I. General Provisions
“Wine Marketer” EOOD, UIC 206512002, with registered office and address of management: Bulgaria, Varna, 98 Slivnitsa Boul., represented by Maria Blagovestova Doganova (hereinafter “Wine Marketer”) is a data controller within the meaning of 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 (Regulation (EU) 2016/679) and the Bulgarian Personal Data Protection Act.
Wine Marketer espects the sanctity of private life of individuals and representatives of legal entities using its services and does its utmost to protect their personal data when processed.
The Privacy Policy of Wine Marketer has been prepared and is based on the Bulgarian and European legislation in the field of personal data protection, and all its amendments and annexes will be published on the website winemarketer.eu.
II. Definitions
“Personal data” means any information relating to an identified or identifiable natural person (“data subject”). A natural person that can be identified is a person that can be identified directly or indirectly, in particular by their name, identification number (e.g. PIN), location data, online identifier or by one or more features specific to that individual’s physical, physiological, genetic, mental, intellectual, economic, cultural or social identity.
“Processing of personal data” means any action or set of actions performed by the data controller with respect to personal data through automatic or non-automatic means (e.g. collection, recording, organization, grouping, storage, adaptation, updating or correction, modification, restoration, disclosure by transmission or provision, distribution, combination, blocking, deletion, destruction, etc.).
III. Reasons and Goals for Collecting, Processing and Storing your Personal Data.
Wine Marketer collects and processes the following personal data when using the online store, booking wine tours, using the contact form, subscribing to an e-newsletter and using the winemarketer.eu website:
- 1. Name and surname;
- 2. Email;
- 3. Phone number;
- 4. Shipping address;
- 5. Cookie data.
Wine Marketer collects these personal data of yours with the following goals:
- 1. Identification of returning users of the website and statistical needs;
- 2. Identification of the author of the message, carrying out meaningful correspondence and addressing the response to the author of the message;
- 3. Sale and delivery of goods purchased from the online store;
- 4. Offering and performing consulting, marketing and other services;
- Sending an e-newsletter containing information about current publications, promotions and offers.
Personal data are collected about the person only after the voluntary and informed consent of the person. Wine Marketer does not use personal data for purposes other than those specified, and does not perform automated decision-making or profiling.
IV. Principles for Collecting and Processing your Personal Data.
When processing your personal data, Wine Marketer observes the following principles:
- – Legality, good faith and transparency;
- – Limiting the purposes of processing;
- – Sao tnosimost with the purpose of processing and minimization of data collected;
- – Limitation of storage for a minimum period in order to achieve the objectives;
- – Explicit consent of the data subject for data processing;
- – Integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.
V. Disclosure of Personal Data to Third Parties.
Collected personal data can be provided to our partners, when that is necessary for providing Wine Marketer’s services: in relation to the maintenance of information systems on the web site; when making accounting entries of orders; when booking wine tours; when making payments through external payment service providers; when providing data for delivery to a courier company; when processing personal data on behalf of Wine Marketer by our partners such as Google Tag Manager, Google Analytics, Facebook Pixel and others.
We adhere to the requirements that personal data may be used only within the limits set by the legal grounds on which it is collected or by your own consent regarding the processing carried out on behalf of Wine Marketer and regard this information is confidential. In all cases, Wine Marketer strives to provide no more than the required minimum of personal data, as well as to ensure that these third parties act in full compliance with applicable personal data protection legislation and make adequate efforts to protection of personal data of customers.
Wine Marketer also provides personal data to third parties where disclosure of such personal data is an obligation by law.
VI. Term of Storage
The personal data of individuals collected and processed in connection with services provided via the website of Wine Marketer are stored until the purposes for which they are collected or until the withdrawal of consent to provide personal data – whichever of these circumstances occurrs earlier.
Wine Marketer can store personal data in an anonymized form for longer periods, e.g. for statistical purposes.
VII. Online Store
The online store allows you to easily and conveniently buy goods to be delivered to the address you specified. Orders are carried out without registering an account on the website. By accepting the General Terms and Conditions and placing and order perform contract creates a contractual relationship which is the basis for processing personal data necessary for performance of the contract in accordance with Regulation (EU) 2016/679 – first and last name, email, telephone, delivery address.
VIII. E-Newsletter
With our e-newsletter we regularly inform you about current informative publications, promotions and proposals related to the activities of Wine Marketer. If you wish to receive the e-newsletter, we will need your valid email address. When registering for our e-newsletter we use a double inclusion procedure. This means that after registration we will send a message with a link to the provided email address, asking you to confirm that you want to receive our e-newsletter. If you do not confirm your registration on the relevant link within 2 weeks, you will not receive the e-newsletter, and the collected personal data will be deleted automatically after one month. In addition, we store in each case the IP addresses used and the time of entry and confirmation. The purpose of the procedure is to be able to prove your registration and where necessary to clarify any potential misuse of your personal data. As a subscriber to the e-newsletter, you can withdraw your consent to the processing of your personal data at any time from the email where you receive the e-newsletter. The consent can be withdrawn through a link provided for this purpose in the content of the e-newsletter itself or by sending an e-mail entitled “unsubscribe from e-newsletter” to [email protected] .
IX. Individualization and Cookies.
New technologies allow us to customize our website for each individual user. Cookies are text files that contain information that allows returning users to be identified. Cookies are stored locally on the device you use to access our website winemarketer.eu and do not cause harm to your system. Cookies help us identify your preferences (appearance and usability settings). The accumulation and analysis of this information allows us to improve our electronic services and overall user experience so that they conform to the highest degree of your needs. You can learn about cookies and other technologies we use in our Cookie Policy.
X. Your Rights in the Collection, Processing and Storage of your Personal Data.
At any time while we are processing your personal data, as a data subject you have the following rights:
- Right of access With a written application you can get information about the type of personal data you have provided and the purpose of its processing. The application can be submitted in person at our specified contact address or electronically to [email protected] from the same email address you have provided, in accordance with the provisions of the Bulgarian Electronic Document and Electronic Certification Services Act, the Electronic Government Act and the Electronic Identification Act. Your application must include your full name, personal identification number, contact address, description of your specific request and preferred form of obtaining the requested information, signature and date of application.
- 2. Right of rectification You have the right to request that your personal data be corrected in case you find errors or inconsistencies.
- 3. Right of erasure (the right to be forgotten) – if the conditions under Art. 17 of Regulation (EU) 2016/679 are met – after you have been provided with access to your personal data, you may request that we remove any records of your personal information without the possibility of further processing.
- Right to object – With regard to the data that is processed on the basis of a “legitimate interest”, you have the right at any time to object to the processing of your personal data. In the event of such an objection, the Wine Marketer undertakes to consider your objection and to inform you within 30 calendar days of its receipt of the result of the conducted internal inspection. If the objection is justified, we shall stop processing your personal data and remove any records of your personal information without the possibility of further processing.
- 5. Right to restriction of processing – In the conditions under Art. 18 of Regulation (EU) 2016/679 are met – you can ask the Wine Marketer to restrict (stop) the processing of your data. Such cases are the need to verify the accuracy of the data, the grounds for the processing or the lawfulness of their processing.
- 6. Right of appeal If you believe that your data is being processed illegally by the data controller, you have the right to appeal to the Commission for Personal Data Protection, which is the supervisory authority responsible for the application of Regulation (EU) 2016/679 and the Bulgarian Personal Data Protection Act.
Commission for Personal Data Protection; Address: Sofia 1592, boul. „Prof. Tsvetan Lazarov“ №2, Tel: 02 / 9153 518, Website: cpdp.bg, email [email protected]
XI. Measures for Information Security and Personal Data Protection
The Company has taken appropriate technical and organizational measures to protect the collected personal data provided from accidental or illegal destruction, accidental loss, unauthorized access, alteration or distribution, as well as from other illegal forms of processing by unauthorized persons. The security measures we apply are subject to constant improvement and adaptation to the latest technologies.
XII. Notification of Amendments to the Privacy Policy
As a controller of personal data, Wine Marketer reserves the right to make amendments and additions to this policy. When making amendments to the Privacy Policy, these will be promptly uploaded and made available to all interested parties on the website of Wine Marketer.
If you have any questions regarding our measures and rules on personal data protection, please contact us:
Wine Marketer
Address: Bulgaria, Varna, p.c. 9000, 98 Slivnitsa Boul.
Telephone: +359 896 826 957
E-mail: [email protected]