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Privacy Policy

INTRODUCTION
This privacy notice will inform you as to how we
look after your Personal data and tell you about your privacy rights and how the law protects
you.
Please use the Glossary to understand the meaning of some of the terms used in this privacy
notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how we collect and process your
Personal data through your use of this website, including any data you may provide through
this website when you sign up to our newsletter, purchase a product or service or take part in
a competition.
It is important that you read this privacy notice together with any other privacy notice or fair
processing notice we may provide on specific occasions when we are collecting or
processing Personal data about you so that you are fully aware of how and why we are using
your data. This privacy notice supplements the other notices and is not intended to override
them.
CONTROLLER
We have appointed a data privacy manager who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy notice, including
any requests to exercise your legal rights, please contact the data privacy manager using the
details set out below.

Name or title of data protection officer:
Under consideration
Postal address:

Address:

Totem Group Ltd
3 Targovska Str
7005 Rousse
Bulgaria

Phones:

Phone: +359 82 595 255
Mobile: +359 888 227 517

Email: office@totem-group.eu

You have the right to make a complaint at any time to the supervisory authority for data
protection issues. We would, however, appreciate the chance to deal with your concerns
before you approach the supervisory authority so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on May 24, 2018 and historic versions can be obtained by
contacting us.
It is important that the Personal data we hold about you is accurate and current. Please keep
us informed if your Personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on
those links or enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the privacy
notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
“Personal data”, or “Personal information”, means any information about an individual from
which that person can be identified. It does not include data where the identity has been
removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal data about you which we
have grouped together follows:

 Identity Data includes name, username or similar identifier.
 Contact Data includes billing address, delivery address, email address and telephone
numbers.
 Financial Data includes bank account.
 Transaction Data includes details about payments to and from you and other details
of products and services you have purchased from us.
 Technical Data includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices you use to
access this website.
 Profile Data includes your username and password, purchases or orders made by
you.
 Usage Data includes information about how you use our website, products and
services.
 Marketing and Communications Data includes your preferences in receiving
marketing from us and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for
any purpose. Aggregated Data may be derived from your Personal data but is not considered
Personal data in law as this data does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users accessing
a specific website feature. However, if we combine or connect Aggregated Data with your
Personal data so that it can directly or indirectly identify you, we treat the combined data as
Personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of 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 and genetic and
biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect Personal data by law, or under the terms of a contract we have with
you and you fail to provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to provide you with goods
or services). In this case, we may have to cancel a product or service you have with us but we
will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
 Direct interactions. You may give us your Personal Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes Personal
data you provide when you:
 apply for our products or services;
 inquiries, complaints or consultation with us;
 create an account on our website;
 subscribe to our service or publications;
 request marketing to be sent to you;
 apply for our recruitment;
 enter a competition, promotion or survey; or
 give us some feedback.
 Automated technologies or interactions. As you interact with our website, we may
automatically collect Technical Data about your equipment, browsing actions and
patterns. We collect this Personal data by using cookies, [server logs] and other
similar technologies. We may also receive Technical Data about you if you visit other
websites employing our cookies.
 Third parties or publicly available sources. We may receive Personal data about you
from various third parties and public sources.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your Personal data when the law allows us to. Most commonly, we will use
your Personal data in the following circumstances:
 Where we need to perform the contract we are about to enter into or have entered
into with you.
 Where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.
 Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your Personal data other
than in relation to sending third party direct marketing communications to you via email or
text message. You have the right to withdraw consent to marketing at any time by contacting
us.

MARKETING
We strive to provide you with choices regarding certain Personal data uses, particularly
around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what
we think you may want or need, or what may be of interest to you. This is how we decide
which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from
us or if you provided us with your details when you entered a competition or registered for a
promotion and, in each case, you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your Personal data with any
company outside our group of companies for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by
contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to Personal
data provided to us as a result of a product/service purchase, warranty registration,
product/service experience or other transactions.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when
websites set or access cookies. If you disable or refuse cookies, please note that some parts
of this website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your Personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible
with the original purpose. If you wish to get an explanation as to how the processing for the
new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal data for an unrelated purpose, we will notify you and we will
explain the legal basis which allows us to do so.

Please note that we may process your Personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your Personal data with the parties set out below for the purposes set
out in the table in paragraph 4 above.
 Internal Third Parties as set out in the Glossary.
 External Third Parties as set out in the Glossary.
 Third parties to whom we may choose to sell, transfer, or merge parts of our business
or our assets. Alternatively, we may seek to acquire other businesses or merge with
them. If a change happens to our business, then the new owners may use your
Personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your Personal data and to treat it in
accordance with the law. We do not allow our third-party service providers to use your
Personal data for their own purposes and only permit them to process your Personal data for
specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your Personal data within the Mimaki Group. This will involve transferring your data
outside the European Economic Area (EEA).
Many of our external third parties are based outside the European Economic Area (EEA) so
their processing of your Personal data will involve a transfer of data outside the EEA.
Whenever we transfer your Personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following safeguards is
implemented:
 We will only transfer your Personal data to countries that have been deemed to
provide an adequate level of protection for Personal data by the European
Commission. For further details, see European Commission: Adequacy of the
protection of personal data in non-EU countries.

 Where we use certain service providers, we may use specific contracts approved by
the European Commission which give Personal data the same protection it has in
Europe. For further details, see European Commission: Model contracts for the
transfer of personal data to third countries.
 Where we use providers based in the US, we may transfer data to them if they are part
of the Privacy Shield which requires them to provide similar protection to Personal
data shared between the Europe and the US. For further details, see European
Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us
when transferring your Personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your Personal data from
being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In
addition, we limit access to your Personal data to those employees, agents, contractors and
other third parties who have a business need to know. They will only process your Personal
data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal data breach and will
notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your Personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.
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.

In some circumstances you can ask us to delete your data: see Request erasure below for
further information.
In some circumstances we may anonymize your Personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this
information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your
Personal data.
You have the right to:
Request access to your Personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the Personal data we hold about you and to
check that we are lawfully processing it.
Request 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 continuing 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.
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. You also have the right to object where we are processing your
Personal data for direct marketing purposes. 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: (a) if you want us
to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not
want us to erase it; (c) 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; or (d) 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. 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
products or services to you. We will advise you if this is the case at the time you withdraw
your consent.
If you wish to exercise any of the rights set out above, inquire to us by Contact form on the
web site.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your Personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your Personal data (or to exercise any of your other rights). This
is a security measure to ensure that Personal data is not disclosed to any person who has no
right to receive it. We may also contact you to ask you for further information in relation to
your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us
longer than a month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.

10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our
business to enable us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you (both
positive and negative) and your rights before we process your Personal data for our
legitimate interests. We do not use your Personal data for activities where our interests are
overridden by the impact on you (unless we have your consent or are otherwise required or
permitted to by law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your request before
entering into such a contract.
Comply with a legal or regulatory obligation means processing your Personal data where it
is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Mimaki Group.
EXTERNAL THIRD PARTIES
 Service providers who provide IT and system administration services.
 Professional advisers including lawyers, bankers, auditors and insurers who provide
consultancy, banking, legal, insurance and accounting services.
 Regulators, court, public prosecutor, police, consumer information center and other
authorities.
 Logistics service providers to allow direct shipments (Partners listed are most
common, but not limited to)

SUBJECT TO CHANGE
As we continually work on GDPR compliancy, this privacy