Information about the personal data administrator:

Grounds and purposes for which we use your personal data

We process your personal data on the following grounds:

• A contract concluded between us and you in order to fulfill our obligations under it;
• Explicit consent from you – the purpose is specified for each specific case;

In the following paragraphs you will find detailed information about the processing of your personal data depending on the basis on which we process it.

FOR THE PERFORMANCE OF THE CONTRACT OR IN THE CONTEXT OF PRE-AGREED RELATIONS

We process your personal data to fulfill contractual and pre-contractual obligations and to exercise the rights under the contracts concluded with you.

Purposes of processing

• establishing your identity;
• management and execution of your request and execution of a concluded contract;
• preparation of a proposal for concluding a contract;
• preparing and sending an invoice for the services you use with us;
• to provide you with the comprehensive service you need, as well as to collect the amounts due for the services used;
• maintaining correspondence regarding orders placed, processing requests, reporting a problem, and more.
• notification of everything related to the services you use with us;
• creating a user profile;
• detect and/or prevent illegal actions or actions in violation of our terms and conditions for the relevant services;

Data we process on this basis:

On the basis of the contract concluded between us and you, we process information about the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including:

• personal contact details – contact address, email, telephone number;
• identification data – name and surname;
• data on orders placed through the user profile;
• e-mail, letters, information about your troubleshooting requests, complaints, requests, grievances;
• other feedback we receive from you;
• credit or debit card information, bank account number or other banking and payment information in connection with payments made;
• customer number, code or other identifier created for identification;
• IP address when visiting our website;
• demographic data;

The processing of the above personal data is mandatory for us in order to be able to conclude the contract with you and perform it. Without you providing us with the above data, we would not be able to perform our obligations under the contract.

We provide personal data to third parties

We provide your personal data, our main goal is to provide you with quality, fast and comprehensive service. We do not provide your personal data to third parties before we make sure that all technical and organizational measures have been taken to protect this data, and we strive to exercise strict control to fulfill this goal. In this case, we remain responsible for the confidentiality and security of your data.

We provide personal data to the following categories of recipients (personal data administrators):

• Postal operators and courier companies;
• Banks for processing payments made by you;
• persons who, by assignment, maintain equipment, software and hardware used for processing personal data and necessary for the company's activities;
• persons providing consulting services in various fields;

When do we delete data, are there grounds?

We delete the data collected on this basis 5 years after the termination of the contractual relationship, whether due to expiration of the contract, termination or other reason. The period is determined by the 5-year statute of limitations for possible claims under the contract.

FOR FULFILMENT OF REGULATORY OBLIGATIONS

We may be required by law to process your personal data. In these cases, we are required to carry out the processing, such as:

• obligations under the Anti-Money Laundering Measures Act;
• fulfillment of obligations in relation to distance selling, off-premises selling, provided for in the Consumer Protection Act;
• providing information to the Consumer Protection Commission or third parties as provided for in the Consumer Protection Act;
• providing information to the Personal Data Protection Commission in relation to obligations provided for in the personal data protection legislation;
• obligations provided for in the Accountancy Act and the Tax and Social Security Procedure Code and other related regulatory acts, in connection with the keeping of legal accounting;
• providing information to the court and third parties within the framework of proceedings before a court, in accordance with the requirements of the regulatory acts applicable to the proceedings;
• age verification when shopping online;

When do we delete personal data collected on this basis?

We delete data collected pursuant to a statutory obligation once the obligation to collect and store it has been fulfilled or has expired. For example:

• under the Accounting and Accounting Data Processing Act (10 years, starting from January 1 of the reporting period following the reporting period to which they relate)
• obligations to provide information to the court, competent state authorities and other grounds provided for in the current legislation (5 years, starting from January 1 of the reporting period following the reporting period to which they relate)

Providing data to third parties

When we are legally obliged to do so, we may provide your personal data to the competent government authority, natural or legal person.

AFTER YOUR CONSENT

We process your personal data on this basis only after your explicit, unambiguous and voluntary consent. We will not foresee any adverse consequences for you if you refuse to process your personal data.

Consent is a separate ground for processing your personal data and the purpose of the processing is specified therein, and does not overlap with the purposes listed in this policy.

If you give us the relevant consent and until its withdrawal or termination of any contractual relationship with you, we prepare suitable product/service proposals for you by performing detailed analyses of your basic personal data;

Detailed analytics is a method of performing analysis that allows the processing of large volumes of data through statistical models and algorithms, and others that include the use of personal data, as well as processes of pseudonymization and anonymization of the same, in order to extract information about trends and various statistical indicators.

With your explicit consent, we provide your data to marketing agencies and social networks such as GOOGLE, Facebook and others.

Withdrawal of consent

The consents given can be withdrawn at any time. The withdrawal of consent has no impact on the performance of contractual obligations. If you withdraw your consent to the processing of personal data in any or all of the ways described above, we will not use your personal data and information for the purposes specified above. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To withdraw the consent you have given, you only need to use our site or simply our contact details, you can also use the options provided in your profile panel.

Data we process on this basis

On this basis, we only process data for which you have given us your explicit consent. The specific data is determined for each individual case.

Typically, the data includes:

• email
• names
• address
• telephone
• demographic data and interests for advertising on Facebook, Google and the like

When do we delete data collected on this basis?

We delete the data collected on this basis upon your request or 10 years after its initial collection.

Providing data to third parties

On this basis, we may provide your data to marketing agencies, Facebook, Google and the like.

PROCESSING OF ANONYMIZED DATA

We process your data for statistical purposes, meaning for analyses in which the results are only summary and therefore the data is anonymous.

Identifying a specific person from this information is impossible.

Your data can be anonymized. Anonymization is an alternative to data deletion. With anonymization, all personally identifiable elements that allow you to be identified are irreversibly deleted. There is no legal requirement to delete anonymized data, as it is personal data.

How we protect your personal data

To ensure adequate protection of the company's and its customers' data, we implement all necessary organizational and technical measures provided for by the Personal Data Protection Act.

For maximum security in the processing, transmission and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization and others.

Personal data we have received from third parties

From third parties, we receive demographic data and interests for advertising on Facebook, Google and the like, collected by marketing agencies, Facebook, Google and the like.

Consumer Rights

Each user of the site enjoys all rights for the protection of personal data, in accordance with Bulgarian legislation and European Union law. Each User has the right to:

• Awareness (in relation to the processing of his personal data by the administrator);
• Access to your own personal data;
• Correction (if data is inaccurate);
• Erasure of personal data (right to be forgotten);
• Restriction of processing by the controller or processor of personal data;
• Portability of personal data between individual administrators;
• Objection to the processing of his/her personal data;
• The data subject also has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects him or her;
• Right to judicial or administrative redress in the event that the data subject's rights have been violated.

The user may request deletion if one of the following conditions is met:

• The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• The user withdraws his/her consent on which the data processing is based and there is no other legal basis for the processing;
• The data user objects to the processing and there are no overriding legitimate grounds for the processing;
• The personal data has been processed unlawfully;
• The personal data must be erased for compliance with a legal obligation under Union or Member State law to which the controller is subject;
• The personal data were collected in connection with the provision of information society services to children and consent was given by the person with parental responsibility for the child;

The user has the right to restrict the processing of his/her personal data by the administrator when:

• You contest the accuracy of the personal data. In this case, the restriction of processing is for a period that allows the controller to verify the accuracy of the personal data;
• The processing is unlawful, but the User does not want the personal data to be deleted, but instead requests a restriction of their use;
• The Administrator no longer needs the personal data for the purposes of the processing, but the User requires them for the establishment, exercise or defense of legal claims;
• Object to processing pending verification of whether the legitimate grounds of the Administrator override the interests of the User.

Right to portability

The subject has the right to receive data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided, where the processing is based on consent or a contractual obligation and the processing is carried out by automated means. When exercising the right to data portability, the data subject shall also have the right to obtain the direct transmission of the personal data from one controller to another, where technically feasible.

Right to object

Users have the right to object to the processing of their personal data to the controller. The controller shall be obliged to stop the processing unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. In the event of an objection to the processing of personal data for direct marketing purposes, the processing shall cease immediately.

Complaint to a supervisory authority

Every user has the right to file a complaint against unlawful processing of his or her personal data to the Personal Data Protection Commission or to the competent court.

Maintaining a register

We maintain a register of the activities for which we are responsible. This register contains all of the information listed below:

• the name and contact details of the administrator;
• the purposes of the processing;
• description of the categories of data subjects and the categories of personal data;
• the categories of recipients to whom personal data are or will be disclosed, including recipients in third countries or international organisations;
• where possible, the time limits for erasure of the different categories of data;
• where possible, a general description of the technical and organisational security measures.