MGT Connect

# Privacy policy

MGT Solutions respects the privacy of its clients and recognizes the importance of providing a secure environment for their data. We have adopted this Privacy Policy (“Privacy Policy”) that explains how and why we collect, store and use the information you provide us.

# Who is processing your data

MGT Solutions is the data controller for the processing of your personal data. We are a registered company located at Sofia, Bulgaria, with registration number: 205743305.

# What information do we collect, and how long do we keep it

We collect information from or about our clients in the following ways:Information provided by you.Information provided by you when you create or update your account(s); and while you are receiving customer service support.Information we get or generate from your use of our games or services.We collect data related to: the services that you use and how you use them, and your devices and activities when you access our services.

# Company data

In order to use MGT Connect, the client must register its company on our platform. During the process, we collect company data, so it can be used when interacting with our platform, exchanging documents with company’s partners (registered company, NOT MGT Connect) and creating a well-designed and customized experience.Examples: Company name, company address, company postal code, company contact details, company tax details, company revenue information, company owner, company preferences.

# Account data

Client’s Account Data refers to information that is provided and generated when a client creates his or her account. All of this data is available to the user by logging into his or her account and can be updated by the user in the account settings section.Examples:Name, email address, preferred language.Who has access to this type of data?Operations, Customer Service and Security.

# Customer service

We also use the information we collect while assisting users through our customer support services to investigate and address users’ concerns and monitor and improve our services. Information gathered or produced during support of our users is retained for up to 2 years to ensure that we address concerns and issues in the best way possible.Examples:Issues raised, case history, restrictions history, contact details, customer service communications, account notes.Who has access to this type of data?Operations, Customer Service and Security.

# Transactions

Our services are centralized around e-document treatment. In order to provide an intuitive platform for our clients, MGT Solutions collects information from the documents so it can be displayed to the clients in order to ease their interaction with our services. Document data may be retained for up to 10 years (primarily for audit purposes).Examples:includes but not limited to: document creation date, document number, document issuer, document contact data, document parties involved and their tax registration details, total document amount, total tax document amount, issuer and receiver’s specific references.Who has access to this type of data?Operations, Customer Service, Security.

# Activity data

When a user interacts with our services, we collect server logs. In most cases, server logs are retained between 90 days and 1 year.Examples:IP address, access dates and times, activity region and activity logs.Who has access to this type of data?Operations,Customer Service and Security.

# Device data

We may collect information about the devices used to access our services.Examples:Hardware models, operating systems and versions, unique device identifiers.Who has access to this type of data?Operations, Security.

# Communications

MGT Solutions may use the information we collect from users or partners to communicate with our clients about our current and upcoming products, services, promotions, studies, surveys, news, updates and events. Data gathered this way will be removed no longer than 90 days after the study/survey is over.Examples:Name, email address, survey details, purchase history, activity history, email activity.Who has access to this type of data?Operations, Marketing.

We keep records as support for any actual or anticipated legal matter for up to 10 years.Examples: Signed contracts with clients, orders, invoices, payments, security audits, case files.Who has access to this type of data?Operations, Security, Legal

# Why do we process your data

MGT Solutions collects and uses your data for the following purposes:

# MGT Connect

Creating the well-designed, highly usable, well structured e-document and integration platform. This includes:

# Ease of use

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Transactions: document number, document issue date, document issuer.
  • Device data: operating system and versions, unique identifiers, IP addresses

# Monitoring

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Transactions: document number, document issue date, document issuer
  • Device data: operating system and versions, unique identifiers, IP addresses

# Users Account and Security

In order to restrict the access to our platform and personalize the experience the users get when interacting with it, MGT Solutions gathers the following account information:

# User’s Account

Examples of data used

  • Account data: Name, email address, language preference
  • Activity data: IP address, login information, operating system

# Business optimization and service development

We conduct troubleshooting, research, analysis and product and service development to provide you with the best services. This includes:

# Analytics & Data Segmentation

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Account data: MGT Connect’s account data, country, email addresses◦ACTIVITY DATA: IP address

# Training & Development

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Account data: Name, country, email address
  • Activity data: IP address◦CUSTOMER SERVICE: Ticket issue description, account notes, Customer Service log

# Reporting

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Account data: Account region, email address
  • Activity data: IP address, preferred language
  • Transactions: Document numbers, document parties involved, document received date, document references, document total amount, document total tax amount

# Global Customer Service

We provide you with personalized support to investigate and address any possible difficulty you might experience with our services, your account or your transactions. This includes:

# Customer Service

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Account data: email address, country, language
  • Activity data: IP address, region, timestamp◦CUSTOMER SERVICE: Chat records, case history

# Business Operations

We process orders for our products and services. This includes:

# Subscriptions

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Account data: Email address, account name, country, language
  • Activity data: IP address
  • Transactions: Invoices, refund details, subscriptions, licenses, payment details

We may use the information we collect to investigate or address claims or disputes relating to your use of MGT Connect’s services or as otherwise allowed or required by applicable law. This includes:

# Litigation or Pre-litigation

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Account data: Name, email address
  • Customer service: Account notes
  • Legal data: Case file

# Security Monitoring and Investigations

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Account data: name, address, email address, country
  • Activity data: IP address
  • Device data: Device ID

Examples of data used

  • Company data: Company preferences, company name, company tax id
  • Account data: Account name, account email address

We process the above in accordance with the legal bases determined as follows:

# Necessary for the performance of your services contract or any other feature you request or enable

These are required, and ceasing their processing will remove access to certain features or to the platform service altogether. This includes using information for:

  • Client functionality
  • Account functionality
  • Transaction processing
  • Global Customer Service

You can withdraw your consent to these at any time.

Receive news and exclusive offers about selected third-party products and services– Carefully selected news, event information and special offers about third-party products and services

Receive news and special offers from MGT Solutions by email– Personalized news, event information and special offers about MGT Solutions products and services

Cookies- Information stored on your device (cookies), so that we can better understand how our sites and services are used.

# Legitimate interest

We use your data for purposes that are not harmful to your privacy and that can be reasonably expected within the context of your relationship with MGT Solutions. This includes using information for:

  • Analytics & Data Segmentation
  • Business Optimization and Service Development
  • Publishing Email - Marketing Campaigns
  • Research Groups◦Training & Development
  • Customer Support◦Your personal data are never shared with third parties without your consent.

We process your data due to a legal obligation or right. This includes using information for:

  • Legal Compliance
  • Litigation or Pre-litigation
  • Security Monitoring and Investigations

# With whom may we share your data

MGT Solutions platform MGT Connect provides a service to create, exchange and manage documents. We provide the tool for companies to manage their business partners and clients, to notify them of new documents and allow them to share documents on our platform. Therefore, the data we store is shared ONLY with client’s partners and NO third parties. Neither company data, nor document data. Our goal is to secure your transactions, company and account details. However, in case of a dispute, your data will be shared with the following parties:

MGT Solutions may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request. This includes sharing your information with law enforcement officials, government authorities or other third parties as necessary to enforce our Terms of Service, user agreements or other policies to protect MGT Solutions’ rights or property or the rights or property of others, or in the event of a claim or dispute relating to your use of our services.

# International Transfer

Your personal data will be transferred to and processed in Europe across shared data centers, where many of our central databases operate. We use European Commission approved contract clauses to protect your personal data. Where we share data with vendors, we use these clauses, or a vendor's Processor Binding Corporate Rules to protect your data. A copy of the relevant mechanism can be provided for your review on request to our Data Protection Officer using the details set out below.

# What rights do I have

# Access my data

You may be able to receive a report about the data MGT Solutions stores about you.

# Erasure

ACCOUNT DATA: You can erase your account data at any point you wish. This will stop your access to our services and to any transaction submitted by the client the account is attached to.CLIENT DATA: You can request that your client profile is erased at any time. In order to do so, pleases contact our support department at support@mgt-connect.com. We will extract all submitted documents by your company within 90 days. The document will be exchanged via secured archive in a convenient way for MGT Solutions.

# Object

You may object to the processing of your data if you believe MGT Solutions doesn’t have the appropriate rights to engage in that processing.

# Rectification

# Account data

You can correct your personal data if you feel it’s inaccurate. Please log in to your profile in MGT Connect and use the account management settings to make the changes.

# Company data

If you believe your company data is inaccurate, then contact our support department at support@mgt-connect.com in order to update the information you want.

# Restrict Processing

You can request that your data no longer be processed in certain cases, for instance, when you exercise your right to object as described above. When objecting, you will be given an option to restrict processing.

# What are tracking technologies, and how are they used

MGT Solutions, may use tracking technologies like cookies, tags, scripts and unique codes used in our services. These technologies are used in analyzing trends, administering the websites or services, tracking users’ movements around the websites or apps. We may receive reports based on the use of these technologies by these companies on an individual, as well as an aggregated, basis.

We use this technology for maintenance of user settings (e.g. language preference), authentication, error monitoring and security audits. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our websites, but your ability to use some of the features or areas of our websites may be limited.We, and third parties with whom we partner to provide certain features on our websites.

# What are Internet Protocol addresses

An Internet Protocol ("IP") address is the unique number assigned to your computer. MGT Solutions may track such IP addresses for system administration, to report aggregate information, site tracking, security purposes, or to prevent our servers from being abused. See tracking technology discussion above.

# What level of security is applied to your personal information

To help protect the privacy of the data and personally identifiable information you provide to us and that we learn from you, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of personal information. We restrict access to your personal data to those employees indicated above. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information.

# Further information or complaints

If you have questions or concerns regarding data protection at MGT Solutions, you may contact our Data Protection Officer by writing totodor.dimitrov@mgt-connect.com.

Each EU Member State shall provide one or more independent public authority (IES) to be responsible for monitoring the application of the GDPR in order to protect the fundamental rights and freedoms of natural persons in relation to processing and to facilitate the free flow of personal data within the Union (‘supervisory authority’). If you feel that MGT Connect has violated your rights, or if you wish to raise a concern with the data protection authorities, please contact the supervisory authority in the country where you live, work, or where you believe a breach of data protection law has occurred.

MGT Solutions Privacy Policy: European Region, created 6/2019.