With the presentation of these policy rules, we aim to explain to you what information we collect about you, why, and how we do 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 OF THE COUNCIL of 27 April 2016 - GDPR).
Why is your consent needed?
Our top priority is to protect your personal data and obtain your free, informed and unambiguous consent to the processing of your personal data by Melon. If you select Accept all in the interface menu for obtaining your consent, then you agree that:
- you provide your personal data voluntarily;
- you have become familiar with your rights under the PDPA and REGULATION (EU) 2016/679 of the EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 – GDPR and give your consent to the collection, processing, storage and transmission of your personal data to third parties for purposes indicated below.
- ‘Personal data’
- means any information relating to an identified or identifiable natural person. (‘data subject’ or ‘user’).
An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
- means an authority which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Bulgarian law, the controller or the specific criteria for its nomination may be provided for by Union or Bulgarian law. In this case the controller is MELON AD (hereinafter referred to as Melon), a company duly incorporated and existing under the laws of the Republic of Bulgaria, UIC 131125985, having its seat and registered office in 1113 City of Sofia, Slatina District, 20 Kosta Lulchev Street, Floor 3;
- means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
- means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
- ‘Supervisory authority’
- means an independent public authority of a Member State of the European Union responsible for monitoring the application of the rules on the protection of personal data. For the Republic of Bulgaria, the Supervisory Authority is the Commission for Personal Data Protection.
Objective of the policy
- complies with data protection laws, namely the Personal Data Protection Act (PDPA) and the General Data Protection Regulation, and other applicable laws, and follows good practice;
- protects Melon's users, customers and partners;
- ensures transparency on means in which personal data of data subjects are stored and processed;
- provides protection against the risks of data breaches.
How do we collect information about you?
We can collect information about you in several ways:
Forms filled in and sent by you to our websites
Examples of such a form are the registration for free testing of our LMS service on https://melonlearning.com/ and registration for adding comments on http://melonmobile.com/blog/
By sending them, you willfully share your personal data. The personal data provided by you is used for the normal operation of the tested services and, in the case of sharing them for adding comments - for identifying you as the author of the comment.
In the case of subsequent secondary processing of your personal data for purposes other than those for which they were collected in in the specific form, we will explicitly indicate the secondary purposes of use, the period of storing thereof, third parties to which we may share them and ways to exercise your rights under the Regulation.
Regardless of the scope of the purposes, we will minimize the amount of data in the form according to the stated purposes.
Data collected by observing your behavior on our websites
We collect information about you by observing your behavior on our websites and in our mobile applications.
For this purpose, we use standard Internet user behavior tracking methods, such as:
The data collected by us based on your behavior analysis are used for the following:
- Using network equipment to track your IP address;
- Analyzing information available as part of the communication in protocols used by us to record and exchange identifiers of you and your device, e.g. HTTP GET/POST requests
- Analysis of your behavior, in particular webpages you visit while staying on the pages, interactions made with sites’ contents, etc., for the purpose of optimizing the content, design and the interface aspect of our websites.
- Optimization of advertising by adding you to user audiences to which specific advertising content will be subsequently served. An example of such advertising is remarketing.
Data received from third parties
Sometimes, after obtaining your explicit consent, we may receive data from third parties, e.g. data from your social network account, such as Facebook. Typically, such consent is administered by a tool of the third party and in the context of your relationship with the same. For example. Facebook will notify you of the scope of your personal data that it will share with us and will request your consent, along with a description of the rights you give us in relation to your social network account.
It is possible that these data will be aggregated with other personal data relating to you that we already have. The purposes for aggregating the data would be similar to those described in the document.
What information do we collect and process when you use our services?
Forms completed and sent by you
It is possible to collect various personal data according to the purposes of the form
Typically, we collect the following data:
- User name
- Mobile phone
- Email address
Data collected through observations
For all visitors, we, as well as the suppliers of the tools used by us, typically collect the following data about you:
For logged-in users, in addition to the above-mentioned data, we also collect identifiers linking them to their particular account on our website.
- The IP address from which you have accessed our website. Depending on your consent, we will state its anonymization when submitting to third-party suppliers of solutions for monitoring and analysis, e.g. Google Analytics;
- Identifier of your browser;
- Identifier of your mobile device;
- History of your behavior - webpages visited, time spent on them, purchased products, etc.;
- Behavior towards the website /mobile application content - navigation, interface elements used, time of stay;
- Your searches;
- Your comments;
Data received from third parties
Depending on the data source, this includes:
- Basic account information, such as name, email address, date of birth;
- Details you decide to share according to the specific settings for social media accounts;
- Your contacts and how you connect with them.
For what purposes do we process information?
The information we collect and process for you may be used for the following purposes:
Normal operation of our websites and services
These data are strictly necessary for the normal operation of our websites and mobile applications. Through them, we can verify your identity as a logged-in user, to better show you the content, to load the website more quickly, protect you from the websites and digital crimes.
Such data, for example, include information on whether you are logged-in, cached content, your browser settings, etc.
Contractual performance of our services
Some of the services we provide require from you to share personal data with us. We use them to be able to perform our contract with you for the use of the service, also when you have requested to use it in test mode.
Save and access information
This is an ancillary purpose to achieve other purposes - using different technical mechanisms, Melon will be able to fulfill any of the other described purposes.
It includes storage and access to information saved on your device, e.g. device identifiers, user identifiers, advertising identifiers, cookies, and other technologies.
Personalization and profiling
We collect and process information about the use of our services for subsequent serving of a personalized advertisement and/or content in another context, e.g. other sites and mobile applications over time.
Typically, the content and your behavior on the website/mobile application are used to make conclusions about your interests through which the future choice of served advertisements and/or content is managed.
We aim to optimize advertisements subsequently displayed to you.
Selection, delivery and reporting of served content
We collect information and combine it with information previously collected to select and deliver relevant content and measure its delivery and effectiveness. This may include previously collected information on your interests to the content, processing of data on the content displayed to you, how often or how long it has been displayed, whether you have taken any action relating to the content, including clicking on the content.
This purpose does not include personalization and profiling.
We collect information about your use of the content and combine it with previously collected information to measure, understand and report your use of our services.
This purpose does not include personalization and profiling.
To do so, we only use the Google Analytics tool, and by the time we receive your consent, we have turned Google Analytics Advertising Features off and we have submitted a command to anonymize your IP to Google Analytics.
We consider that, by doing so, we have minimized the volume of information collected for the purposes of measuring to the extent required and, thus, these data are not used for any purpose other than Measuring and, on the other hand, we believe that we protect our legitimate business interest in developing and improving our services.
Planning, reporting, and statistics purposes
Planning, reporting, and statistics purposes shall mean any operation of collection and processing of personal data necessary for statistical studies or for the production of statistical results, as well as for the preparation, implementation, and revision of plans and results thereof.
Collecting your personal data under this paragraph would be in response to specific legal requirements and the data collected would be used only for the purposes provided for by law.
In order to always send you up-to-date and useful information about our initiatives, we collect data, such as an e-mail address or another way to contact you –Viber, Skype, Messenger profile or such in any other communication platform.
By providing your contact details, you give us your consent to send you from time to time our information and advertising newsletters by email or to your mobile phone.
You may withdraw your consent at any time by using the form in the newsletter itself or the relevant functionality on our website.
How long do we retain information?
How long we retain your Personal data depends on the type of data and the purpose for which we process the data. We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.
Who has access to your personal data?
Sometimes we disclose your personal data to third parties - Melon’s Partners, including those established outside the European Union, subject to the requirements of the Regulation. Examples of such transfer of personal data are:
- Subsidiary companies for software development;
- Third parties with which Melon has contractual relationship to perform Measurements (e.g. Google Analytics); To select, deliver, and measure serving content or advertisements (e.g. Google Ads).
- Third parties with which Melon has contractual relationships for the use of collocation services;
- Third parties with which Melon has a contractual relationship for the use of Virtual Servers (VPS);
- Industry-recognized solution providers, which have publicly declared compliance with the GDPR and the e-privacy policies, such as Google and Facebook. Consent also includes the insertion and use of tagging unique depersonalized identifiers, including by using cookies, localStorage or other appropriate web technology;
- Third persons providing services to Melon as accountants and accounting entities; auditors and audit firms; lawyers – attorneys at law, legal offices and legal advisers; notaries; advertising and PR agencies; companies operating in the field of system administration of data.
What are your rights relating to personal data?
Our priority is to inform you of your legitimate rights and to ensure that they are respected. You have the following rights, which should be observed when processing your personal data:
- Right to withdraw at any time your consent to processing of your personal data;
- To request your data to be rectified or supplemented if an inaccuracy is found by a written application addressed to us;
- Right to access your personal data;
- Right to restriction of processing of your personal data;
- Right to objection to processing of your personal data;
- Right to data portability;
- Right to request erasure of your personal data that are processed illegally or the legal grounds of which no longer exist (withdrawn consent, achieved initial purpose for which they were collected, etc.);
- Right to request from the Controller of your personal data to notify third parties, to which the Controller has provided your data, of rectification, erasure or restriction of processing of the personal data.
- You have the right to lodge a complaint with the Commission for Personal Data Protection.
When may Melon use your data to contact you?
We may use the information provided by you to contact you about various issues such as:
We will never contact you to request the password of your account.
- to notify you of amendments to Melon’s policies and this policy;
- to respond when you have contacted us or to reply to your comment or complaint;
- to invite you to participate in our surveys on Melon's services;
- for marketing purposes;
- to send you appropriate offers of Melon’s products and services and/or of third parties – Melon’s Partners;
- to inform you about games, contests or promotional offers of Melon and/or of third parties – Melon’s Partners.
How can I obtain, update, and manage my personal data?
In order to manage your consents more easily, you can download the following online form to exercise your rights as per GDPR: Application form and send it to [email protected]
Using it, you can view and manage the consents given and request to exercise the rights provided for by the GDPR.
Melon reserves its right to amend and/or supplement this Policy at any time. The amendments shall take effect as soon as they are published on the website, unless otherwise provided in the updated version of the Policy. You should periodically visit this webpage to review the Policy. The Policy may be updated at any time without specific notice to users of the Website. Melon shall not be responsible if a website user has not become familiar with the latest valid version of this Policy.
Please send your questions and comments about cookies or privacy at: [email protected].