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Privacy Policy

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally identifiable information' (PII) is being used online. PII, as used in information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

Your privacy is important to:

ETN Host Ltd  (hereinafter “ETNHost”). ETNHost is therefore pleased to provide this privacy
statement to inform you of Our's practices with respect to the collection and use of your personal information (“Personal Data”).

The legal entity which has the role as data controller is:

Name: ETN Host Ltd.
Company Number: 203180452
Company VAT Number: BG203180452
Address: E. Georgiev Str 1
City: Plovdiv
Country: Bulgaria

The Data Protection Officer is:
Name: Andrei Uzunov
ETN Host's Jurisconsult
Address: E. Georgiev Str 1
City: Plovdiv
Country: Bulgaria

The Official Regulatory Institution is:
Name: European Data Protection Supervisor
Site: https://edps.europa.eu/
 

COMPLIANCE WITH INTERNATIONAL DATA PROTECTION LAWS , IN PARTICULAR THE GDPR

ETN Host complies with international data protection laws, in particular the Regulation 2016/679/EU of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”). ETN Host has implemented the following requirements under the GPDR, including but not limited to:

- A record of our Personal Data processing activities.
- Adequate organizational and technical protection measures (more information can be found in this privacy statement).
- A Data Processor Agreement in our role as data controller and data sub-processor.

THE WAYS ETNHOST COLLECTS INFORMATION ABOUT YOU IN HIS ROLE AS DATA CONTROLLER

ETNHost may collect your Personal Data when:

- You order a service from ETNHost and / or this site.
- You participate in a ETNHost survey.
- You subscribe to ETNHost newsletter.
- You ask ETNHost for more information about a ETNHost service, or contact ETNHost with a question, comment or complaint.
- You submit an abuse notification to ETNHost.
- You already use some of ETNHost's services.

WHAT KIND OF INFORMATION ETNHOST MAY COLLECT ABOUT YOU IN OUR ROLE AS DATA CONTROLLER

ETNHost may collect the following information about you:

- Your name, (business/private) address, phone number, date of birth, email address and personal identification numbers.
- Your ETNHost account information – such as ETNHost services you ordered, domain name registration information, the IP addresses used to access your service with us, your customer ID, service charges owed and received, the use of ETNHost services or any other information related to your account.
- Your contact with ETNHost – such as a note or recording of a call you make to ETNHost, a chat record when you engage in a chat session with ETNHost, an email or letter you send to us or other records of any contact you have with ETNHost.
- Information about your payment method, bank account number or other banking information. All data like this is collected by ETNHost as Data controller, but is stored and processed by our Partner Payment Gateways in accordance and with the full protection instated by GDPR act.
- Information provided by you to ETNHost when you notify ETNHost of a (suspected) breach of ETNHost’s acceptable use policies.
- Documents and information that certify your identity.

REASONS FOR DATA PROCESSING BY ETNHOST AS A DATA CONTROLLER

ETNHost processes your Personal Data for the following purposes:

- Processing of orders and provision of services.
- Conducting market research, conducting retention and customer satisfaction surveys, conducting marketing activities (including through email newsletters, social media and onsite/offsite and online/offline advertisement), conducting sales activities (including analyzing your Personal
- Data and your use of ETNHost services for making (personalized) offers and quotes with the aim of entering into a customer relationship, and/or maintaining, renewing or expanding a customer relationship) and offering promotional prepositions.
- Communicating with customers:
  * to provide information about services of ETNHost;
  * to provide information about offers, orders, provision of services, order status and payment;
  * to provide support and maintenance services;
  * to handle complaints;
  * to answer questions from (potential) customers.
- Performing financial processes, including:
  * for calculating, invoicing and collecting of service charges;
  * for processing financial transactions regarding the acceptance of orders;
- Investigating and processing suspected violations of ETNHost acceptable use policy.
- Ensuring the security of persons, goods and objects, and performing fraud detection.
- Conducting legal processes, including:
  * conducting legal proceedings;
  * collecting evidence for civil legal proceedings relating to you;
- Complying with statutory obligations, including: 
  * provision of data to authorized authorities in the context of criminal investigations;
  * complying with (applicable) data retention obligations;
  * the provision to third parties of Data concerning customers in connection with an infringement of these third parties’ rights.
 

SHARING YOUR PERSONAL DATA WITH THIRD PARTIES IN OUR ROLE AS DATA CONTROLLER

ETNHost may share Data about you with:

- Partners or agents involved in delivering the services you’ve ordered with ETNHost.
- Domain name registries when ETNHost registers a domain name on your behalf.
- Law enforcement agencies, regulatory organisations, courts or other public authorities to the extent required by law.


 

ETNHost AS SUB – PROCESSOR

Personal Data hosted, transmitted or processed by ETNHost's CUSTOMERS on infrastructure, ordered by the CUSTOMERS as part of their services with ETNHost, is govern  by this paragraph.
 
The customer of ETNHost that has ordered a service with ETNHost, will be responsible for determining the purposes and means of theprocessing of Personal Data on the infastructure used by the ordered service, and this ETNHost customer (or its customers) will be the data controller in regards to such processing. If at any time ETNHost has access to personal data stored on infrastructure ordered by an ETNHost customer as part of his service, then ETNHost shall be a data sub-processor, and any actions performed by ETNHost in relation to such data shall be solely governed by the agreement concluded between ETNHost and its customer.

RETENTION PROCEDURES

ETNHost will store your Personal Data as long as necessary to perform the purposes of processing as stated in this privacy statement.
 

LEGAL GROUNDS

To process your information as described above, we rely on the following legal bases:

Performance of a contract: the use of your information may be necessary to perform the contract that you have with us. For example, if you use our services, we will use your information to carry out our obligation to complete and administer that service under the contract that we have with you.

Legitimate interests: the processing is necessary for the purposes of the legitimate interests pursued by us, namely for information security. We also want to provide you with the best suitable content of the website, emails and newsletters, to improve and promote our products and services and the content on our website, and for administrative, fraud detection and legal purposes.

TECHNICAL AND ORGANISATIONAL SECURITY PROCEDURES AND DATA TRANSFERS

In accordance with international data protection laws, in particular the GDPR, we observe adequate procedures to prevent unauthorized access to, and the misuse of, Personal Data. We use appropriate business systems and procedures to protect and safeguard the Personal Data. We also use
security procedures and technical and physical restrictions for accessing and using the Personal Data. Only authorized personnel are permitted to access Personal Data in the course of their work. 
ETNHost has implemented the following, but not limited to, generic information security measures across its organisation: next generation firewalls, anti-virus software, encrypted communication via SSL or VPN, security awareness training, segregation of duties, role-based access permissions (based on least-privilege), tools to enable employees to work secure (such as password managers), physical security zones. Per application or communication, additional security measures can be implemented.
Because we are a global company with customers located in many different countries around the world, it is important that we comply wtih data privacy laws in many jurisdictions.

YOUR RIGHTS

In accordance with data protection laws, you have a number of rights regarding your Personal Data and the processing thereof:

You can view and, if necessary, change your Personal Data in your account at any time.
If you wish to know what information ETNHost have collected about you.
If you want to make changes to the Personal Data in your account.
You also have the right to obtain from us the erasure of your Personal Data (right to be forgotten).
In addition, you may, under certain circumstances, have the right to restriction of the processing of your Personal Data.
You have the right to object, on grounds relating to your particular situation, at any time to processing of your Personal Data.
You have the right to receive your Personal Data, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller when the processing is based on your consent or is necessary for the performance
of a contract.
If you have any requests regarding the above mentioned, please contact us using the contact details below. If we do not grant your request, we willinform you about the reason why.

CONSENT AND WITHDRAWAL OF CONSENT

You are entitled to withdraw your consent at any time by giving us notice. Upon receipt of a notice where your consent is withdrawn, we will without
undue delay stop processing your Personal Data to the extent it is required under law. Please use the contact information in this page should you wish to withdraw your consent given under this privacy statement.

STATEMENT CHANGES


ETNHost reserves the right to change the privacy statement, and will post any revisions on the ETNHost website www.etnhost.com. ETNHost advises you to check this page regularly to see if any changes have been implemented.

CONTACT INFORMATION

If you have any requests, questions or suggestions about ETNhost’s privacy practices, please send an email to [email protected]
ETNHost Ltd., a private limited liability company, incorporated under the laws of Bulgari and with its office at E. Georgiev 1, Plovdiv 4000, Bulgaria, listed with the Chamber of Commerce under number 203180452.
This privacy statement was most recently changed on 22 May 2018.

Do we use 'cookies'?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We use cookies to:
• Help remember and process the items in the shopping cart.
• Understand and save user's preferences for future visits.
• Keep track of advertisements.
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.

We may also use trusted third party services that track this information on our behalf. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies. If users disable cookies in their browser: If you disable cookies off, some features will be disabled It will turn off some of the features that make your site experience more efficient and some of our services will not function properly. However, you can still place orders over the telephone by contacting customer service.

Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Google

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en We use Google Analytics on our website. Google, as a third party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy. We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

We will notify the users via email as soon as possible and we will also notify the users via in site notification as soon as possible.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

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