Abraxa Group Ltd. shall be referred to as “Abraxa” and “our”, “us” or “we”.
www.abraxa.com shall be referred to as “Site”
A visitor or end user of our Site is referred to as “you”, “your(s)” or “yourself”.
Personally Identifiable Information shall be referred to as “PI”
Terms and Conditions of service shall be referred to as “Terms”
In addition, the terms “collect”, “process”, “treat”, “use”, “share”, “disclose”, “divulge” and analogous words shall be refer to your PI and other data collected from our visitors and end users.
Introduction & General Scope.
Unless otherwise stated to the contrary herein, this Policy applies to this Site, our cloud-provided software as a service targeted for Port Agent Companies, along other types of companies, and any website that references this Policy, any of Abraxa’s operated websites, as well as any data Abraxa may collect across partnered and unaffiliated websites.
User Agreement & Registration.
As a user of our Site, you will be asked to create a profile with us, by clicking on the “I Agree” checkbox on the registration form or box or other similar means. Through that action, you thereby acknowledge and agree to the terms of this Policy, which is and constitutes a legal, binding agreement between you and Abraxa.
This Policy is freely available for your review prior to registration, and if you do not agree to its terms, your remedy shall consist of not registering into the Site, and exiting the web tab though which you visited us.
The Abraxa team does every possible effort to keep your trust; and thus we adhere to these general privacy principles, in order to defend your privacy:
- Abraxa does not rent or sell your PI.
- Abraxa does not divulge your contact information to third parties or other users without your consent.
- Any PI that you give to Abraxa will be protected by industry standard technology and codes of ethics.
For purposes of this Policy, the Site shall be the initial point of contact between you and Abraxa, and will serve as the point of collection of any personal data you may provide us.
As our user, you will normally be able to manage and select the quantity and type of PI you may reveal to us when using our Site, usually in your account settings.
We constantly try to develop our user experience, and continuously work in order to:
- notify you concerning the ways in which your personal information may be utilized and shared (overseas included);
- preserve the security and protection of your personal details; and/or
- enforce the accessibility of your personal information in order for you to exercise your right of correction of said information.
Collection of Personal Information.
As a general rule, we collect both “Non-Personal Information” and “Personal Information” from our users:
- “Non-Personal Information” includes information that cannot be used to personally identify an individual person, such as anonymous usage data, general demographic information that we may collect, number of clicks, platform types, preferences you submit and preferences that are generated based on the data you submit.
- “Personal Information” includes information that can be used to personally identify an individual person, such as name, address, email address, home/business address, mobile number and payment processing account details.
More specifically, though the Site, we collect PI through our contact forms, including but not limited to, name, surname, company name, emails, profile picture, company email address, personal mobile number, company phone number, client lists, client contact details, order & project data, customer management data, Skype username and LinkedIn profile.
We may also collect non-personally identifiable information via third party tools, such as aggregate user statistics, analytics, demographic information, and web site usage information. As our user, you will generally be able to control and select the amount and type of PI you may disclose to us.
Accordingly, by registering with us or otherwise using our products and services, you consent to the collection, transfer, processing, storage, and disclosure of your PI as described in this Policy.
Users may use their email address in order to login into the Site. We use user authentication services such as those provided by Auth0 (www.auth0.com).
The Site might provide an option of using your social media and other third party credentials such as Google and Microsoft in order to execute single-sign-on and interact with other users of the Site. Thus, by such action, we will collect your PI as given by such third party platforms, but never more than the PI these platforms disclose. For more information, please read the terms and policies of such third party platforms.
When you access our platform via a mobile device, we may use your mobile device ID (i.e. the unique identifier assigned to a mobile device by the manufacturer) and/or Advertising ID (for Apple iOS 6 and later) instead of cookies in order to recognize you and track displayed web pages, along with their performance.
Purpose of PI Collection.
We will store your PI for the purposes of managing your collaboration with other users and clients, improve your user experience, send newsletters and contact you about inquiries for our services. Overall, we use the collected PI to provide and improve our services. Accordingly, we will generally collect, use and disclose your PI to:
- Provide, operate, maintain, improve, and promote our platform and our products and services.
- Verify your e-mail address and other account notices.
- Develop, research, process, safeguard and improve our services.
- Offer promotions, newsletters, sweepstakes entries, send service related announcements and contact you about inquiries for our products and services.
- Investigate and prevent fraudulent transactions, unauthorized access to our services, and other suspicious activities.
- Monitor and analyze trends, usage, and activities in connection with our products and services and for marketing or advertising purposes.
Abraxa will keep any collected PI only as long as it is necessary, with regard to the purpose of its processing. This means that PI collected and processed for marketing and commercial purposes will be stored for as long as you have an active account, and for twelve (12) months after your subscription has ended or where your account has been deleted or deactivated.
If you do not wish to disclose any or part of your PI to us, you may still be able to use some of the functionalities of our Site, though we will not be able to guarantee that you will be able to enjoy them at their fullest if you elect not to disclose it to us.
Billing and Payments.
We currently rely on direct bank transfer in order to bill your payment account linked to you. In the future, we may implement authorized third-party payment processors in order to bill our users, and in such case we will request your authorization to charge the pertinent fees through your indicated payment processing account.
The management of your payments to us is subject to the fees, terms and circumstances and privacy policies of such third party payment processors, and Abraxa shall not be held responsible for any and all outside fees, errors and delays by such payment processors.
Disclosures to Business Successors.
If our business is sold or merges in whole or in part with another business that would become responsible for providing the Site to you, we retain the right to transfer your PI to the new business. The new business would retain the right to use your PI according to the terms of this Policy as well as to any changes to this privacy notice as instituted by the new business.
We will also retain the right to transfer your PI if our company files for bankruptcy and some or all of our assets are sold to another individual or business.
Third Party Tools and PI Processors.
In order to provide our services, we use third-party platforms and tools, such as those provided by Google and Amazon Web Services, among other providers. Please be aware that such platforms are governed by their own terms, policies and personal data collection practices and policies. Accordingly, by acknowledging your consent to this Policy, you are also acknowledging the applicable terms and conditions of Google and/or Amazon or their affiliates. Upon the case of any discrepancy or conflict among this Policy and the terms of Google or Amazon, the terms of the latte entity will govern.
We will keep a list of any sub-processors that will be involved in the processing of your PI due to the provision of our service and will inform you of any intended material changes concerning the addition or replacement of sub-processors before such changes are effective, thereby giving you the opportunity to object to such changes.
You can learn more about how to opt-out by browsing Google’s opting-out and privacy pages located at www.google.com, or the Network Advertising Initiative website located at www.networkadvertising.org.
You must at least be eighteen (18) years of age, or older—to purchase our products and/or to use our services. Abraxa does not knowingly collect any kind of information from persons under the age of thirteen (13). If we learn or have reason to suspect that any user or that any client, project or customer data appertains persons under the age of thirteen (13), we will freeze and/or delete any PI under that user’s account, without prior notice and without responsibility.
Lawful Disclosure of Personal Information.
We, or our affiliates, clients, contractors, licensors, officers, agents and/or representatives, reserve the right to allow access to any of your PI when we think it is reasonably important or when you violate the terms mentioned in this policy. Hereafter, we will have the right to disclose any or all gathered PI and/or data, when the following circumstances arise: (i) if necessary under an applicable law; (ii) in reply to a legal demand or subpoena from an agency of the law ; (iii) to protect ourselves and our affiliates from any legal third party claims and procedures that may be brought to us (inclusive of takedown notices); and/or (iv) to prevent or cause cessation of any undertakings that may be construed by us as having the ability to be or cause a predicament or hazard to us.
Occasionally, we will ask you for express permission and approval to receive electronic messages in electronic format which are then sent to an electronic address and that contains a message asking recipients to participate in commercial activities such as newsletters, purchase of products, services and invitations to participate in surveys.
We will send you service-related announcements on occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, or a new enhancement is released, which will affect the way you use our services, we might send you an email. Generally, you may not opt-out of these communications, which are neither commercial nor promotional in nature.
If you no longer wish to receive email update and other commercial communications and messages, you may opt-out of receiving them by following the instructions included in each update or communication.
Periodically, we may place what are known as ‘cookies’ inside your computer for the purpose of tracking and collecting data in regard to your utilization of our Site and our services. These files are small texts that our site transfers to your computer, and which allow us to recognize you and obtain data such as the time in which you browse pages within our Site, time of the day, specs of your computer, session length, etc.
We may also collect and use the data contained in log files, which may include your IP address, your ISP, the browser you used to visit our platform, the time you visited our platform and which sections you visited.
We do not currently offer “do-not-track” or similar mechanisms. Unlike cookies, device IDs cannot be deleted, but you can select to reset your Advertising IDs in the “Settings” section of your mobile device, among other.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If you wish so, you can easily disable cookies on your web browsing software by following the step-by-step guides located at www.allaboutcookies.org and at www.youronlinechoices.com.
Third Party Services.
Our Site may present our commercial partner’s hyperlinks as well as those of other third parties. It is important that you consider that we are not responsible for data practices that are conducted by third-parties or the privacy policies that apply thereof, and that the way in which such third-parties may assemble, process, handle or utilize your PI is not in our control. When such a link is used to go from our Site to an outside website, our Policy and Terms are no longer in force and your further browsing is at your personal and ultimate risk.
International Transfer Notice.
We have our headquarters in Bulgaria. Henceforth, your PI may be accessed by us or our affiliates, agents, partners and third-party service providers in Bulgaria and our locations which may or may not be located in your country of residence, and you hereby consent to such access and transfer by simple disclosure. Abraxa-related entities are subject to the privacy practices set out in this Policy and any applicable jurisdictional legislation.
GDPR Notice and your Rights as Data Subject.
For the purposes of the GDPR, in the European Union, Abraxa is a “data controller” of the PI you provide to us for the primary purposes of providing you with our services.
For European Union customers and users, by clicking the "I Accept" button or otherwise accepting the terms and conditions of our services through a clickable action or similar action, you hereby acknowledge, agree and unequivocally consent to the collection, process, management, treatment, transfer and authorized of your PI by Abraxa, its affiliates and authorized third parties.
The section below covers the certain situations that you, as data subject, and we as a data controller, are most likely to see, but you should also carefully review the full list of data subject rights here: https://gdpr-info.eu/chapter-3/. You retain the right to access, amend, correct or delete your PI where it is inaccurate at any time. To do so, please contact firstname.lastname@example.org.
- Right to be Forgotten: You can request us to be “forgotten”; that is, to have your entire PI removed from our service. If we are asked to do this, we will remove any PI you we collected from you as requester. We will also need to contact any third parties, such as our cloud service providers, that process your PI on our behalf. To ensure that any personal data in Abraxa’s possession can be removed in a timely manner, you can relay any request to be “forgotten” to us by submitting a request-
- Right to Data Portability: Under the GDPR, our users located in the EU may request Abraxa to send them any PI in our possession. In this case, we will provide you with any PI that you have in a commonly used, machine-readable format.
- Right to Data Access: As a data subject, you can ask Abraxa to confirm how and where your PI is being stored and processed. You also have the right to know how such that data is shared with third parties by us.
- Right to Data Rectification: As data subject, you have the right to obtain from Abraxa, without undue delay, the rectification of inaccurate PI concerning you.
- Right to be Informed: You have the right to be informed about the PI we collect from you, and how we process it.
- Right to Object: You have the right to object to us processing your PI for the following reasons:
- Processing was not based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
- Direct marketing (including profiling);
- Processing for purposes of scientific/historical research and statistics; and
- Rights in relation to automated decision-making and profiling.
- Automated Individual Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- Right to Complain: You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the GDPR. If the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.
Your privacy request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the PI with regard to which you seek to enforce any of your privacy rights. If you request rectification, please indicate amendments to be made and attach documentation to back up your request.
Upon receipt of your privacy request, and after due review, we may then edit, deactivate and/or delete your PI from our services within thirty (30) days. In case of secure databases under our control where deletion is impossible, we will make such information permanently inaccessible.
From time to time, this Policy may be translated into other languages for your convenience. The English language version of each of these documents shall be the version that prevails and governs your use of Site and our products and services. Upon the case of any conflict between the English language version and any translated version, the English language version will prevail.
Amendments to this Policy.
Periodically, and at the final discretion of ourselves, we may update, change, suspend and/modify or our Site, our services, this Policy and/or our Terms, in whole or in part. We hereby reserve such right in order to operate our business and protect ourselves. Your use after any changes indicate your acceptance thereof and we will post a notice regarding such changes on our Site, and may also write an email to you or otherwise notify you.
If you have any questions or comments about us, our Site, our Terms and/or this Policy, please contact us at:
Vertigo Tower, 109, Bulgaria Blvd, Sofia, Bulgaria
+359 88 320 3405
Date of last effective update is [---------], 2019.