Legal Information

Cookies Policy for Axiom Translate

The website of Axiom Translate and Axiom Translate Ltd. uses cookies to provide clients and freelancers with better and personalised service.

This Cookie Policy explains what cookies are, how they are used on Axiom Translate Ltd’s website, and how you can manage their use.

What are Cookies?

Cookies are small text files that contain a small amount of information, which are sent and stored on your computer, mobile device or other access methods to our website. The HTTP cookie, usually simply referred to as a “cookie”, is a package of information, sent to a web server by an Internet browser, which the browser then returns each time it accesses the server. Cookies can contain random information, selected by the server, and then the cookies are sent back to the original site during every visit to the site or to another site that recognises these cookies. Cookies are useful, because they allow a website to recognise the client’s computer.

There are two types of cookies – permanent and temporary or “session” cookies.

Permanent cookies are stored as a file on the computer or mobile device for a longer period of time. They allow AxiomTranslate Ltd to recognise the user’s browser again at a future visit.

Session cookies are stored temporarily, while a website is being visited, but they are deleted as soon as the page is closed.

Most cookies do not contain sensitive identifiable information about personal data subjects. The purposes, for which cookies are used, are mostly for tracking the behaviour of personal data subjects with regard to the following:

• Tracking the sections of websites that are being visited;
• How much time they spend in a particular website;
• The ads they view and/or interact with;

Usually cookies are used to authenticate a registered website user as part of the login or signup process in one or more websites, so that the user is not prompted to enter a username and password with every future visit to the website(s).

Other purposes of cookies may include maintaining a shopping cart for selected goods for purchase by a particular website/websites during a session, for personalisation of the website(s), presenting different pages to different users, and for tracking the access of individual users to a particular site.

You may find more information about cookies at www.allaboutcookies.org.

Specific use of cookies on the Axiom Translate Ltd website:

Axiom Translate Ltd’s website uses cookies for various reasons. They include, but are not limited to, the following:

Functionality – these cookies store information that allows saving preferences like language, aspect ratios and settings. They are used for the benefit of the users, eg. by preventing displaying the same message twice.

Fraud protection – these cookies contain information that enables fraud protection when using the website.

Tracking – these cookies allow storing information about the way the user landed on our page. We need to know that, so we can maintain our relationships with our Partners.

Analytics – these cookies allow identifying and counting users, as well as tracking the model these users utilise to browse our website. This allows us to improve the performance of the website, eg. by facilitating users to find what they are looking for, or by providing them with the ads and information they need and simultaneously tracking the effectiveness of these ads and information.

If there are links to third-party websites on our website, it is important that you remember these websites have their own cookies and policies to manage the information you provide. If you use a third-party website, please read their cookie policy, before using the website.

How to manage cookies?

You can control and/or delete cookies at your discretion.

You can delete all cookies that were installed on your computer, or you can set up most browsers so that they do not accept cookies on your computer. In addition, you can set up your browser so that it informs you about cookie usage, so you can allow cookies only in specific cases.

In case you perform any of the above actions, it may be necessary to change the setting of some preferences each time you visit Axiom Translate Ltd’s website, and it is possible that some services and features of our website will not work.

How to delete all cookies from a specific browser (the following is information for the most popular browsers):

Modifications to our Cookie Policy

We reserve the right to modify this Cookie Policy and thus we recommend that you review its content regularly. All future modifications in our Cookie Policy will be posted on Axiom Translate Ltd’s website, effective immediately upon posting, in case nothing else is specified.

This Policy is up-to-date as of 24.05.2021.

Questions and feedback

Please send any questions and feedback about cookies or confidentiality to: info@axiomtranslate.com

Terms and Conditions for using the website

Effective as of  May 24th 2021

PLEASE READ THESE TERMS AND CONDITIONS CAREFULLY. BY USING THIS WEBSITE, YOU INDICATE YOUR ACCEPTANCE OF THESE TERMS AND CONDITIONS. IF YOU DO NOT ACCEPT THESE TERMS AND CONDITIONS, THEN DO NOT USE THIS WEBSITE. THIS WEBSITE AND THESE TERMS AND CONDITIONS ARE SUBJECT TO CHANGE AT ANY TIME WITHOUT NOTICE.

Copyright 2021 Axiom Translate Ltd. All rights reserved.

All documents and information on the Axiom Translate website are protected by copyright. Except as specifically permitted herein, no portion of the documents or information on this website may be reproduced in any form or by any means without the express written consent of Axiom Translate Ltd.

Content and Liability Disclaimer

Axiom Translate Ltd shall not be responsible for any errors or omissions contained on any Axiom Translate Ltd website and reserves the right to make changes anytime without notice. Online alias can be used and Axiom Translate Ltd shall not be held responsible with regards to any information related to online alias. Mention of non-Axiom Translate Ltd products or services is provided for informational purposes only and constitutes neither an endorsement nor a recommendation by Axiom Translate Ltd. All Axiom Translate Ltd and third-party information provided on any Axiom Translate Ltd website is provided on an “as is” basis.

AXIOM TRANSLATE Ltd DISCLAIMS ALL WARRANTIES, EXPRESSED OR IMPLIED, WITH REGARD TO ANY INFORMATION (INCLUDING ANY SOFTWARE, PRODUCTS, OR SERVICES) PROVIDED ON ANY AXIOM TRANSLATE Ltd WEBSITE, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to you.

In no event shall Axiom Translate Ltd be liable for any damages whatsoever, and in particular Axiom Translate Ltd shall not be liable for direct, special, indirect, consequential, or incidental damages, or damages for lost profits, loss of revenue or loss of use, cost of replacement goods, loss or damage to data arising out of the use or inability to use any Axiom Translate Ltd website, any Axiom Translate Ltd product or service. This includes damages arising from use of or in reliance on the documents or information present on any Axiom Translate Ltd website (including any information posted or placed by anyone other than Axiom Translate Ltd), even if Axiom Translate Ltd has been advised of the possibility of such damages.

Release of Information for Legal Reasons

We may release information concerning your use of the website as required by law and when we believe in good faith that such release is appropriate to protect our rights and/or comply with a judicial proceeding, court order or legal process served on us or the website.

Feedback Information

Any information provided to Axiom Translate Ltd in connection with any Axiom Translate Ltd website shall be provided by the submitter and received by Axiom Translate Ltd on a non-confidential basis. Such information shall be considered non-confidential and property of Axiom Translate Ltd. By submitting any such information to Axiom Translate Ltd, you agree to a no-charge assignment to Axiom Translate Ltd of all worldwide rights, title, and interest in copyrights and other intellectual property rights to the information. Axiom Translate shall be free to use such information on an unrestricted basis.

Global Programs

Information contained in this site may contain references to Axiom Translate Ltd products or programs that are not announced or available in all countries. Such references do not imply that Axiom Translate Ltd intends to announce such products, programs or services in any particular country. Consult your local Axiom Translate Ltd representative or email Axiom Translate Ltd at info@axiomtranslate.com for information regarding the products and services that are available to you. Axiom Translate Ltd’s obligations with respect to its products and services are governed solely by the license and/or service agreements under which they are provided. If you obtain a product or service from Axiom Translate Ltd from this website that is provided without an agreement, that product or service is provided “AS-IS” with no warranties whatsoever, express or implied, and your use of that product or service is at your own risk.

Links to Third-Party Sites

The Axiom Translate Ltd websites may contain links to third-party sites. Access to any website linked to any Axiom Translate Ltd website is not the responsibility of Axiom Translate Ltd and Axiom Translate Ltd is not responsible for the accuracy, or reliability of any content on such websites. Further, the presence of a link to a third-party site does not mean that Axiom Translate Ltd endorses that site, its products, or views expressed there. Axiom Translate Ltd provides these links merely for convenience and the presence of such third-party links are not an endorsement or recommendation by Axiom Translate Ltd.

Limitation of Liability

IN NO EVENT AXIOM TRANSLATE LTD WILL BE LIABLE TO ANY PARTY FOR ANY DIRECT, INDIRECT, INCIDENTAL, EXEMPLARY, SPECIAL OR OTHER CONSEQUENTIAL DAMAGES FOR ANY USE OF THIS WEBSITE, OR ON ANY OTHER HYPER LINKED WEBSITE, INCLUDING, WITHOUT LIMITATION, ANY LOST PROFITS, BUSINESS INTERRUPTION, LOSS OF PROGRAMS OR OTHER DATA ON YOUR INFORMATION HANDLING SYSTEM OR OTHERWISE, EVEN IF AXIOM TRANSLATE LTD IS EXPRESSLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Security Policy

We are concerned about privacy and endeavor to collect only as much data as is required to make your experience on the website as efficient as possible. The website has security measures in place to help protect against the loss, misuse and alteration of the data under our control. When you submit sensitive information via the website, your information is protected both online and off-line by use of Secure Socket Layer (SSL) technology. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and after we receive it. While no methods are completely secure and we cannot guarantee absolute security, we strive to use commercially accepted methods to protect your personal information. See the privacy statement disclosures relating to the collection and use of your information.

Governing Law and Jurisdiction

This Axiom Translate Ltd website is controlled by Axiom Translate Ltd from its offices in Bulgaria. All matters relating to your access to or use of any Axiom Translate Ltd website shall be governed by Bulgarian Law. Any legal action or proceeding relating to your access to or use of any Axiom Translate Ltd website shall be instituted in Pleven regional court. You and Axiom Translate Ltd agree to submit to the jurisdiction of, and agree that venue is proper in, these courts.

You may not access, download, use, or export information (including any software, products or services) contained on this Axiom Translate Ltd website in violation of Bulgarian export laws or regulations, or in violation of any applicable laws or regulations.

Trademarks

The trademarks, logos, and service marks (collectively “Trademarks”) appearing on the Axiom Translate Ltd  website are the property of Axiom Translate Ltd,. or Axiom Translate Ltd. and other parties. Nothing contained on the Axiom Translate Ltd  website should be construed as granting any license or right to use any Trademark without the prior written permission of the party that owns the Trademark. In particular, the Axiom Translate Ltd ™ logo are trademarks of Axiom Translate Ltd.

DIGITAL MILLENNIUM COPYRIGHT ACT (“DMCA”)

If you are a copyright owner or an agent thereof and believe any Content or other posted information infringes upon your copyrights, you may submit a notification of claimed infringement under the Digital Millennium Copyright Act (“DMCA”) containing the following information:

1. A physical or electronic signature of a person authorized to act on behalf of the owner of a copyright interest that is allegedly infringed;

2. Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;

3. Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled and information reasonably sufficient to permit us to locate the material;

4. Information reasonably sufficient to permit us to contact you, such as an address, telephone number, and, if available, an electronic mail address;

5. A statement that you have a good faith belief that the disputed use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and

6. A statement that the information in the notification is accurate, and made under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Our Designated Copyright Agent to receive notifications of claimed infringement is:

Axiom Translate Ltd
By E-Mail: info@axiomtranslate.com

Please send an email with DMCA as subject line/

You acknowledge that if you fail to comply with all of the above requirements of this Section, your DMCA notice may not be valid.

PRIVACY POLICY FOR PERSONAL DATA PROCESSING

Introduction

Among AXIOM TRANSLATE Ltd s top priorities is the security of personal data of physical persons — our clients and partners — which means we have taken the necessary measures to comply with the best practices and legal requirements for privacy and data protection.

This Policy aims to clarify why we collect and how we treat the information and personal data you submit to us.

This Policy applies to data, collected by AXIOM TRANSLATE Ltd with business registration number: 206082999, registered address: Boulevard Vitosha 66, 1464 Sofia, Bulgaria  (hereinafter referred to as the “Company”, “we”, or the “Administrator”), in its capacity as Personal Data Administrator. Before becoming our customer and/or using our website, please read this Privacy Policy carefully as it provides information about the way in which we process personal data and use “cookies”. We will process your data that you have submitted to us in the manner described in this Policy.

By presenting this Policy, we aim to clarify to you what information we collect about you, why and how we collect it, what your rights are under the Personal Data Protection Act (PDPA) and the General Data Protection Regulation (REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND THE COUNCIL, dated 27 April 2016, also referred to as the Regulation or GDPR).

Why we need your consent

It is our top-most priority to protect your personal data and to obtain your voluntary, informed and unambiguous consent for the processing of your personal data by Axiom Translate Ltd.

If you place a check mark next to “I read the Terms & Conditions and I agree with them”, you acknowledge that you submit your personal data voluntarily; that you are familiar with your rights under the PDPA and the Regulation (EU) 2016/679 of the European Parliament and the Council, dated 27 April 2016, also referred to as the Regulation or GDPR; and you provide us with your consent to collect, process, store and transfer your personal data to third parties for the purposes we have specified below.

Definitions

“Personal Data” shall denote any information, related to an identified or identifiably physical person (“data subject” or “user”); an identifiably physical person is a person that can be identified, directly or indirectly, more specifically through an identifier such as a name, ID number, location data, online ID or by one or more traits, specific to the physical, physiological, genetic, psychological and mental, economic, cultural or social identity of that person.

“Administrator” shall denote an agency that, on its own or jointly with other agencies, defines the purposes and means for processing personal data; when the purposes and means for this processing are defined by the law of the European Union or the law of the Republic of Bulgaria, the Administrator or the special criteria for determining the Administrator may be established in the law of the European Union or in Bulgarian law. In this case, the Administrator is Axiom Translate LLP, a company, duly registered and acting in accordance with the law of the Republic of Bulgaria, with business registration number: 206082999 , registered address:  Boulevard Vitosha 66, 1464 Sofia Bulgaria.

“Personal Data Processor” shall denote any physical or legal entity, public agency, authority or other structure, which processes personal data on behalf of the Administrator

“Processing” shall denote any operation or combination of operations, performed with personal data or a set of personal data through automatic or other means, such as: collecting, recording, sorting, structuring, storing, adapting or modifying, extracting, consulting, using, disclosing through transfer, distribution or other form of access to data, arranging or combining, restricting, deleting or destroying

“Supervisor” shall denote a European Union member-country’s independent public agency that is in charge of monitoring the observance of rules for personal data protection. For the Republic of Bulgaria, the supervisor is the Commission for Personal Data Protection.

“Specific traits” are traits, related to the physical, physiological, genetic, mental, psychological, economic, cultural, social or other identity of a person.

“Personal data register” is a structured collection of personal data, accessible through means, defined in accordance with the internal documents of Axiom Translate Ltd, which may be centralised or decentralised and are distributed in accordance with function.

“Physical person consent” is any freely expressed, specific and informed declaration of personal will, through which the physical person, to whom the personal data relates, provides unambiguous consent for the processing of this data.

"Sensitive personal data” is information for racial or ethnic background, religious beliefs, belonging to a professional body, genetic or biometric data, health status, data for sexual life or sexual orientation. This type of data is subject to specific conditions for processing.

“Data pseudonymisation” is a data protection tool that adds an extra step — a pseudonym — between the person and the information about them. This process is reversible, meaning that the information can be traced back to the person.

“Data anonymisation” is a data protection tool that separates personal information from the specific person it relates to. The process is irreversible and this type of data is not a subject of the Regulation.

“Data processing restriction” – as per the Regulation, companies and institutions only have the right to process data that is related to their business. For example, if you offer a car sharing service, you may ask for a name, address, credit card number and possibly information about the health condition of a physical person, but not information about their racial background or sexual orientation.

“Legitimate interest” is a condition for processing personal data, when the company or institution uses the data in a manner that physical persons would expect, that has minimal impact on the privacy of their personal life, or where there is undeniable justification for the processing.

“Profiling” is any form of automated personal data processing, which consists of using personal data for the assessment of specific personal aspects, related to a physical person, and more specifically, for analyzing and predicting aspects, related to the professional duties of said physical person, their economic status, health, personal preferences, interests, reliability, behaviour, location or movement. These may be the performance of work duties, economic status, health status, personal interests, behaviour, location. For example, profiling is used for assessment/refusal to issue a credit card, or for staff selection processes.

“Child” –- the Regulation defines a child as anyone under the age of 16 years; however, this may be reduced to 13 years by a member-country’s legislation. Processing the personal data of a child is only legal if a parent or guardian has given consent. In such cases, the Administrator makes reasonable effort to verify that the person in parental charge of the child has given or is authorised to give their consent.

“Personal data security breach” – a breach of security that leads to accidental or illegal destruction, loss, change, forbidden disclosure or access to personal data that are transferred, stored, or otherwise processed;

“Main settlement location” – the headquarters of the EU Administrator shall be the location in which they make the main decisions regarding the purpose and means of their data processing activities. Concerning the personal data processor, their main settlement location in the EU shall be their administrative hub. If the Administrator’s headquarters is outside the EU, they need to appoint their representative within the jurisdiction in which the Administrator operates, who would act on behalf of the Administrator and who would handle communication with the supervisors.

“Recipient” – a physical or legal entity, public agency, authority or other structure, to which personal data is disclosed, regardless of whether they are a third party or not. However, public agencies that can receive personal data within a specific investigation in accordance with the law of the Union or a member-country’s law, are not considered “recipients”; processing this data by the respective public agencies is in accordance with the applicable rules for data protection with relation to the processing purposes;

“Third party” – any physical or legal entity, public agency, authority or other body that is not the Data Subject, the Administrator, the personal data Processor or the persons, directly managed by the Administrator or the personal data Processor, who have the right to process personal data;

Purpose of this Policy

This Privacy Policy’s purpose is to guarantee that the Administrator:

1. Complies with the law in the area of data protection, more specifically the Personal Data Protection Act (PDPA) and the General Data Protection Regulation and other applicable law, and observes best practices;

2. Protects Axiom Translate Ltd ’s customers and partners;

3. Guarantees transparency regarding the ways in which subjects’ personal data are stored and processed;

4. Guarantees protection from risks, associated with data breaches.

Required Information

The information and data about you that we may require, use, and process, includes:

• Information, submitted by you through filling out forms on Axiom Translate’s website or any other information you submit to us through the website or via email;

• Records of correspondence through the website http://axiomtranslate.com/, email, phone or other methods;

• Your answers to customer polls or questionnaires that we carry out;

• Data of transactions you execute through the website http://axiomtranslate.com/, phone or other methods;

• Data about your visits to the website http://axiomtranslate.com/, including, but not limited to traffic data and other communication data.

When reasonable and when it does not infringe upon your rights and liberties, we also collect personal data from publicly accessible sources, such as Internet searches, companies and broadcast media.

Protection of Your Personal Data

Your personal data are protected not only by Axiom Translate Ltd’s high standards and the actions we have taken, but also by the Personal Data Protection Act and the Regulation. In accordance with the law, we may process your personal data, only if we have an applicable reason for that action, which may be one of the following:

• Performing under the terms of a contract, signed between us and you

• We have a legal obligation to do so

• If you have given your consent for processing

• If it is in our legitimate interest

• If it is in the general public’s interest

• If it is in your vital interest

Legitimate Interests

When we have commercial or business reasons to process your personal data, it is a “legitimate interest”. Your personal data are protected and we must not process them in a way that would be unfair to you or your interests.

If the reasons for our processing of your personal data is grounded in the existence of a legitimate interest, we will inform you about that and about what our legitimate interests are. We will also provide you with a method to send us queries or objections, should you have those. Even so, the convincing grounds for the processing of such information may override your right to an objection.

Lawfulness of Processing

Within the frame of GDPR, there are six alternative ways in which the lawfulness of a specific personal data processing case may be established. It is Axiom Translate Ltd’s policy to identify the appropriate grounds for processing and to document these in accordance with the Regulation. The options are briefly described in the following sections.

Consent

Unless required for a reason admissible under GDPR, Axiom Translate Ltd will always ask for the data subject’s explicit consent to collect and process their data. For children under the age of 18 years or persons under interdiction, consent will be requested from the parent/guardian. The subjects may exercise their rights under GDPR (request for access to their personal data, correction, restriction of processing, denial of automated profiling, omission) in a manner, established and communicated with them, in accordance with the law, free of charge and within 30 (thirty) days after submission of the request.

Performance of Contract

When the collected and processed personal data is required for the performance of a contract with the data subject, no explicit consent is necessary. This is often the case when a contract cannot be concluded and fulfilled without the relevant personal data.

Legal Obligation

If the collection and processing of personal data is required for compliance with the law, no explicit consent is necessary. This may be the case with some data, related to employment, social security, taxation, and enforcing court orders.

Data Subject’s Vital Interests

In cases in which personal data is required for the protection of vital interests of the data subject or another physical person, this may be used as legitimate grounds for processing. Axiom Translate Ltd  will keep reasonable and documented proof that this is the case when this reason is used as legitimate grounds for processing personal data. For example, this is applied in cases of significance to the general public.

Performing a Task in the Interest of the General Public

When Axiom Translate Ltd has to perform a task it considers to be in the interest of the general public or part of a business obligation, no consent will be requested from the data subject. The assessment of the interest of the general public or the business obligation shall be documented and provided as evidence, if required.

Legal Interests

If personal data processing is within the legal interests of Axiom Translate Ltd and it is considered that this does not have material impact on the rights and liberties of the data subject, this may be established as legitimate grounds for processing. Again, the arguments for this perspective shall be documented.

Privacy Right Protection

Axiom Translate Ltd has adopted the principle of privacy for its development and will guarantee that the determination and planning of all new or significant changes in the procedures for collecting or processing personal data will be subject to proper consideration of matters, related to privacy, including completing one or more assessments of the impact on data protection. The assessment of impact on data protection shall include:

• Considering how the personal data would be processed and for what purposes

• Assessing whether the proposed personal data processing is required and proportional to the purpose (purposes)

• Risk assessment for physical persons, concerning personal data processing

• What control devices are necessary for handling the established risks and for proving adherence to the law

• Using techniques such as data minimisation and pseudonymisation will be discussed, when applicable and appropriate.

Contracts Concerning Personal Data Processing

Axiom Translate Ltd warrants that all relevant relations that involve personal data processing are subject to a documented contract that includes the specific information and conditions, required by the GDPR.

International Transfer of Personal Data

Axiom Translate Ltd does not transfer personal data to other countries, including countries outside the European Union.

PRINCIPLES FOR PROCESSING YOUR PERSONAL DATA

We adhere to the following principles when processing your personal data:

1. Principle of lawfulness, good faith and transparency – this means we will process your personal data, only when we have legal grounds, in good faith and in a manner that is transparent to you.

2. Purpose restriction principle – this means that we only collect your data for specific purposes, stated explicitly below in this Policy, and we do not process data in further ways that do not comply with these purposes.

3. Data minimisation principle – this means that we only collect the amount of data that is minimally necessary for the purposes of processing.

4. Principle of correctness – we take all reasonable and available measures to guarantee the timely deletion or correction of incorrect personal data, considering the purposes for which it is being processed.

5. Storage limitation principle – we do not store data longer than the legally defined period for the Republic of Bulgaria, or the period that is necessary for the purposes for which the data is being processed.

6. Loyalty and privacy principle – we provide an appropriate level of personal data security, including protection against unpermitted or unlawful processing and accidental loss, destruction or damage, by applying the relevant and available appropriate technical or organisational measures, considering the available technology.

PROCESSING PURPOSES AND PROTECTION MEASURES

For your convenience, we provide below a clear explanation as to why we process your personal data:

1. We register our personal data;

2. For signing and performing contractual relations;

3. We collect and process personal data in order to comply with the legal and regulatory requirements, more specifically – the laws and regulations of the Republic of Bulgaria, the regulations about complying with the law and the tax and social security legislation that applies in the Republic of Bulgaria;

4. We create personal profiles upon your request, only with the attributes and personal data you have provided;

5. We carry out customer research, polls and analyses for statistical purposes, improvement of our services and increasing your satisfaction when using our services;

6. We provide you with information about our promotional offers and products and services if you have given us your explicit consent for this or if there are other valid legal grounds;

7. We monitor transactions, including when we are legally bound to collect data for the origination of funds with the purpose of preventing crimes, unusual betting, money laundering and fraud in accordance with the applicable legislation in the area of measures against money laundering and terrorism funding.

8. In other circumstances that are not mentioned above, when it is our legal obligation or when it is necessary for the protection of a legitimate interest or the interest of the general public.

If you prefer not to provide your personal data, this may prevent us from observing our legal obligations, contracts, or performing the services that are necessary for managing and supporting your account. If you do not provide us with your personal data, this might mean we are unable to provide you with our products or services.

Rules for Personal Data Management

The personal data shall be stored in such a way that the Data Subject may only be identified for as long as it is necessary for processing purposes.

When personal data is retained after the date of processing, it will be stored in an appropriate way (data is stored in specialised facilities, protected by working security systems; the access to Axiom Translate Ltd’s administrative departments is restricted with a controlled access system; external individuals are only allowed access after they identify themselves; there is a working surveillance system on the territory of Axiom Translate Ltd; the data in electronic format is stored in specialised software applications that are only accessible to the relevant individuals responsible (management staff), for whom separate access rules apply with a separate user name and password only known to the relevant individual responsible; the passwords need to be changed frequently with the purpose of achieving a higher level of data security; specialised software products are used in relation to GDPR with a high level of protection – only certain individuals with certain rights, protected with certain passwords, have access; the electronic registries are stored on a server with a high level of security; there are various procedures in place that guarantee security when processing, storing and destroying data; all computer devices have anti-virus software and firewalls installed; when software applications that contain data detect inactivity, the access to them is disabled automatically; every employee, who works with a computer device, has to input a user name and password in order to use it; data on paper are stored in a locked cabinet only accessible to the relevant individual responsible;

Regarding the information security inside the software product that is used by the finance/accounting department, the following security measures have been implemented: entry into the system with an encrypted user name and password that are sent to the server, where they are verified; the information that is exchanged between workstations and the server, is encoded; every user is assigned a specific role/s, which defines what data they can access and what operations they can execute with the system. The server is locked in a separate room; the database is backed up at planned time intervals.

Personal data shall be kept in accordance with the “Personal data management procedure”, and after the storage time frame has passed, this data has to be destroyed in a reliable manner specified in the procedure.

Axiom Translate Ltd has to give special approval for any retaining of data that exceeds the time frame, defined in the “Personal data management procedure”, which guarantees that the grounds are clearly defined and in accordance with the requirements of the legislation about data protection.

Personal data shall be processed in a manner that guarantees appropriate security (art. 24, art. 32 of the Regulation)

Axiom Translate Ltd performs or verifies impact assessments (risk assessments) by taking into account all circumstances related to the operations for managing or processing data by Axiom Translate Ltd.

When determining how appropriate processing would be, Axiom Translate Ltd also takes into account the degree of possible damage or losses that could be inflicted on physical persons (like staff or contractors) should a security breach occur, as well as any possible damage to the Administrator’s reputation, including a possible loss of trust by the contractors, suppliers, sub-contractors, users, and customers.

Accountability Principle

Regulation (EU) 2016/679 includes stipulations that encourage accountability and manageability and complement the requirements for transparency. The accountability principle, stipulated in art. 5, para. 2 of the Regulation requires the Administrator prove compliance with the other principles in the Regulation, and explicitly states this is a responsibility of the Administrator.

Axiom Translate Ltd shall prove adherence to the principles for data protection by applying policies for data protection, joining codes of conduct, implementing appropriate technical and organisational measures, adopting techniques for data protection at the planning stages, ensuring data protection by default, assessing the impact on personal data security, having a procedure for informing about personal data breaches, etc.

Addressing GDPR Compliance

The following measures have been taken to ensure that Axiom Translate Ltd complies with GDPR’s accountability principle at all times:

• The legal grounds for processing personal data are clear and unambiguous

• The entire staff involved in personal data processing understands their responsibilities for adhering to best practices for data protection

• The entire staff has been provided with data protection training

• The rules for consent and notification are observed

• The paths are available for Data Subjects who wish to exercise their rights with regard to personal data, and their queries are processed in an effective manner

• Procedures, involving personal data, are reviewed on a regular basis

• Protection of the right to personal privacy is adopted for all new or amended systems and processes

• The following documentation is recorded about processing activities:

• Name of the organisation and relevant details

• Purpose of personal data processing

• Categories of individuals and processed personal data

• Categories of personal data recipients

• Agreements and devices for personal data transfer to countries outside the EU, including details about implemented control measures

• Time schedules for personal data retention

• Existent technical and organisational control

These measures are regularly reviewed as part of the management process concerning data protection.

WITH WHOM WE SHARE YOUR PERSONAL DATA

We will use all necessary measures to make sure that the information your provide us with is stored in a reliable and safe manner.

The data, indicated above, is only provided to our trusted partners (technical suppliers of IT services) or commercial banks (when it is necessary for processing your data), for which we have ensured that they adhere to the highest standards of information security and privacy. Providing data to our partners is necessary, so that we can provide you with the services you have requested, as well as to improve the performance of our website.

We will not sell your personal data or share it with any other company for their own use without prior notification to you in writing and, when necessary, obtaining your consent.

Please note that we are bound by law and the Republic of Bulgaria’s applicable legislation to submit your data to government, administrative and judicial agencies when these agencies request us to do so.

We will submit your data to a third country or international organisation only in situation in which we are bound to do so by a stipulation of valid legislation in the Republic of Bulgaria and/or EU law regarding the warranties, provided in this legislation and/or established by the competent supervising authorities or the European Commission.

HOW LONG WE STORE YOUR PERSONAL DATA

Axiom Translate Ltd will store personal data only for the purposes, mentioned above, and only for the minimally required period of time.

When we process your personal data on the basis of your consent (eg. for direct marketing purposes) and in situations in which there are no other legal grounds for processing this data, we will discontinue processing your data if you decide to withdraw the consent you have previously given us (see more in section “What your rights are”).

If you are no longer our customer, we will only store your data for the minimal period of time required for the protection of our interests and rights and in accordance with the obligations, imposed on us by law and regulations.

Phone conversations

Phone conversations to and from our customer service department are recorded for security purposes as well as in order to serve for training and evaluation of the service you have received.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Access to Information

You have a right to access the information we store about you.

Your right of access may be used in accordance with Bulgaria’s Personal Data Protection Act and the applicable EU legislation in the area of personal data.

We will provide you with a single copy of your personal data that is being processed. For any additional copies you request, we may impose a reasonable fee based on administrative expenses, for which you will receive prior notice. The personal data you have submitted will be provided to you in a method chosen by Axiom Translate Ltd.

If you submit a request through electronic means, if possible, the information will be provided in a widely used electronic format, unless you have requested otherwise.

Please note that your right to access cannot affect adversely the rights and liberties of other persons.

Right to Correct

You have the right to request us to correct any incorrect personal data related to you. Regarding the purposes of processing, you have the right to complete any incomplete personal data, including adding on, which would be performed through your submission of corrected data.

Right to Deletion (Right of “Being Forgotten”)

You have the right to request us to delete and/or erase the following personal data of yours, if any of the following circumstances exist:

Right to Restrict Processing

1. You have the right to request us to restrict processing when any of the following grounds applies:

a) The personal data’s accuracy is being disputed by you for a period of time that allows the Administrator to verify the personal data’s accuracy;

b) Processing is illegal, but you do not want your personal data to be deleted and would rather restrict its use;

c) We do not need more of your personal data for the sake of processing, but you require the data for the establishment, exercising or protection of legal claims;

d) You have objected to processing for the period of time for verifying whether the legal grounds we have indicated override your interests.

2. When the processing is restricted in accordance with a) above, such data will be processed, excluding storage, only with your consent or for the sake of establishing, exercising or protecting legal claims and protecting the rights of another physical person or due to important reasons of interest to the general public of the European Union or a member-country.

3. When you have requested a restriction on processing as per clause 1) above, we will notify you, before the processing restriction is cancelled.

Other

It is important for you to know that you can withdraw your consent for personal data processing at any time.

If you believe your rights of data protection have been infringed upon, you have the right to file a complaint to a Personal Data protection Commission.

For questions related to your rights, or if you would like to exercise any of them, please contact us at: info@axiomtranslate.com.

For more information about your rights over your personal data, you can contact us at the email address: info@axiomtranslate.com.

AMENDMENTS TO OUR POLICY

Any future amendments we make to our Policy will be announced on our website in a timely manner and they will enter into force at the time of their posting.

If we introduce any material or significant changes to this Policy, we will make an effort to inform you through email, an announcement on the website or other means of communication previously agreed upon.

We will give you prior notice about the amendments, which will give you an appropriate period of time to review and understand the changes before they come into effect.

We will not introduce significant changes to our Policy, without having obtained your consent. If you refuse to accept the changes in this Policy, or for any other reason you do not accept the changes within the time period, we may be unable to provide some or all of our products or services.

This Privacy Policy is up-to-date as of 24 May 2021.

AXIOM Translate Ltd collects your data so that we can:

•   Process your order, manage your account.

•   Email you with special offers on other products and services we think you might like.

•  Offer you the possible customer service and support

•  Recommend related products and services

When AXIOM Translate Ltd processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.

How do we store your data?

AXIOM Translate Ltd securely stores your data at our electronic and physical premises located in various countries, including the United States of America.

AXIOM Translate Ltd will keep your data for a period of 7 years. Once our relationship has ended and this time period has expired, we will delete your data by erasing it from our electronic and physical storage.

What are your data protection rights?

AXIOM Translate Ltd would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request AXIOM Translate Ltd for copies of your personal data. We may charge you a small fee for this service.

The right to rectification – You have the right to request that AXIOM Translate Ltd correct any information you believe is inaccurate. You also have the right to request AXIOM Translate to complete information you believe is incomplete.

The right to erasure — You have the right to request that AXIOM Translate Ltd erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that AXIOM Translate Ltd restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to AXIOM Translate Ltd’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that AXIOM Translate Ltd transfer the

data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email:

Call us at: +359 88 504 0323

Or write to us: info@axiomtranslate.com

What are cookies?

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

AXIOM Translate uses cookies in a range of ways to improve your experience on our website, including:

•   Keeping you signed in

•   Understanding how you use our website

•   Collecting information to improve our services and propose relevant services

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

•   Functionality — AXIOM Translate Ltd uses these cookies so that we recognize you on our

website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

•   Advertising — AXIOM Translate Ltd uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your  
browser, device, and your IP address. AXIOM Translate Ltd sometimes shares some limited  
aspects of this data with third parties for advertising purposes. We may also share online  
data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not  function as a result.

Privacy policies of other websites

The AXIOM Translate Ltd website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

AXIOM Translate Ltd keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 24th of May 2021.

How to contact us

If you have any questions about AXIOM Translate Ltd’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: info@axiomtranslate.com

Call us: +359 88 726 2665

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that AXIOM Translate Ltd has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.

Email: kzld@cpdp.bg

Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria