It is Abalta’s policy to comply with all applicable privacy and data protection laws, including the General Data Protection Regulation, Regulation (EU) No. 2016/279 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”) and the California Consumer Privacy Act of 2018 (“CCPA”). This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, and others who share their data with us.
1. Data Controller
2. What Data We Collect About You
Personal data means any information about an individual from which that person can be identified, directly or indirectly. It does not include data where the identity has been removed (anonymized data), which we can use for any purpose. Some jurisdictions may consider your Internet Protocol (IP) address to be personal data. We may collect different kinds of personal data about you which we have grouped together as follows:
- Identity or Contact Data includes app-instance ID, advertising ID (IDFA on iOS and ADID on Android), Internet Protocol (IP) address or similar identifiers. When you contact us about WebLink® services by email or phone or through our Data Subject Request Form or contact us form, we may also collect your first name, last name, and your contact information, such as email address and phone number.
- Communication Data includes your comments through our Website’s contact us page.
- Data Automatically Collected from WebLink Host Application users and Website Visitors includes usage details, IP addresses, device information, language information, and other information collected through cookies. We may also collect certain demographic data such as your age range, gender and interests, collected through Google Analytics for Firebase (WebLink Host Application) or Google Analytics (Website). For more details, please see the Automatic Data Collection section.
- Device Data includes the device’s hardware information, operating system, platform information, browser type, language information, and the device’s language setting.
- Usage Data includes information about how you use WebLink service.
- Location Data includes your geolocation information, including the country/city you reside in. We do not collect your precise location.
We do not collect any special categories of sensitive personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, and precise geolocation data). Nor do we collect any information about criminal convictions and offenses.
3. Reason for Processing Your Personal Data
Abalta may process the personal data you provide for the following reasons and legal bases:
|Why we process your data
||Legal basis for processing
|To respond to your comments, requests, questions and inquiries that you submit by email or phone or through our Data Subject Request Form or our Website’s contact us form.
|To communicate with you about your comments, requests, questions and inquiries provided by email or phone or through Data Subject Request Form or our Website’s contact us form.
|To provide WebLink® service.
||Performance of a contract with you
|To improve and develop WebLink® services.
|To provide and improve our Website.
|To market products and services that are of interest to you.
|To administer surveys and conduct research
||Consent or legitimate interest based on its stated goals (where no sensitive personal data is in scope)
|To allow you to exercise your data privacy rights.
||Necessary to comply with our legal obligation
In addition, we may process your personal data for the following reasons:
- To carry out our obligations and enforce our rights.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
We may use information that is not personal data for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on WebLink® service and our Website.
4. How We Collect Your Personal Data
We use different methods to collect information from and about you including through:
We also use Google Analytics for Firebase and Firebase Crashlytics, services provided by Google LLC (collectively, “Firebase Services”). Firebase Services use an app-instance identifier – a randomly generated number that identifies a unique installation of a mobile app, advertising identifiers (IDFA on iOS and ADID on Android) and similar identifiers. In addition to these identifiers, Firebase Services collect and send to Google LLC device data, IP address, app usage data and app crash logs. The data collected by Firebase Services are exported to and stored in BigQuery, another Google service. The data collected is used to analyze how you use WebLink® services and your demographic data and to improve and develop WebLink® services.
For more information about how Google uses information from WebLink Host Application, please visit https://www.google.com/policies/privacy/partners/.
You may opt-out of certain Firebase features through applicable device settings. For details, please visit https://thenai.org/opt-out/mobile-opt-out/.
Our Website use
- Automatic Data Collection on our Website. Our Website uses automatic data collection technologies to distinguish you from other Website users. This helps us deliver a better and more personalized service when you browse our Website. It also allows us to improve our Website by enabling us to:
- Estimate our audience size and usage patterns.
- Store your preferences, so we may customize our Website according to your individual interests.
- Recognize you when you return to our Website.
Our Website does not currently respond to or honor “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers.
5. How We Use Your Personal Data
We may use your personal data to:
- Communicate with you. This may include: (i) informing you of Abalta’s products, services, and promotional activities that may be of interest to you; (ii) responding to your questions or inquiries, including customer service requests; (iii) responding to your privacy inquiries, and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.
- Provide and improve our website, products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) developing new websites, products, and services.
- Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal processes; (iv) detecting, preventing, and responding to fraud or intellectual property infringement claims, violations of our contracts or agreements, violations of law, or other misuse of our website, products or services; and (v) protecting the Abalta’s rights or property, or yours or others’ health, safety, welfare, rights, or property.
Abalta may also use your personal data for other uses consistent with the context in which the data was collected or with your consent.
Abalta may anonymize or aggregate any of the data we collect and use it for any purpose, including research and product development. Such data will not identify you individually.
6. Disclosure of Your Personal Data
- Abalta may share your personal data between Abalta Technologies Inc. and Abalta Technologies, EOOD.
- Abalta may also disclose your personal data with third-party processors to perform support services and to assist us in processing your personal data as described above. These processors are required to treat your personal data in compliance with all applicable privacy and data protection laws.
- Abalta may share your personal data with third parties when we have a good faith belief that disclosure is necessary:
- to comply with a law, regulation, court order, or other legal processes;
- to detect, prevent, and respond to fraud or intellectual property infringement claims, violations of our contracts or agreements, violations of law, or other misuse of our website, products or services;
- to protect Abalta’s rights or property or yours or others’ health, safety, welfare, rights, or property; or
- under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal data.
- Abalta may disclose your personal data with third parties in connection with the sale, purchase, merger, reorganization, liquidation, or dissolution of Abalta, or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal data.
- Abalta may share your data with your consent or at your request.
- Abalta may share anonymized or Aggregated Data internally and with third parties for any purpose. Such information will not identify you individually.
7. Web App Modules by Third Party
Some web app modules provided by third parties are incorporated in WebLink Host Application to make their apps available to users on WebLink®. Those web app modules may collect your personal data directly from you. The personal data collected by those web app modules are processed in accordance with their respective privacy policies. We encourage you to read carefully their privacy policies before you use those apps.
8. Third-Party Links
Some content or applications on our Website may be served by third parties, content providers and application providers including the following:
b. Third-party links. Our Website and the WebLink Host Application may contain links to other sites, which we do not control. Those websites have their own privacy policies and terms, and we encourage you to read those terms before interacting with third-party sites.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your express agreement may permit us to retain your personal data for a longer period. Furthermore, legal requirements may require us to retain portions or all of the personal data we hold for a longer period of time. For example, we may be required to retain your information for tax, financial reporting, and other regulatory compliance reasons. When we are no longer required to retain your personal data, we will delete, erase, or anonymize your personal data as required by applicable law and regulations.
Neither WebLink® services nor our Website are intended for children under 16 years of age. We will not knowingly solicit or collect personal data from children under 16, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. If we learn that we have received information directly from a child under 16 without his or her parent’s or legal guardian’s consent, we will make commercially reasonable efforts to delete such information.
11. Your Rights and Choices
Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.
- Marketing. If you no longer want us to use your email address or other contact information that you have provided to promote or recommend our own products and services, or third parties’ products or services, you can opt-out by replying to any promotional email we have sent you or following the opt-out links on that message.
- Accessing, Updating, and Deleting Your Information. You can contact us as set forth in the Contact Us section below to submit the following types of requests regarding the personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.
- Request access to your personal data, commonly known as a “data subject access request,” which allows you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request a correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If we delete your personal data upon your request, we may not be able to provide the WebLink® service to you.
- (EEA residents only) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party (right to data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain WebLink® service to you. We will advise you if this is the case at the time you withdraw your consent.
- We may make automated decisions about you based on your personal data that may affect your access or services provided to you. You have the right not to be subject the automated decision making so long as the decision is not necessary for the performance of the contract with you or required by legal obligation. If the decision making is necessary, you may contest the decision and request human intervention in the decision-making process.
- If you are in the European Economic Area (“EEA”), you also have a right to lodge a complaint with the Bulgarian Data Protection Authority at https://www.cpdp.bg or the data protection authority where you live.
To exercise your data subject rights, please submit your request, through any of the methods described in the Contact Us section.
12. International Transfers
If you are located in the EEA, we have put in place appropriate measures to comply with the laws and regulations to ensure that the transfer of personal data to countries outside of the EEA provides an adequate level of data protection, for instance, by entering into standard contractual clauses or an alternative mechanism for the transfer of data as approved by the GDPR.
13. Data Security
The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse and unauthorized access, use, alteration, or disclosure. We will only retain your personal data for as long as reasonably necessary to fulfill the purpose of collecting it. In providing you with the WebLink® service, we host the WebLink-related data, including your personal data, on Amazon Web Service server (AWS), and as described above, we use Google Analytics for Firebase and Firebase Crashlytics. For security certifications AWS and Google Firebase services have, please see the following webpages:
Google Firebase: https://firebase.google.com/support/privacy#certifications
We will continue to improve our physical, electronic, and administrative safeguards. However, the Internet environment is not 100% secure, and we cannot guarantee that information we collect will never be accessed in an unauthorized way.
15. Additional Disclosures for California Residents
If you are a resident of California, you may have additional personal rights and choices with regard to your personal data. Please see WebLink Privacy Notice for California Residents for more information.
16. Contact Us
Data subject request:
To exercise your data subject rights, please submit your request through our Data Subject Request Form, or contact us through any of the following methods.
3655 Nobel Drive, Suite 550 San Diego, CA 92122
For GDPR inquiries and data subject rights requests or to contact our Data Protection Officer, please email us at email@example.com or mail your inquiries and requests to the following postal address:
Abalta Technologies, EOOD
Office A, Floor 4, 2 Ivan Abadzhiev Street,
1784, Sofia, Bulgaria