Controller Name Zetta Systems Ltd. UIC/BULSTAT: 203161587 Seat and registered address: 111 Bulgaria blvd., Embassy Suits building, fl.7, 1404 Sofia, BULGARIA Correspondence address: 111 Bulgaria blvd., Embassy Suits building, fl.7, 1404 Sofia, BULGARIA Telephone: +359 2 437 4776 Email: [email protected]
GDPR point of contact (POC) Employee – Kaloian Parchev Telephone: +359 2 437 4776 Email: [email protected] Information about the Supervisory Authority
Commission for Personal Data Protection Name: Commission for Personal Data Protection Seat and registered address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia Correspondence address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia Telephone: +359 2 915 3518 Email: [email protected], [email protected] Website: www.cpdp.bg
Grounds for collecting, processing and storing your personal data
Art. 1. (1) Zetta Systems shall collect and process your personal data in relation to the provision of IT Support services, management and implementation of virtual or rented servers and cloud resources and the conclusion of contracts with the Company on the grounds of Art. 6, Para. 1, Regulation (EU) 2016/679 (GDPR), and in particular on the following grounds:
explicit consent provided by you as a customer; fulfillment of the obligations of Zetta Systems under contract with you; compliance with a legal obligation applicable to Zetta Systems; for the purposes of the legitimate interest of Zetta Systems. (2) Zetta Systems shall be a controller regarding your data as the User of our services. With regard to the personal data you process using our services, Zetta Systems shall act as a processor.
Purposes and principles for collecting, processing and storing your personal data
Art. 2. (1) Zetta Systems shall collect and process the personal data you provide to us in connection with the use of our services and for the conclusion of a contract with the Company, including for the following purposes:
creating a profile for full functionality in providing our services; individualization of a party to this contract; accounting purposes; statistical purposes; information security; securing the implementation of a contract for the provision of a respective service; sending information e-mails, announcements about changes in services, and recommendations to improve the use of the platform, etc.; provision of technical support via ticketing system (Zetta ServiceDesk) or call center. (2) Zetta Systems shall comply with the following principles when processing your personal data:
lawfulness, fairness and transparency; limitation of the purposes for processing; relevance with processing purposes and minimization of data collection; accuracy and age of the data; limitation of storage for the achievement of the purposes; integrity and confidentiality of processing, and ensuring an adequate level of security for the personal data. (3) When processing and storing personal data, Zetta Systems may process and store personal data to protect the following its legitimate interests:
fulfilling their obligations to the National Revenue Agency, the Ministry of Interior and other governmental or municipal authorities. What kind of personal data shall Zetta Systems collect, process and store?
Art. 3. (1) Zetta Systems shall perform the following operations with personal data and for the following purposes:
Registration of a user on the ticket system (Zetta ServiceDesk) and implementation of a contract for the provision of IT Support services, system administration, etc. The purpose of this operation shall be to create an account that is associated with the service and to allow you to manage the content of the service through the user panel. Conclusion of the Impact assessment: Based on the Impact Assessment referred to above, the Data Protection Officer considers that the ‘Conclusion of IT Support Contract’ operation is eligible and provides sufficient guarantees to protect the rights and legitimate interests of the data subjects in accordance with the requirements of the GDPR. Conclusion and implementation of a commercial transaction (deal) with a customer or a partner. The purpose of this operation shall be to conclude and implement a contract with a business partner or customer and the administration thereof. Sending information and notification e-mails. The purpose of this operation shall be to administer the process of sending notification messages to customers about service improvements, system requirements and service expiration, as stated in service contract. (2) Zetta Systems shall process the following categories of personal data and information for the following purposes, and for the following reasons:
Data: Your personalizing data (name and surname, e-mail, country, phone) Purpose for which data is collected: 1) To register the User. 2) To establish contact with the User and to send information to them. Grounds for processing your personal data. By accepting the terms and conditions and signing a contract, a contractual relationship shall be established between Zetta Systems and you, on which basis we shall process your personal data – Art. 6, Para. 1, Item (b) of the GDPR. Additional data provided by you. If you want to update your profile, you can fill in the contact details and the technical/sales contact email. Purpose for which data is collected: Updating the information in the User’s account. Grounds for data processing: By accepting the terms and conditions and signing a contract, a contractual relationship shall be established between Zetta Systems and you, on which basis we shall process your personal data – Art. 6, Para. 1, Item (b) of the GDPR. Other data that Zetta Systems shall process. When logging in to our support portal (Zetta ServiceDesk) or your account, Zetta Systems shall collect data about the IP address you use. Purpose for which data is collected: Improving security of the service and interface localization. Grounds for data processing: The data processing is necessary for the implementation of the contract by which the data subject is a party – Art. 6, Para. 1, Item (b) of the GDPR. Before the creation of the User’s profile, the IP address shall be collected on the basis of the legitimate interests of the Controller – Art. 6, Para. 1, Item (e) of the GDPR. Your invoice data. If you would like an invoice to be issued to you as an individual, you should provide us your personal ID number. Purpose for which data is collected: Issuing an invoice for payments under a contract for the provision of services for the use of products or services. Grounds for processing your personal data. By accepting the terms and conditions and signing a written contract, a contractual relationship shall be established between Zetta Systems and you, on which basis we shall process your personal data – Art. 6, Para. 1, Item (b) of the GDPR. (3) Zetta Systems shall not collect or process personal data that relates to the following:
reveal racial or ethnic origin; reveal political, religious or philosophical beliefs, or trade union membership; genetic and biometric data, health data, or data on sexual life or sexual orientation. (4) Personal data shall be collected by Zetta Systems from the persons to whom it relates.
(5) The Company shall not perform automated decision making with data.
Personal data storage period
Art. 4. (1) Zetta Systems shall store your personal data for no longer than the duration of existence of your profile in our ticketing system. Upon expiry of this period, Zetta Systems shall take reasonable care to erase and destroy all your data without undue delay.
(2) Zetta Systems shall notify you in case the storage period needs to be extended in order to achieve the purposes, the implementation of the contract, related to the legitimate interests of Zetta Systems or otherwise.
(3) Zetta Systems shall keep the personal data that they are required to keep under the applicable legislation for the required term, which may exceed the duration of your registration.
Transfer of your personal data for processing
Art. 5. (1) Zetta Systems may, at their sole discretion, transmit all or part of your personal data to personal data processors for the fulfillment of the processing purposes, subject to the requirements of Regulation (EU) 2016/679.
(2) Zetta Systems shall notify you in case of intent to transmit all or part of your personal data to third countries or international organizations.
Your rights when collecting, processing or storing your personal data
Withdrawal of consent to process your personal data
Art. 6. (1) If you do not wish all or any of your personal data to continue to be processed by Zetta Systems for a particular or for any processing purpose, you may, at any time, withdraw your consent to processing by a personal request in free text on paper at our office or by e-mail sent to our address [email protected]
(2) Zetta Systems may require you to prove your identity compared to the data subject.
(3) Your account shall become inactive if you withdraw your consent for the processing of personal data which is required for creating and maintaining your registration for the use of the services.
Right of access
Art. 7. (1) You shall have the right to request and obtain from Zetta Systems confirmation as to whether or not personal data about you is being processed.
(2) You shall have the right to access the data relating to it as well as the information relating to the collection, processing and storage of your personal data.
(3) Zetta Systems shall provide you, upon request, with a copy of the processed personal data about you, in electronic or other appropriate form.
(4) Providing access to the data shall be free of charge, but Zetta Systems shall reserve the right to impose an administrative fee in the event of recurrence or disproportionate claims.
Right to rectification or filling in
Art. 8. You can rectify or fill in the inaccurate or incomplete personal data about you directly through your support portal profile or by sending a request to Zetta Systems.
Right to erasure (‘right to be forgotten’)
Art. 9.(1) You shall have the right to request from Zetta Systems the erasure of the personal data about you, and Zetta Systems shall have the obligation to erase it without undue delay where one of the following grounds applies:
the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw your consent on which the data processing is based and where there is no other legal ground for the processing; you object to the processing of the data about you, including for the purposes of the direct marketing, and there are no overriding legitimate grounds; the personal data has been unlawfully processed; the personal data has to be erased for compliance with a legal obligation in the EU or Member State law to which Zetta Systems is subject; the personal data has been collected in relation to the offer of information society services. (2) Zetta Systems shall not be obliged to erase the personal data, if they store and process the data:
for executing the right of freedom of expression and information; for compliance with a legal obligation which requires processing by the EU or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the execution of official authority vested in the Controller; for reasons of public interest in the area of public health; for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; for the establishment, execution or defense of legal claims. (3) In order to execute your right to be ‘forgotten’, you should submit a request through e-mail or a written request sent to Zetta Systems, as well as to authenticate your identity with the person to whom the data provided to Zetta Systems relates, by presenting your ID card on site for identification purposes and, if necessary, entering your login data for the account of the person to whom the data relates, in front of an employee of Zetta Systems.
(4) Zetta Systems shall not erase the data that they have a legal obligation to store, including for protection against legal claims brought against them or proof of their rights.
Right to restriction
Art. 10. You shall have the right to request from Zetta Systems restriction of processing of data about you where one of the following applies:
you contest the accuracy of the personal data, for a period which allows Zetta Systems to verify the accuracy of the personal data; the processing is unlawful, but you oppose the erasure of the personal data and only request the restriction of their use instead; Zetta Systems no longer needs the personal data for the purposes of the processing, but you require them for the establishment, execution or defense of your legal claims; you have objected to processing, pending the verification whether the legitimate grounds of Zetta Systems override those of yours. Right to data portability
Art. 11. (1) You may, at any time, download by email request, the data about you that is stored and processed related to the use of Zetta Systems services.
(2) You can request Zetta Systems to transmit your personal data directly to another controller, chosen by you, when technically feasible.
Right to receive information
Art. 12. You may request from Zetta Systems to inform you of all recipients to whom personal data has been disclosed for which rectification, erasure or limitation of the processing has been requested. Zetta Systems may refuse to provide this information if this would not be possible or would require disproportionate effort.
Right to object
Art. 13. You shall have the right to object, on grounds relating to your particular situation, at any time, to processing of personal data about you, by Zetta Systems including profiling or direct marketing.
Your rights upon personal data security breach
Art. 14. (1) If Zetta Systems become aware of a breach in your personal data that is likely to result in a risk to your rights and freedoms, we shall, without undue delay, notify you about this breach and about the measures that have been undertaken or are to be undertaken.
(2) Zetta Systems shall not be obliged to notify you if:
they have implemented appropriate technical and organizational protection measures, and those measures were applied to the personal data affected by the personal data breach; they have taken subsequent measures which ensure that the high risk to your rights and freedoms is no longer likely to materialize; the notification would involve disproportionate effort. Persons provided with your personal data
Art. 15. The Controller shall not transfer your data to third countries.
Art. 16. In case of violation of your rights under the above or applicable data protection laws, you shall have the right to file a complaint with the Commission for Personal Data Protection as follows:
Name: Commission for Personal Data Protection Seat and registered address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia Correspondence address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia Telephone: +359 2 915 3518 Email: [email protected], [email protected] Website: www.cpdp.bg Art. 17. You may execute all of your rights to protect your personal data through appropriate public forms. Of course, these forms shall not be mandatory and you can make your claims in any form that contains a statement about it and identifies you as the data holder.
Art. 18. If the consent relates to transfer, the Controller shall describe the possible risks in the transfer of data to third countries in the absence of a decision for adequate protection and appropriate remedies.
Art. 19(1). When assigning Zetta Systems to process personal data to a third party for the purposes of using the service, Zetta Systems shall act in their capacity of a personal data processor.
(2). In the cases under Para. 1, Zetta Systems shall act only on your instruction as the User of the service and only as long as they may have control over the personal data you are processing. Zetta Systems shall have no control over the content and data that you as a service user choose to be uploaded to the service (including whether or not this data includes personal data). In this case, Zetta Systems shall have no role in the decision-making process whether the User uses the data processing service, for what purposes and whether it is protected. Accordingly, the responsibility of Zetta Systems in this case shall be limited to 1) complying with the instructions of the User of the service, pursuant to the contract and the general terms and conditions, and 2) providing information about the service and functionalities through their interface.
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What security measures have been taken in Zetta Systems’ infrastructure to keep your personal data safe? The security of every type of information, including personal data, stored on our infrastructure is a number one priority for us as a company. Security is something we just cannot afford to compromise.
With full responsibility, we declare that we have made every effort to fully comply with the new Privacy Regulation. What’s more, for added security, we use a comprehensive DDoS attack protection system based on the CloudFlare services. The DDoS security system detects 95% of the known types of DDoS attacks and is continually updated against newly registered attacks
We are at your disposal for any additional information needed!
Write us at [email protected]