PRIVACY POLICY

The privacy of personal data is important to Comac Trans and Comac Trans processes any personal data only in accordance with company’s  Data Protection and Privacy Policy complying with all the requirements of the local, EU, and international legislation. Herein are stated the basic terms of data processing within Comac Trans and LuxFly website. Comac Trans collects an individual’s personal data in case an individual chooses to provide it to Comac Trans and the LuxFly website. We do not share any of the personal data with third parties for their own marketing use. All personal data is collected, processed and stored according to the requirements of the REGULATION (EU) 2016/679 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, and repealing Directive 95/46/EC (General Data Protection Regulation).

Please review these Privacy Terms to learn more about how we collect, use, share and protect data online.

These Privacy Terms apply to all Personal Data, either in electronic or paper format, received by Comac Trans in the EU or a country where Comac Trans operates, outside EEA.

Personal Data is any data or set of data that identifies or could be used by or on behalf of Comac Trans to identify an Individual. Comac Trans is a data controller that processes personal data in accordance with all applicable local, EU and international legislation. Comac Trans collects personal data for operational purposes only following the GDPR and local law requirements. All personal data is collected, processed and stored in compliance with data protection laws. Personal data could be collected by Comac Trans or LuxFly website both on paper and/ or electronically Personal Data does not include data that is anonymized such that an individual cannot be identified;

An individual is any real, actually existing, person located in the European Union or a country outside ЕЕА, whose personal data is shared with Comac Trans;

Third-party is any entity different than the individual and Comac Trans/LuxFly website;

General Data Protection Regulation (GDPR) is Regulation (EU) 2016/679 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, and repealing Directive 95/46/EC.

If personal data is collected, processed and used via company’s website or in apps, the data subjects are informed of this in a privacy notice/statement and, if applicable, information about cookies.

The Privacy Notice/s and any cookie information are integrated so that it is easy to identify, directly accessible and consistently available for the data subjects. If use profiles (tracking) are created to evaluate the use of websites and apps, the data subjects must always be informed accordingly in the privacy statement.

Personal tracking may only be performed if it is permitted under national law or upon consent of the data subject. If tracking uses a pseudonym, the data subject should be given the chance to opt out in the privacy statement.

When websites or apps can access personal data in an area restricted to registered users, the identification and authentication of the data subject must offer sufficient protection during access.

 

Data collected through the Comac Trans  and LuxFly website

The LuxFly website could be visited without providing any personal data.

LuxFly automatically receives certain types of data whenever an individual interacts with us on our site. Automatic technologies and services LuxFly website uses may include, for example, web server logs/IP addresses and third-party application and content tools such as:

Web Server Logs/IP Addresses: An IP address is a number assigned to a computer whenever it accesses the Internet. All computer identification on the Internet is conducted with IP addresses, which allow computers and servers to recognize and communicate with each other. LuxFly collects IP addresses to conduct system administration and website performance reviews.

Cookies: A cookie is a piece of data that is placed automatically on an individual computer’s hard drive when somebody accesses certain websites. The cookie uniquely identifies an individual’s browser to the server. LuxFly website uses cookies.

Aggregate data: In some cases, Comac Trans may remove personal identifiers from data an individual has provided and maintain it in aggregate form. This data may be combined with other data to produce anonymous, aggregated statistical data (e.g. number of visitors, originating domain name of the Internet Service Provider), helpful to us in improving our products and services.

Security

Comac Trans and LuxFly website uses technology and security precautions, rules and other procedures to protect personal data from unauthorized access, improper use, disclosure, loss or destruction. To ensure the confidentiality of an individual’s data, Comac Trans applies suitable technical or organizational measures and safeguards can depending on the context and risks associated with the processing in question including but not only, having malware detection systems; data loss prevention systems, training employees about basic “cyber hygiene”; establishing privacy and information security management systems, obligating processors contractually to implement specific data minimization practices.

 Use of Data

Comac Trans and/or the companies we hire to perform services on our behalf or on behalf of our clients will use any personal data an individual chooses to provide to us to comply with the individual’s requests. We will retain control of and responsibility for the processing of this data in full compliance with the local law and EU requirement under the monitoring and advice of the appointed company data protection officer who is involved, properly and in a timely manner, in all issues which relate to the protection of personal data.

Data Sharing and Transfer

Comac Trans may share personal data with its clients for the purposes of performing its main activities. They are required to comply with the terms of GDPR and relevant local legislation. A transfer of personal data to a third country (outside EEA) or an international organization may take place where the EU Commission has decided that the third country ensures an adequate level of protection. In the absence of an adequacy decision Comac Trans, as a controller or processor may transfer personal data to a third country or an international organization only if it has secured appropriate safeguards, as specified by GDPR.

We may also disclose personal data to respond to appropriate requests of legitimate governmental agencies/authorities or where required by applicable laws, court orders, or government regulations.

No Third-Party Direct Marketing Use: Comac Trans will not sell or otherwise transfer the personal data provided to us at our websites or in person to any third parties for their own direct marketing use.

Privacy Terms for Children

Comac Trans does not collect any personally identifiable data from anyone we know to be under the age of 18 without the prior, verifiable consent of his or her legal representative/s. Such a legal representative/s has the right, upon request, to view the data provided by the child and/or to require its deletion.

Links to Other Sites

Comac Trans website contains links to a number of websites that may offer useful information to our visitors. This Privacy Terms does not apply to those sites. It is recommended that an individual communicates to them directly for information on their privacy policies.

Updates to Privacy Terms

Comac Trans may revise these Privacy Terms. Any such changes to this Privacy Terms will be promptly communicated on its webpage. Continued use of our sites and services provided to individuals after a posted change in our Privacy Terms indicates the individual’s consent to the use of newly submitted data in accordance with the amended Privacy Terms.

How to Contact Comac Trans

For questions or if you wish to contact Comac Trans for any data privacy-related reason, please contact us in writing (by post), as follows:

Comac Trans Ltd.

69, Bulgaria Blvd., fl.7

Tower (Building) B

1404 Sofia, Bulgaria

or by DPO E-mail: privacy@luxfly.net

or by telephone: +359 2 8921000

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