Effective as of 16.04.2026
| Prepared by: AdvIO Tech Ltd , UIC: 208186480, with seat and registered address at: 7 Vega Street, Kazichene, 1532 Sofia, Bulgaria, in its capacity of controller in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”), hereinafter referred to as the “Company” or the “Controller”. |
| This Privacy Notice intends to provide information about what personal data of yours the Controller processes in relation to the execution, service and performance of contracts and any other binding relations, related to the services offered by it, as well as when using the Company’s website or when visiting the office of the latter. |
| Should you wish to confirm whether the Controller processes your personal data, or to gain access to any personal data that Controller might have about you, as well as in case of any questions related to the processing of your personal data, you may contact us in one of the following ways: |
| e-mail: georgi.georgiev@adviotech.com; |
| address: 7 Vega Street, Kazichene, 1532 Sofia, Bulgaria. |
INTRODUCTION
The Company is a technology company providing different IT services including such for real-time transport visibility via its own online platform called GeoArmada (the “GeoArmanda”). GeoArmada enables companies to track shipments and access operational information in a secure digital environment.
CATEGORIES OF DATA SUBJECTS AND PURPOSES OF PERSONAL DATA PROCESSING
| In order to carry out the functioning, management, development and its services, the Company processes the personal data of the following main categories of data subjects: |
| statutory representatives of the customers and the other contractors of the Company; |
| proxies of the individuals under item a) above; |
| contact persons of its customers and contractors; |
| employees of the customers and the other contractors of the Company; |
| subcontractors of the customers and the other contractors of the Company; |
| users of GeoArmada, which may include: representatives of the customers of the Company; representatives of the carriers transporting goods for the customers of the Company; representatives of GPS data services providers. |
| visitors of the web page of the Company https://geoarmada.com/data-protection (for information on how we process your data, please refer to the section “Using the Webpage” below). |
visitors at the Company’s office, including the employees of the Company (for information on how we process your data, please refer to the section “Video surveillance” below).
HOW, WHY AND IN WHAT TERMS WE PROCESS YOUR PERSONAL DATA
The information set out below applies both to the data subjects who have themselves provided their personal data to the Controller, and to those whose personal data have been provided to us by third parties (for example: their employers).
Categories of personal data
| The Company processes the following categories of personal data of the above listed persons: |
| for physical identity: name; Personal Identification Number (EGN)/Personal Number of a Foreigner or other identification number; ID card/passport/residence permit data: document number, date of issuance and validity, issuing authority; address; phone number; e-mail address; signature; images including video images, considering that: |
| The Company processes ID card/passport/residence permit data of customers and contractors only if notarized documents are prepared or used; |
| for social identity: occupation; professional qualification, where needed with regard to performance of any activities requiring specific qualification. |
| Note that the personal data which is processed in relation to GeoArmada service of the Company is: name, phone number and e-mail address. |
Purpose and Legal Ground of the Processing
| We use the abovementioned personal data for the following purposes: |
| signing and execution of contracts; |
| control over performance of contractual obligations; |
| accountancy and taxation; |
| debt collection; |
| direct marketing and promoting the activities of the Company and the services offered by the Company; |
| defence in case of legal claims and protection of the legal rights and interests (incl. economic) of the Company and its customers, contractors and related parties; |
| administration of our platform GeoArmada, including creation and management of user accounts and access rights; |
| ensuring operational security and integrity of GeoArmada; |
| compliance with legal and regulatory obligations related to GeoArmada’s operation. |
| We process the personal data on the following grounds: |
| execution of pre-contractual, contractual and statutory obligations of the Company with regard to the respective relations; |
| performance of the legal obligations of the Company in relation to its activity. |
| the legitimate interest of the Company to advertise and improve the activities and the services it offers; |
| the legitimate interest of the Company to ensure operational security and integrity of GeoArmada; prevention and detection of fraud or misuse of GeoArmada. |
| Information on how to exercise the right to object can be found below in this notice. |
Storage Limitations
| The term for processing of your personal data for the abovementioned purposes is: |
| data contained in accounting registers and financial statements: up to 11 years; |
| data contained in documents subject to tax audits and needed for accounting purposes: up to 11; |
| data contained in documents needed for the performance of contractual relations: up to 6 years after termination of the respective contract or until closure of dispute related procedures, |
| data contained in the account of the users of GeoArmada: Up to 1 year after deactivating the account |
| except where a legislative act, a judicial act, an agreement or the commercial practice require otherwise. |
With whom we may share your personal data
| the legal representatives of the Company; |
| outside providers of tax and accounting services; |
| outside expert auditors; |
| outside providers of legal services; |
| service providers supporting software systems used by the Company or its processors; |
| service providers supporting the email accounts system used by the Company; |
| service providers supporting GeoArmada |
| other IT service providers; |
| Public and Private Enforcement Agents; |
| other competent authorities. |
USING THE WEBPAGE
| As is true of most other websites, the Controller’s website collects certain information automatically and stores it in log files. The information may include technical and usage data such as: internet protocol (IP) addresses, the region or general location from which your computer or device is accessing the internet, browser type, operating system and other usage information about your use of our website, including a history of the subsections you have reviewed. We use this information to help us: maintain and improve the design and functionality of our web site to better suit our users’ needs; analyze trends, monitor visitor activity and better understand visitor’s preferences. Diagnose technical problems and administer our website. The listed personal data are processed on the ground of the legitimate interest of the Company, consisting in ensuring the secure and efficient operation of our website and improving the user experience. The Company has assessed that this interest is not overridden by your interests or fundamental rights and freedoms, having regard to the technical nature of the data collected and the reasonable expectation of users that websites collect such data in the ordinary course of operation. The term for processing of the log files containing information for the website activity of the users is up to 1 month, except where a legislative act, a judicial act, an agreement or the commercial practice require otherwise. Cookies and Web Beacons The Company’s website uses cookies and similar tracking technologies, including web beacons. Cookies are small text files placed on your device when you visit our website. We use the following categories of cookies: Strictly necessary cookies — These cookies are essential for the website to function and cannot be disabled. They do not require your consent. They are used, for example, to maintain session continuity and ensure the security of the website. Analytical / performance cookies — These cookies allow us to count visits and traffic sources so that we can measure and improve the performance of our website. All information collected by these cookies is aggregated. These cookies are only placed if you have given your consent through our cookie consent tool. You may withdraw your consent to non-essential cookies at any time by accessing the cookie settings on our website, or by configuring your browser to refuse cookies. Please note that disabling certain cookies may affect the functionality of the website. The Company does not use cookies for the purposes of targeted advertising and does not track users across third-party websites. |
| VIDEO SURVEILLANCE |
| Video surveillance is used to process the personal data of the visitors at the office of the Company, including the Employees (together hereinafter referred to as the “Visitors”) who enter the office premises and the server rooms of the Company and who happen to be present in the video surveillance zones. The personal data being processed are data related to physical identity, namely: video images and video recordings without sound and without possibility of automatic facial recognition. The purpose for the video surveillance is ensuring the protection office premisses and the server rooms of the Company. The Company processes your personal data on the legal basis of its legitimate interest. Your data is stored for a period of up to two months, unless it pertains to information regarding a committed offense, in which case the data is stored for a maximum period of up to six years or until the conclusion of procedures related to potential disputes. The personal data has been or might be disclosed to partners and legal representatives of the Company; outside providers of legal services; external providers of/or consultants for the construction of security system and security services; service providers supporting software systems for video surveillance, used by the Company or its processors; other IT service providers; competent authorities. |
RIGHTS OF THE DATA SUBJECTS
| If you are a person whose personal data are processed by the Company under any of the circumstances listed above, you have the following rights: |
| a) you have the right to object to the processing of your personal data for the purposes of direct marketing, if you are an addressee of direct marketing message. If you make such objection we will no longer process your personal data for this purpose. However, in order to ensure that your objection is regarded, your data will be included in data base of data subjects that have objected against direct marketing; |
| b) all data subjects have the right: |
| to be informed what kind of personal data are processed by the Company; |
| to access and copy of their processed personal data; |
| of rectification or erasure of their personal data; |
| to restrict the processing; |
| to object and withdrawal of consent; |
| of data portability. |
| You may exercise any of your rights above by submitting a written request, in any of the following ways: |
| address: 7 Vega Street, Kazichene, 1532 Sofia, Bulgaria; |
| e-mail: georgi.georgiev@adviotech.com |
| You also have the right to file a complaint regarding the processing of your personal data to the relevant authority, which for the Republic of Bulgaria is the Commission for Personal Data Protection with contact details: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592; kzld@cpdp.bg; fax: 029153525. |
CONTENTS OF YOUR APPLICATION
| Please note that your application for exercise of any of your rights should contain at least your names in combination with other identification information about you, description of your request, preferred way of communication with you, address for correspondence, signature and date of the application. |
| If the application is signed by a proxy, the respective Power of Attorney should be attached to the application. |
| The Company may contact you for additional information, if your identity needs to be verified or if further clarifications are needed on your application. |
EXCESSIVE DATA PROVIDED BY/ABOUT YOU
If we receive any personal data in surplus of what is needed for us to comply with our purposes above, we will delete this information immediately but not later than one month after its receipt.
PROTECTION OF YOUR DATA
To help protect the privacy of your personal data, we have implemented physical, personal, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data only to those employees and personal data processors who need to have that information in order to provide benefits, goods or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We are committed to undertaking the appropriate disciplinary measures to enforce our employees’ responsibilities regarding privacy obligations.
CHANGES AND UPDATES TO THIS PRIVACY NOTICE
| As our organization and services change from time to time, this Privacy Notice may change as well. We reserve the right to change this Privacy Notice at any time, for any reason, without notice to you other than by publishing it the amended and updated Privacy Notice on the Company’s website. We may send periodic email reminders of our notices and terms and conditions and notify our clients and partners by email of material changes to them, but you should check our website periodically to be aware of our current Privacy Notice as well as any changes that may have been introduced thereto. |
| The present document represents privacy notice within the meaning of Art. 13 and Art. 14 of 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). |