Policy for Use and Protection of the Information on the WiFi.bg / Advifi.com Website (“Policy”)
Provision of any information or content by a User is voluntary and subject to the Terms of Use, an integral part of which the present Policy for use and protection of information is (hereinafter referred to as “the Policy”).
1. What information do we collect, how and for what purposes do we use it?
1.1. User Information ( in its capacity of Wi-Fi Hotspot or Wi-Fi Advertiser )
WiFi.bg is entitled to collect and use information about the Users. The information by which the User can be identified may include names, location, email address as well as any other information the User has voluntary entered or provided when using the Services on the WiFi.bg Website (accessible via the various WiFi.bg domains operated by WiFi.bg).
In the registration form filled in by the User when concluding the contract WiFi.bg clearly indicates the mandatory or the voluntary nature of provision of data and the consequences of refusal for such provision. By agreeing with the Terms of Use and the present Policy the User agrees that the User information may be processed as provided therein.
Provision of personal data identified as mandatory for provision in the respective electronic registration forms on the WiFi.bg Website is necessary for the User’s registration and therefore for the User’s access to the services which require registration. Its non-provision is an obstacle for the successful registration completion or grounds for termination of the respective registration unilaterally by WiFi.bg as provided in the Terms of Use.
Beyond the above information, WiFi.bg has the right (but not the obligation) to automatically save certain information that a computer or other User’s terminal device sends to the WiFi.bg’s Servers in connection with the User activity. The information shall be stored in log files on WiFi.bg’s Servers and may include information about Web Pages on the WiFi.bg Website visited by the User, websites that have forwarded the User to the WiFi.bg Website, websites visited by the User through Links on the WiFi.bg Website, date and time of these visits, the User IP address, the type of Internet browser the User uses, the number of users who have seen a banner on the WiFi.bg Website, the number of clicks on the banners on the WiFi.bg Website, etc. This information is not connected to the information that identifies the individual User and shall be used for impersonal research and tracking of the User’s behaviour, habits and interests, to analyze the efficiency of advertising, for statistical purposes and to improve the offered Services. This information can be processed and stored by WiFi.bg in a personalized form together with other information about the User, provided by the User during the registration or use of the Services. In addition, WiFi.bg collects log files (date, time and respectively source – IP addresses) when required by applicable law, as well as log files and any other information necessary to reproduce electronic statements made by the User when using the Services (for example acceptance of the Terms of Use, etc.) and for identification of the User in the event of a dispute.
1.2. Publicly accessible content. User Content
The User Content (containing or not personal data), which the Registered User publishes on the Website, as well as any information which the latter provides when using the Services (such as names, location, e-mail, photos, telephone numbers, date of birth, information about profiles in social networks, etc.), are password-protected on the WiFi.bg Website.
For the avoidance of doubt, WiFi.bg does not have any purpose to collect, use, preserve or process in any other way personal data or any other information which is subject to special protection according to the existing legislation, through the User Content posted by the Registered User on the WiFi.bg Website, nor does it follow the existence of such information on it. Posting User Content or any personal data or other information which it contains, or in any other way, when the User uses the Services it is entirely at their own risk and responsibility. By accepting the Terms of Use and the present Policy, the User declares that he/ she is informed, accepts and agrees that all information (including personal data) included in the User Content, published by him/ her or in his/ her User Account, as well as the events indicated by the User as such that he/ she will take part in, and the Place Pages the User follows will be publicly accessible for every User of the WiFi.bg Website, as well as for the third persons to whom WiFi.bg provides access to this User Content or information according to what is foreseen in the Terms of Use and in the present Policy. The User also declares and guarantees that when publishing the User Content or any other information he or she does not violate the rights of any third persons in relation to their personal data or any other personal rights, including that he or she has already received their consent for such publishing (as far as such is necessary according to the existing legislation).
WiFi.bg collects and uses the information under Para 1.1 for the purposes stipulated in the Terms of Use and in the present Policy such as providing the Services, assuring the User’s access and control of his or her User Account, fulfilment of its obligations under the law, exercising and protecting of his or her legally protected rights and legal interests, the offering of goods and/or new services, offered by third persons, for promotions, request organizing, inquiries and surveys and for statistical purposes.
1.3. Invitation to a friend
The Registered User has the opportunity to send through their User Account an invitation to the e-mail of third persons (friends) so that they register on the WiFi.bg Website. The Registered User can send an invitation to third persons (friends) also through the Facebook Connect service which gives access to the publicly-accessible information from this third person’s user account on Facebook. When sending an invitation in any of the above mentioned manners, the Registered User declares and assures that they have received the preliminary approval of those persons (friends) to reveal their e-mail addresses and other data that could be revealed when sending the invitation, for the purpose of sending such invitation. The people who have received a “friend invitation” through the manner described above can refuse to register on the WiFi.bg Website.
1.4. Services connected to third parties
WiFi.bg may allow third parties, such as Facebook, Inc., to publish on their websites publicly available content from Place Pages of the WiFi.bg Website. Such content may not include personal data and shall be only limited to information regarding legal entities.
In certain Web Pages of the WiFi.bg Website, share buttons may be visualized for sharing the User Content with other especially indicated websites. By using such buttons, the User agrees and at his/her own discretion personally presents the User Content (including any possible personal or other information that may be contained therein) to be shared with the respective website. When using such sharing buttons the User shall be considered informed that he/she shares his/her User Content with third parties that are not under the control of WiFi.bg and that may be located and may perform their activities outside Republic of Bulgaria, or even outside the EU and the EEA. The present Policy shall not apply to the User Content thus shared by the User, and respectively the collection, storage, protection and processing of such information shall be subject to the terms and conditions of those other websites.
1.5. Cookies
The WiFi.bg has the right (but not the obligation) to install on the User’s computer or other terminal device cookies – small text files which are preserved on an Internet page through Internet Server on the User’s hard drive and give the opportunity to recover information about the User as they identify the sites/pages used by his or her terminal device and/or browser.
When providing the services WiFi.bg preserves information and receives access to the information saved on the User’s terminal device and processes it in order to:
1.5.1. secure the User’s normal and quality access to the Services with all their functional possibilities;
1.5.2. check for the presence of scripts, software applications and settings of the User’s terminal device necessary for the normal access and use of the Services and notify him or her about the lack of them;
1.5.3. trace and prevent multi-accounting (registration and use of many User Accounts by the same person) and malicious actions;
1.5.4. visualize and non-visualize elements from the WiFi.bg Website which have specific requirements compatible or non-compatible with certain features, qualities or options of the User’s terminal device (for example: screen width, resolution and others);
1.5.5. adjust the Services and secure automatic showing or hiding of different elements of the WiFi.bg Website in accordance with the User’s preferences and settings;
1.5.6. advertise and research of the Users’ preferences.
The cookies used by WiFi.bg do not preserve information (personal data) which enables the identification of the User as a natural person. It is aimed only to identify the used by the User browser and/or terminal device.
The User has the right at any time to reject the preserving and/or the access to the information saved on the terminal device used by the User.
The prohibition and/or the erasing of cookies by the User can lead to full or partial impossibility of the User to access the WiFi.bg Website and/or the Services, to change or remove the previously set by the User preferences on the WiFi.bg Website and/or to considerably worsen the quality of the Services for which WiFi.bg does not take responsibility.
WiFi.bg uses two types of cookies – “temporary” (which are erased from the User’s terminal device memory when the User closes the Internet browser) and “permanent” (which are being kept on the User’s terminal device until he or she erases them). The permanent cookies can be removed by the User following the instructions of the Internet browser used. The cookies used by WiFi.bg contain an identification number which helps in the identification of the User.
Cookies can be installed also by third persons in order to advertise goods and services which may be of interest to the User at the time of his or her visit on the WiFi.bg Website and other websites visited by him or her. WiFi.bg does not have access to or control over the use of these cookies. These cookies also collect information about the way of usage of the WiFi.bg Website, such as which website redirected to the WiFi.bg Website, which Internet pages the User visited on the WiFi.bg Website, information about the User’s visits on other websites but do not collect information such as names, e-mail addresses, other information concerning contacts or other personal data which could give the opportunity to a third person to identify the User and get into contact with him or her.
2. Whom do we share your information with?
2.1. Public content
WiFi.bg has the right to distribute and provide the publicly-accessible content on the WiFi.bg Website, including any User Content, logos, to persons related to WiFi.bg, its business partners and any other third persons, and the Users understands and agrees that those third persons might publish that User Content on their Websites or media platforms. They must point the User as source of the relevant User Content and show and refer to the publicly-accessible information on his User Account such as names and photos.
2.2. Persons who process the data on behalf of WiFi.bg (Data Processors)
In order to perform technical support and administration on the WiFi.bg Website and in the processing of the information for statistic and marketing purposes when performing tests and probes on the work of the WiFi.bg Website, when making payments and using other services related to the WiFi.bg Website, personal data and other information about the User can be revealed to and processed by third persons to which WiFi.bg has assigned the performance of particular services connected to the WiFi.bg Website. Thеsе data will be revealed and respectively processed only to the extent and volume necessary for performing the assigned job. Accordingly, those third persons will act as data processors on behalf of WiFi.bg. Data processors shall be aware that information in their possession is subject of the legislation for the protection of individuals regarding the processing of personal data.
These persons will be obliged to process the data only and solely under the strict instructions of WiFi.bg and will not have the right to use or process in any other way the personal data of the Users for other purposes, except for the purposes specified in the Terms of Use and the present Policy.
2.3. Direct marketing
With the acceptance of the Terms of Use and the present Policy the User agrees with the processing of his/her personal data for the purposes of direct marketing. The User has the right at any time to object to the subsequent processing of his or her personal data for the purposes of direct marketing, by sending a written notice to WiFi.bg to the specified contact address or e-mail. The User has the right to be informed before revealing his/her personal data to third person for the first time or using it on their behalf for the purposes of direct marketing and to be given an opportunity to object to such reveal and use.
With the acceptance of the Terms of Use and the present Policy the User declares that he/she has been informed and has expressed his/her consent for his/her personal data to be provided and revealed by WiFi.bg to other data controllers for the purposes of marketing and advertising on the territory of the Republic of Bulgaria and in countries out of the European Union, when in compliance with the provisions of the Bulgarian Personal Data Protection Act and other applicable foreign laws, if the case. The User has the right at any time to withdraw his or her consent for the subsequent provision of his personal data to third persons in the manner described previously in the present article.
2.4. Revealing personal data
WiFi.bg undertakes not to reveal any personal data and other User information or about his or her use of the Services and not to reveal the collected data to third persons – authorities, companies, individuals and other, except:
2.4.1. when this is stipulated in this Policy or in the Terms of Use or when the User has given his explicit consent in the moment of the registration or later;
2.4.2. when this is necessary for the execution of a legal obligation of WiFi.bg;
2.4.3. when the information has been required by state authorities, judicial authorities or officials, which according to the existing law are competent to require and collect such information in accordance to the legal procedures and rules;
2.4.4. when the revealing of personal data by WiFi.bg is necessary for protection of the rights, legal interests and reputation of WiFi.bg, related to WiFi.bg persons or the Users;
2.4.5. when the information is revealed to employees or subcontractors of WiFi.bg for activities related to administration of the WiFi.bg.com and to the use of the services;
2.4.6. in other cases specified by law;
3. How we secure your information? What rights do you have?
3.1. Policy concerning people less than 14 years of age
The WiFi.bg Website is not targeted to people less than 14 years of age. WiFi.bg does not aim to collect and process personal data concerning people less than 14 years of age. In case an under 14-year-old person has submitted his or her personal data without the consent of his/her parents and/or guardians, the latter should inform WiFi.bg immediately.
3.2. Security
WiFi.bg takes the due diligence for collecting, preserving and processing the personal data of the Users, in good faith, for the well settled and expressed purposes and in compliance with Bulgarian Personal Data Protection Act and other applicable foreign laws, if the case. In this respect, WiFi.bg shall take all proper technical and organizational measures to protect the personal data belonging to the Users against accidental or illegal destruction, loss, modification, disclosure or unauthorised access.
WiFi.bg takes the due diligence and is responsible for the protection of the User’s personal data obtained during the provision of the Services, subject to the Terms of Use unless in cases of: force majeure, chance events or malicious actions of third persons and in cases when the User himself or herself has made this information accessible to third persons.
3.3. Rights concerning the personal data
Except for the above, accepting the Terms of Use and the present Policy the User confirms that he or she is familiar with the rights provided by the Bulgarian Personal Data Protection Act and other applicable foreign laws (if the case) including, but not only:
3.3.1. general right to be informed about all indications/references regarding data protection and processing that WiFi.bg is obliged to provide, ex-oficcio or upon Users’ request, according to applicable legislation in force.
3.3.2. right of access to his or her personal data processed by WiFi.bg;
3.3.3. right to correct and update his or her personal data processed by WiFi.bg;
3.3.4. right to ask for his or her personal data to be deleted,or blocked when it is not processed in accordance with the present Policy, the Terms of Use and the applicable laws in force;
3.3.5. right to require WiFi.bg to inform the third persons to whom it has revealed the personal data about any obliteration, correction or blocking of the data except for the cases when it is not possible or it is connected with excessive effort by WiFi.bg;
3.3.6. right to oppose, at any moment, free of charge and without reasons, for that data concerning him/her to be processed for direct marketing purposes, by or behalf of WiFi.bg or by a third person or to be disclosed to third parties for such purposes, according to applicable legislation in force;
3.3.7. right to take action before a competent court in order to defend any rights granted by the applicable laws.
Each Registered User can correct and update his/her personal data, preserved by WiFi.bg, through his/her User Account.
The User can exercise his or her rights in this article, except the right under Art. 3.3.7, by sending a written demand to WiFi.bg dated and signed and complying with any other legal requirement of form provided by applicable laws in force. The User can exercise his/her rights concerning his or her data himself or herself or by an authorized person (with a notary certified power of attorney).