Privacy Policy

1. European Subcontracting Network and its partners companies (“ESN”)  respects your integrity and commits to process personal information in a lawful and accountable manner in accordance with prevailing information practices as well as relevant data protection and privacy laws. ESN has therefore created this policy to provide you with information on how we collect store, use and/or share information as well as information concerning individual rights as a data subject and how you can exercise them. This policy applies only to information we process from subcontractors and general contractors in connection with ESN platform (www.subcontracteu.com) (the “site”). It does not apply to information processing done by other websites linked from this site. Please note that by using the ESN website and platform, you are deemed to have read and accepted this Policy and agree to be bound by it. If you do not agree with our information management practices, please do not use the ESN platform and website.
   ESN’ s is an online market place operated by ESN Ltd, a company based in Varna, Bulgaria and having its registered office at 36 Feliks Kanitz str., 9009 Varna, Bulgaria and company UIC 204768412. ESN acts as a data controller with respect to all information collected in connection with access and use of the ESN website.
2. Information we collect:
   ESN collects information which is necessary for the delivery of ESN services and compliance with its contractual and legal obligations. Some of the information we collected is provided directly by you (personal and company information) while other information is automatically generated when you use or access this website. Personal information is information that relates to an identified or identifiable physical person: information which can reasonably identify, directly or indirectly, person trough identifiers such as name, contact in formation, location data, or online identifiers. We collect the following information:

• Personal information (name and email)
• Company information such as company name, logo, corporate email, telephone number, website,  physical address, contact person or registered agent, DUNS number, VAT number, country of registration, sector of activity, specialisation , as well as information relating to company products and services. At discretion, users may also attach company portfolio or presentation including photographs or documents.
• Web usage information: We collect information relating to your use of ESN website, services and products, including your internet protocol address, approximate geographical location, information about the device used to view the website (device type and operating platform) as well as the type of internet browser user to view the website. Some information of this information is also collected using cookies and web tracking technologies.

3. Cookies: This website uses cookies to tailor content and to provide measure internet traffic to our website.  We may also share information about your use of the site with our advertising and web analytics partners who may combine such information with other information you have provide to them or which they have collected from other sources.

What are cookies? A cookie is a tiny file containing a string of random data. This file is saved on your browser’s cookie file when you visit our website. Cookies are useful in a number ways and are of different types.

 At ESN we use two types of cookies: session cookies (temporary cookies) as well as persistent cookies (“permanent cookies”). Session cookies are cookies that manage the user’s browsing session. They are only active while users navigate the site and are erased when a user leaves the site or closes the browser. Session cookies help to make the site usable by enabling basic functions like log in and navigation. Session cookies remember log in information and enable registered users to access the secure area of the site. Persistent cookies, or so called permanent cookies, are cookies that are stored in a user’s device for longer period until their defined expiration time or until the user deletes them manually. These types of cookie help to remember user preferences including for example preferred language or the location from which you access the website. We use both types of cookies for statistics purposes to understand how users use the ESN platform and to collect and compile anonymous information such as number of visitors , popular pages as well as the origins of web traffic to the website.

To control cookies being saved on your device, please review the privacy and security settings of your internet browser.

4. Lawful Grounds for collecting information: We collect and use personal information on the following lawful reasons:
   • For performance of contract between ESN and you and/or to facilitate any negotiations between you and us before entering into contract.
   • In ESN’s legitimate interest to operate its business effectively.
   • To comply with any legal requirement to which ESN is subject
   • In accordance with your consent, where consent is required by law for the processing of certain information.
   • To protect your vital interests as a user of the ESN platform.

5. How we use your information:
   • Provide access to the ESN platform and its services. We will use your information as necessary to provide you with access to our database and services. For example we use your name and email to register you and create your user account and grant you access to those services which require registration. We use company information to create your company profile and grant you access to our digital audience, eBid system, marketing services, outsourcing services, pricing data, research data and reports, as well as provide access to a database of potential suppliers, buyers or subcontractors. We may also use your information in the performance of our administrative and customer support services.
      
   • Improve the ESN website and its services: ESN strives to be a safe, reliable and an effective platform where EU subcontractors/suppliers can utilize the leverage of updated information in the subcontracting industry. ESN will use certain information to analyse and understand how contractors, suppliers and buyers use the ESN services and website with the sole aim of improving its efficiency.
      
   • Communication: We will use your contact information to respond to respond to your enquiries and provide information related to service you purchased from us including for example price requests and alerts on your eBids auctions. If you agree to receive marketing information from us, we will use your email address to send information about news, releases, tips and other industry information that we think would be valuable to your company.
      
   • Safety and Legal compliance: ESN strives to be a safe and secure online market place and we always work to ensure the integrity of this website. We may collect, store and process personal information as necessary to enforce our rights under our Terms ad Conditions and applicable laws. ESN will also collect nd store some information protect our customers and to detect and prevent fraud, financial crimes as well as misuse of the ESN platform and services.  Where we are required by applicable law to collect, store and disclose specific data (including for example sales tax and accounting purposes), we will handle such data as required by the law.
      
   • Marketing: ESN works to ensure that EU subcontractors and suppliers get the best market exposure possible. We will use your information in our marketing and advertising campaigns.  We may also use your contact information to send information about potential companies that could be relevant to your business. If you subscribed to our newsletter, we will user your email to send information about special offers, discounts, events and or releases happening at the ESN.
      
6. How we share information: ESN may have to share certain personal and non-information under the following circumstances:
   • Service providers and business partners:  Certain portions of company information will be publicly accessible. We may share certain personal and company information to our partner companies, service providers, marketers or other providers who deliver services and products to you on our behalf.
   • Business transfer or sale: Where ESN is sold to, acquired by or merged with any company or organization, we may share information to the newly formed company as necessary for completion of such merger, sale or acquisition. This information may include personal information such as customer lists.
   • To comply with the law:  We may share information to governmental regulatory or enforcement agencies when required to so by law or court order.
   • Marketing: we will share your company information, with your consent, to our marketers and advertisers.
      
7. International transfers:  Please note that ESN endeavours as much as possible to process all information received in connection with the ESN platform within the European Union/European Economic Area. Please note however our partner companies and service providers may be located outside of the EU/EEA and in this regard personal as well as non-personal information may be transmitted to other jurisdictions which have other standards of privacy protection. This includes for example providers who provide web hosting and email delivery services to us. In those cases, we will take measures to ensure that your personal information is afforded with adequate safeguard including entering into data processing agreement, which set out sufficient protection requirements for processing of personal data. Where applicable, and in accordance with the law, we may request your consent for such transfers.
    
8. Data retention: ESN will keep personal and company information for as long as it is required for the purposes for which it was collected. Information collected for contractual performance will normally be kept for the entire duration of contract and for an additional period as may be required or permitted by applicable law.
    
9. Protecting your information: ESN take precautionary measures to safeguard personal information from loss, misuse or unauthorised access, sharing and destruction. We have implemented suitable technical and organisational measures aimed to protect our database where your personal information is stored. This includes encryption, malware scanning and use of personal passwords. We also require our affiliated parties and service providers to protect your personal information in accordance with this policy and our data processing agreements. In addition, ESN has implemented role-based access policy and buyer’s registration is only visible to website administrators.
    
10. Links:  ESN allows subcontractors and general contractors to include links to their websites on its platform. ESN does not screen, review, manage or control the linked websites and is not responsible for information collection activities done by such contractors. Our inclusion of the links is for convenience only and not an assurance that those websites are secure or reliable. If you use the links, you agree that you do so at your own risk.
     
11. Your Rights: Your rights may vary depending on the laws applicable in your jurisdiction. ESN processes personal data in accordance with the EU General Data Protection Regulation which applies to all entities processing data of EU/EEA citizens. Under that law, you have the right to:
    • Information and access: You can request to have access to your information and obtain a copy of your information. This right has some limitations.  Access to information may be denied if it is repetitive or if it could violate another person’s privacy.
    • Data rectification: You have the right to request the correction or updating of erroneous or outdated information.
    • Data erasure: You may have a right to erase your personal information. This right may have some limitations.
    • Object to  processing of personal information: You have the right, under certain circumstances, to object to specific types of processing of personal data including for example processing for direct marketing, research nd statistical purposes or processing based on our legitimate interests
    • Restrict the processing of personal information: You have the right to restrict access to your personal information including for example the restriction that your personal information should only be handled by ESN, and not be processed by other entities, as long as the restriction is in place or while your complaints is being processed.
    • Data Portability:  You have the right to request portability of your information. This means the right to obtain your personal information in a structured, commonly used and machine-readable format so that is can easily be transferred by you or us to another company.  
       
12. Consent and withdrawal of consent:  Where consent is the lawful basis for the collection and use of your personal information or special categories of personal information, you have the right, at any time, to withdraw consent previously given for a certain purpose, without charge, by contacting our Data Protection Officer.
     
13. Data Protection Officer: For enquiries about privacy protection and data subject access rights, please send your enquiries to our human resource department our data protection officer (privacy@subcontracteu.com).
     
14. Changes in our Privacy Policy: We may update this policy where necessary. This policy may also be revised so as to comply with legal requirements of your jurisdiction. In case of changes to the policy, ESN will post the revised policy on the website and notify you via the email supplied to us upon registration.

This policy was last updated on 25 August 2018.