Privacy Policy


The privacy of personal data is important to Comac Medical and Comac Medical processes any personal data only in accordance with  company’s  Data Protection and Privacy Policy complying with all the requirements ot the local, EU and international legislation. Herein are stated the basic terms of data processing within Comac Medical group. Comac Medical collects individual’s personal data in case an individual chooses to provide it to Comac Medical. We do not share any of the personal data with third parties for their own marketing use. All personal data is collected, processed and stored according to the requirements of the 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).

Please review this Privacy Terms to learn more about how we collect, use, share and protect data online.

This Privacy Terms apply to all Personal Data, either in electronic or paper format, received by Comac Medical in the EU or a country where Comac Medical operates, outside EEA.

  • Personal Data is any data or set of data that identifies or could be used by or on behalf of Comac Medical to identify an Individual. Comac Medical is data controller that processes personal data in accordance with all applicable local, EU and international legislation. Comac Medical collects personal data for operational purposes only following the GDPR and local law requirements. All personal data is collected, processed and stored in compliance with data protection laws. Personal data could be collected by Comac Medical both on paper and/ or electronically Personal Data does not include data that is anonymized such that an individual cannot be identified;
  • An individual is any real, actually existing, person located in the European Union or a country оутсиде ЕЕА, whose personal data is shared with Comac Medical;
  • Third-party is any entity different than the individual and Comac Medical;
  • General Data Protection Regulation (GDPR) is 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.
  • If personal data is collected, processed and used via company’s website or in apps, the data subjects are informed of this in a privacy notice/statement and, if applicable, information about cookies.
  • The Privacy Notice/s and any cookie information is integrated so that it is easy to identify, directly accessible and consistently available for the data subjects. If use profiles (tracking) are created to evaluate the use of websites and apps, the data subjects must always be informed accordingly in the privacy statement.
  • Personal tracking may only be performed if it is permitted under national law or upon consent of the data subject. If tracking uses a pseudonym, the data subject should be given the chance to opt out in the privacy statement.
  • When websites or apps can access personal data in an area restricted to registered users, the identification and authentication of the data subject must offer sufficient protection during access.


Data collected through Comac Medical website
Comac Medical website could be visited without providing any personal data.

Comac Medical automatically receives certain types of data whenever an individual interacts with us on our site. Automatic technologies and services Comac Medical uses may include, for example, web server logs/IP addresses and third-party application and content tools such as:

  • Web Server Logs/IP Addresses: An IP address is a number assigned to a computer whenever it accesses the Internet. All computer identification on the Internet is conducted with IP addresses, which allow computers and servers to recognize and communicate with each other. Comac Medical collects IP addresses to conduct system administration and web site performance review.
  • Cookies: A cookie is a piece of data that is placed automatically on an individual computer’s hard drive when somebody accesses certain web sites. The cookie uniquely identifies an individuals’ browser to the server. Comac Medical site uses cookies.
  • Aggregate data: In some cases, Comac Medical may remove personal identifiers from data an individual has provided and maintain it in aggregate form. This data may be combined with other data to produce anonymous, aggregated statistical data (e.g. number of visitors, originating domain name of the Internet Service Provider), helpful to us in improving our products and services.
  • Security
    Comac Medical uses technology and security precautions, rules and other procedures to protect the personal data from unauthorized access, improper use, disclosure, loss or destruction. To ensure the confidentiality of an individual’s data, Comac Medical applies suitable technical or organizational measures and safeguards can depending on the context and risks associated with the processing in question including but  not only, having malware detection systems; data loss prevention systems, training employees about basic “cyber hygiene”; establishing privacy and information security management systems, obligating processors contractually to implement specific data minimization practices.


Use of Data
Comac Medical, including all its subsidiaries, divisions and groups worldwide and/or the companies we hire to perform services on our behalf or on behalf of our clients will use any personal data an individual chooses to provide to us to comply with the individual’s requests. We will retain control of and responsibility for the processing of this data in full compliance with the local law and EU requirement under monitoring and advice of the appointed company data protection officer who is involved, properly and in a timely manner, in all issues which relate to the protection of personal data.

Data Sharing and Transfer
Comac Medical may share personal data with its clients for the purposes of performing its main activities. Comac Medical may also share personal data with our company’s subsidiaries and affiliates. All these companies within Comac Medical group are required to comply with the terms of Comac Medical Data Protection and Privacy Policy and all other data relevant company policies and Standard Operative Procedures. A transfer of personal data to a third country (outside EEA) or an international organization may take place where the EU Commission has decided that the third country ensures an adequate level of protection. In the absence of an adequacy decision Comac Medical, as a controller or processor may transfer personal data to a third country or an international organization only if it has secured appropriate safeguards, as specified by GDPR.

We may also disclose personal data  to respond to appropriate requests of legitimate governmental agencies/authorities or where required by applicable laws, court orders, or government regulations.

No Third-Party Direct Marketing Use: Comac Medical will not sell or otherwise transfer the personal data  provided to us at our web sites or in-person to any third parties for their own direct marketing use.

Privacy Terms for Children
Comac Medical does not collect any personally identifiable data from anyone we know to be under the age of 18 without the prior, verifiable consent of his or her legal representative/s. Such a legal representative/s has the right, upon request, to view the data provided by the child and/or to require its deletion.

Links to Other Sites
Comac Medical website contains links to a number of web sites that may offer useful information to our visitors. This Privacy Terms does not apply to those sites. It is recommended that an individual communicates to them directly for information on their privacy policies.

Updates to Privacy Terms
From time to time, Comac Medical may revise this Privacy Terms. Any such changes to this Privacy Terms will be promptly communicated on its webpage. Continued use of our sites and services provided to individuals after a posted change in our Privacy Terms indicates the individual’s consent to the use of newly submitted data in accordance with the amended Privacy Terms.

How to Contact Comac Medical
For questions or if you wish to contact Comac Medical for any data privacy related reason, please contact us in writing (by post), as follows:

Comac Medical Ltd.

69, Bulgaria blvd., fl.7

Tower (Building) B

1404 Sofia, Bulgaria

or by DPO E-mail: privacy@comac-medical.com

or by telephone: +359 2 8921000