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PRIVACY POLICY

GENERAL INFORMATION

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From May 25, 2018 a new regulation for the protection of personal data (General Data Protection Regulation), adopted by the European Union, is in force. The regulation aims to ensure the protection of the data of natural persons from all EU member states and to unify the regulations for their processing.

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In its capacity as a personal data administrator for the provision of services, VARNA FOOD LTD meets all the requirements of the new regulation, collecting only the data of individuals to the extent that it is necessary for the provision of the service - delivery of goods, and keeps them responsibly and legally .

 

 

Information about the controller of personal data

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Name "VARNA FOOD" LTD

2. EIK/BULSTAT: 103642986

3. Headquarters and address of management:  BULGARIA, city of Varna, Primorski district, 5 VOYNISHKA str., entrance. 1, fl. 1

4. Address for correspondence: BULGARIA, city of Varna, Primorski district, 5 Voynishka street, entrance 1, fl. 1

5. E-mail:  agrovarna@abv.bg

6. Phone: +359 896 666 222

7. Website:  https://www.hazelnut.bg

 

Information about the competent supervisory authority

 

1. Name: Commission for Personal Data Protection

2. Headquarters and management address: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2

3. Correspondence details: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2

4. Phone: 02 915 3 518

5. Email:  kzld@government.bg ,  kzld@cpdp.bg

6. Website:  www.cpdp.bg

 

"VARNA FOOD" LTD carries out its activities in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons in in relation to the processing of personal data and on the free movement of such data.

The texts below will explain to you what information we need, why we need it and how we use it. It is your right to limit our access to it, as well as to completely delete your personal data from our site.

 

Basis for collecting, processing and storing your personal data

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Art. 1. The administrator collects and processes your personal data in connection with the use of the online store   www.hazelnut.bg   and concluding contracts with the company on the basis of Art. 6, para. 1, Regulation (EU) 2016/679 (GDPR), and more specifically on the following grounds:

  • Express consent received from you as a customer;

  • Fulfillment of the Administrator's obligations under a contract with you;

  • Compliance with a legal obligation that applies to the Administrator;

  • For the purposes of the legitimate interests of the Administrator or a third party;

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Purposes and principles in the collection, processing and storage of your personal data

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Art. 2. (1) We collect and process the personal data that you provide us in connection with the use of the online store  www.hazelnut.bg   and the conclusion of a contract with the company , including for the following purposes:

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  • creating a profile and providing full functionality when using the online store;

  • individualization of a party to the contract;

  • accounting purposes;

  • statistical purposes;

  • protection of information security;

  • ensuring the performance of the contract for the provision of the relevant service;

  • sending a newsletter and e-mails with special offers upon your request;

  • sending advertising materials and product samples from other companies through "VARNA FOOD" LTD if you wish;

  • sending responses to inquiries made through the feedback form on our website;

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(2) We observe the following principles when processing your personal data:

  • legality, good faith and transparency;

  • limitation of processing purposes;

  • relevance to the purposes of the processing and minimization of the data collected;

  • accuracy and timeliness of data;

  • limitation of storage in order to achieve the objectives;

  • integrity and confidentiality of processing and ensuring an appropriate level of personal data security.

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(3) When processing and storing personal data, the Administrator may process and store personal data in order to protect the following legitimate interests:

  • fulfillment of obligations to the National Revenue Agency, the Ministry of Internal Affairs and other state and municipal bodies.

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What types of personal data does our company collect, process and store

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Art. 3. (1) The company performs the following operations with the personal data provided by you as customers, for the following purposes:

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  • Registration of a customer in the e-store and execution of a remote purchase and sale contract - the purpose of this operation is to create a profile for using the e-store to purchase goods and provide contact details for delivery of purchased goods. Registration and creation of an account to use the online store is not a mandatory step of providing the service and it is available to a significant extent without creating an account through the option "Order as a guest" - Conclusion of the impact assessment: Based on the evaluation of impact, the personal data protection officer considers that the operation "Registration of a user in the electronic store and execution of a contract of purchase and sale at a distance" is permissible to carry out and provides sufficient guarantees to protect the rights and legitimate interests of the data subjects in accordance with GDPR requirements;

  • Sending a newsletter (newsletter) – the purpose of this operation is to administer the process of sending newsletters, e-mails with special offers, promotions, promo codes, news and new features to customers who have indicated that they wish to receive them. Given the limited scope of personal data collected, the Personal Data Protection Officer considers that conducting an impact assessment is not necessary to conduct an impact assessment of the operation.

  • Exercising the right of refusal or making a complaint - the purpose of this operation is to administer the process of exercising the right of refusal or complaint by the customer for the goods in respect of which these rights can be exercised. Given the limited scope of personal data collected, the Personal Data Protection Officer considers that conducting an impact assessment is not necessary to conduct an impact assessment of the operation.

  • Provision of advertising materials and sampling from other companies through "VARNA FOOD" LTD - the purpose of this operation is to administer the process of sending advertising materials and product samples from other companies through "VARNA FOOD" LTD to customers who have requested , that they wish to receive them. Given the limited scope of personal data collected, the Personal Data Protection Officer considers that conducting an impact assessment is not necessary to conduct an impact assessment of the operation.

  • Making inquiries through the feedback form on the website in the Contact section - the purpose of this operation is to send a response to an inquiry. Given the limited scope of personal data collected, the Personal Data Protection Officer considers that conducting an impact assessment is not necessary to conduct an impact assessment of the operation.

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(2) The administrator does not collect or process personal data relating to the following:

  • reveal racial or ethnic origin;

  • reveal political, religious or philosophical beliefs, or membership in trade unions;

  • genetic and biometric data, health data or data about sex life or sexual orientation.

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(3) The personal data are collected by the Administrator from the persons to whom they relate.

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(4) The administrator does not perform automated decision-making with data.

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(5) The company does not collect data on persons under the age of 16, except with the express consent of their parent or legal representative.

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Art. 4. (1) The administrator processes the following categories of personal data and information for the following purposes and on the following grounds:

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  • Your personalizing data (email, name, etc.)

    • Purpose for which the data is collected: 1) Making contact with the user and sending information to him, 2) for the purposes of registering a user in the online store, as well as 3) for sending a newsletter, e-mails with special offers, promotions , promo codes, news and new features and 4) sending a response to an inquiry through the form on our website.

    • Basis for processing your personal data - By accepting the general conditions and registering in the electronic store or placing an order without registration, or when concluding a written contract, a contractual relationship is created between the Administrator and you, on the basis of which we process your personal data - art. . 6, para. 1, b. (b) GDPR. Your data for sending newsletters and e-mails, as well as for sending a response to an inquiry using the form on our website, are processed based on your express consent - Art. 6, para. 1, b. (a) GDPR.

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  • Delivery data (names, phone, address, etc.)

    • Purpose for which the data is collected: 1) Fulfillment of the administrator's obligations under the sales contract and delivery of the purchased goods and 2) Sending advertising materials and samples of products from other companies through "VARNA FOOD" LTD to the customers, who have stated that they wish to receive them.

    • Basis for processing your personal data - By accepting the general conditions and registering in the electronic store or placing an order without registration, or when concluding a written contract, a contractual relationship is created between the Administrator and you, on the basis of which we process your personal data - art. . 6, para. 1, b. (b) GDPR.

      Your data for sending advertising materials and product samples is processed on the basis of your express consent - Art. 6, para. 1, b. (a) GDPR.

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  • Data from your social network profiles (publicly available information from your Google+, Facebook profiles)

    • Purpose for which the data is collected: 1) Making contact with the user and sending information to him and 2) for the purposes of user registration in the online store.

    • Basis for processing your personal data - With the acceptance of the general conditions and registration in the electronic store through a social network profile, a contractual relationship is created between the Administrator and you, on the basis of which we process your personal data - art. 6, para. 1, b. (b) GDPR.

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Duration of storage of your personal data

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Art. 5. (1) The administrator stores your personal data for a period not longer than the existence of your profile in the online store or placing the order "as a guest". After deleting your account or completing the order, the Administrator takes the necessary care to delete and destroy all your data without unnecessary delay or to anonymize it (ie to make it in a form that does not reveal your identity).

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(2) The Administrator stores your personal data, provided in connection with online orders, for a period of 5 years for the purpose of protecting the legal interests of the Administrator in legal or administrative disputes with users of the online store, and the accounting documents are stored for the relevant statutory term.

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(3) The Administrator notifies you in the event that the data storage period needs to be extended in order to fulfill a legal obligation or in view of legitimate interests of the Administrator or otherwise.

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(4) The administrator stores the personal data that it is necessary to keep by virtue of the applicable legislation for the relevant stipulated period, which may exceed the period of existence of your profile in the electronic store or until the completion of the order.

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Art. 6. (1) The Administrator stores the personal data of the legal representatives of its commercial partners for the period of performance of the contract, to comply with the legitimate interests and legal obligations of the Administrator, and this period may exceed the term of the concluded contract.

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Transmission of your personal data for processing

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Art. 7. (1) The administrator may, at his own discretion, transfer part or all of your personal data to processors of personal data for the fulfillment of the purposes of processing to which you have agreed, subject to compliance with the requirements of Regulation (EU) 2016/679 (GDPR) .

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(2) The administrator notifies you in case of intention to transfer part or all of your personal data to third countries or international organizations.

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Your rights in the collection, processing and storage of your personal data

Withdrawal of consent to the processing of your personal data

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Art. 8. (1) If you do not wish all or part of your personal data to continue to be processed by the Company for specific or all processing purposes, you can at any time withdraw your consent to processing by filling in the form in your profile or by free text request.

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(2) The administrator may request that you verify your identity and identity with the person to whom the data relates.

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(3) With the withdrawal of consent to the processing of personal data, which is mandatory for the creation and maintenance of a profile in the online store, your account will become inactive. Of course, you will be able to browse the online store and the products offered and place orders as a guest or make a new registration.

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(4) If there is an order placed by you that is being processed, the earliest you can withdraw your consent to processing is upon successful completion of the order.

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(5) You may at any time withdraw your consent to the processing of your personal data for direct marketing purposes.

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(6) The withdrawal of consent does not affect the legality of the processing of personal data, which the Administrator has carried out up to this point.

Right of access

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Art. 9. (1) You have the right to request and receive confirmation from the Administrator as to whether personal data related to you is being processed, and you can at any time see in your profile, if you are a registered user, the data that we are processing for you..

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(2) You have the right to access the data related to you, as well as the information related to the collection, processing and storage of your personal data.

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(3) Upon request, the administrator shall provide you with a copy of the processed personal data related to you in electronic or other appropriate form.

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(4) Providing access to the data is free of charge, but the Administrator reserves the right to impose an administrative fee in case of repetitive or excessive requests.

Right to rectification or completion

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Art. 10. You can correct or complete inaccurate or incomplete personal data related to you directly through your profile on the website or by making a request to the Administrator.

Right to erasure ("to be forgotten")

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Art. 11. (1) You have the right to request from the Administrator the deletion of part or all of your personal data, and the Administrator has the obligation to delete them without undue delay, when any of the following grounds are present:

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  • the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

  • You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;

  • You object to the processing of your personal data, including for direct marketing purposes, and there are no overriding legal grounds for the processing;

  • the personal data were processed unlawfully;

  • the personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the Administrator;

  • personal data were collected in connection with the provision of information society services.

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(2) The administrator is not obliged to delete the personal data if it stores and processes them:

  • to exercise the right to freedom of expression and the right to information;

  • to comply with a legal obligation that requires processing provided for in EU or Member State law applicable to the Administrator or for the performance of a task in the public interest or in the exercise of official powers conferred on him;

  • for reasons of public interest in the field of public health;

  • for the purposes of archiving in the public interest, for scientific or historical research or for statistical purposes;

  • for the establishment, exercise or defense of legal claims.

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(3) In case of exercising your right to be forgotten, the Company will delete all your data, except for the following information:

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  • information that is necessary to verify that your right to be forgotten has been met - email, IP address;

  • technical information about the functioning of the online store, which information cannot be linked in any way to your person;

  • e-mail with which you registered in the online store.

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(4) In order to exercise your right to be forgotten, you need to take the following steps:

  • Submit a request through your account in the online store or by email;

  • To present a unique identification code to perform the action, which will be sent to you by e-mail to the e-mail address associated with the registration made in the online store;

  • Identify yourself as the account holder;

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(5) Once we have verified the identity of the person who made the request and the person to whom the data relates in accordance with the above steps, we will delete all data that we process about you in accordance with para. 3.

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(6) If there is an order placed by you that is being processed, the earliest you can request to be "forgotten" is upon successful completion of the order.

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(7) By deleting your personal data, your account will become inactive. Of course, you will be able to browse the online store and the products offered and place orders as a guest or make a new registration.

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(8) The administrator does not delete the data that he has a legal obligation to store, including for defense in connection with legal claims made against him or to prove his rights.

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Right to limitation

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Art. 12. You have the right to request the Administrator to limit the processing of your data when:

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  • dispute the accuracy of the personal data, for a period that allows the Administrator to verify the accuracy of the personal data;

  • the processing is illegal, but you do not want the personal data to be deleted, but only to have its use restricted;

  • The administrator no longer needs the personal data for the purposes of processing, but you require them to establish, exercise or defend your legal claims;

  • You have objected to the processing pending verification of whether the legal grounds of the Administrator take precedence over your interests.

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(2) In case of exercising your right to restriction, the Company will stop processing your data, but will not remove the publications you have made in the online store.

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Right of portability

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Art. 13. (1) If you have consented to the processing of your personal data or the processing is necessary for the performance of the contract with the Administrator, or if your data is processed in an automated manner, you may, after identifying yourself to the Administrator:

  • to ask the Administrator to provide you with your personal data in a readable format and to transfer them to another Administrator;

  • to ask the Administrator to directly transfer your personal data to an administrator specified by you, when this is technically feasible.

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(2) You can at any time download or receive in a machine-readable format the data that is stored and processed for you in connection with the use of the Administrator's services, directly through your profile through the data export option or by request on email.

Right to receive information

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Art. 14. You may request the Administrator to inform you about all recipients to whom the personal data for which correction, deletion or restriction of processing has been requested has been disclosed. The administrator may refuse to provide this information if it would be impossible or would require a disproportionate effort.

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Right to object

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Art. 15. You may object at any time to the Administrator's processing of personal data relating to you, including if it is processed for the purposes of profiling or direct marketing.

Your rights in the event of a breach of the security of your personal data

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Art. 16. (1) If the Administrator detects a violation of the security of your personal data, which may create a high risk for your rights and freedoms, he shall notify you without undue delay of the violation, as well as of the measures that have been taken or are about to be taken .

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(2) The administrator is not obliged to notify you if:

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  • has taken appropriate technical and organizational measures to protect the data affected by the security breach;

  • has subsequently taken measures to ensure that the breach will not result in a high risk to your rights;

  • notification would require a disproportionate effort.

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Persons to whom your personal data is provided

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Art. 17. For the purposes of processing your personal data and providing the service in its full functionality and in view of your interests, the Administrator may provide your data to the following processors of personal data:

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Personal data processor - Purpose of personal data processing

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Shipper - Make a delivery to an address

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The indicated processors of personal data comply with all requirements for legality and security when processing and storing your personal data.

Art. 18. The administrator does not transfer your data to third countries.

Art. 19. In the event of a violation of your rights under the above or applicable personal data protection legislation, you have the right to file a complaint with the Personal Data Protection Commission as follows:

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Name - Personal Data Protection Commission

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Headquarters and management address - Sofia 1592, "Prof. Tsvetan Lazarov" No. 2

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Address for correspondence - Sofia 1592, "Prof. Tsvetan Lazarov" No. 2

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Phone - 02 915 3 518

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Website -  www.cpdp.bg

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Art. 20. You can exercise all your rights regarding the protection of your personal data through the forms attached to this information or through the functionalities in your profile. Of course, these forms are not mandatory and you can make your requests in any form that contains a statement to that effect and identifies you as the data owner.

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Art. 21. If the consent refers to a transfer, the Administrator describes the possible risks for the transfer of the data to third countries in the absence of a decision for adequate protection and suitable means of protection.

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Art. 22. The Company may amend the Privacy Policy by posting a notice to that effect on its website.

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