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Personal Data Processing Policy

 

Information about the personal data administrator:

„AGRODES“ EOOD is a company registered in the Commercial Register of the Registry Agency with UIC 202481666, with registered office and management address: Kavarna, 42 G. S. Rakovski Street, Tel: 0885945612; e-mail: agrodes2013@abv.bg. 

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;
  • Your explicit consent – the purpose is specified for each specific case;
  • If there is a statutory obligation;

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

FOR THE PERFORMANCE OF A CONTRACT OR IN THE CONTEXT OF PRE-CONTRACTUAL RELATIONS

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

Purposes of processing:

  • establishing your identity;
  • managing and fulfilling your request and fulfilling a concluded contract;
  • preparing a proposal for concluding a contract;
  • preparing  and sending an invoice for the services you use with us;
  • to provide you with the necessary comprehensive service, as well as to collect the amounts due for the services used;
  • retaining correspondence in connection with orders placed, processing requests, reporting problems, etc.
  • notification of everything related to the services you use with us;
  • to detect and/or prevent illegal actions or actions in conflict with our terms for the relevant services;

Data that 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 data – contact address, email, telephone number;
  • identification data – three names, single civil number or personal number of a foreigner, permanent address;
  • data on orders made;
  • correspondence in connection with the overall service – e-mail, letters, information about your requests for troubleshooting, complaints, requests, grievances, feedback that we receive from you;
  • credit or debit card information, bank account number or other banking and payment information in connection with payments made;

o   other information such as:

  • Social network profile data.

 

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

We provide personal data to third parties

We provide your personal data to third parties, as our main goal is to offer you quality, fast and comprehensive service. We do not provide your personal data to third parties before we ensure 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):

  • postalerators and courier companies;
  • 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 the data collected on this basis

We delete the data collected on this basis 3 years after the termination of the contractual relationship, regardless of whether due to the expiration of the contract, cancellation or other reason.

FOR FULFILMENT OF REGULATORY OBLIGATIONS

We may be required by law to process your personal data. In these cases, we are obliged 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;
  • Provision of information to the Consumer Protection Commission or third parties, provided for in the Consumer Protection Act;
  • Provision of information to the Personal Data Protection Commission in relation to obligations provided for in the legal framework for the protection of personal data;
  • Obligations provided for in the Accounting Act and the Tax and Social Security Procedure Code and other related legal acts, in relation to keeping legal accounting;
  • Provision of information to the court and third parties, within the framework of proceedings before a court, in accordance with the requirements of the legal framework applicable to the proceedings acts;

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 ceased to exist. For example:

  • under the Accounting Act for the storage and processing of accounting data (11 years),
  • obligations to provide information to the court, competent state authorities, etc. grounds provided for in the current legislation (5 years).

Provision of data to 3rd parties

When we are legally obliged to do so, we may provide your personal data to the competent state 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 the personal data.

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

Data that we process on this basis:

On this basis, we process only the data for which you have given us your explicit consent. The specific data is determined for each individual case. Typically, this data is names, permanent address, email address, telephone number.

Provision of data to third parties

On this basis, we may provide your data to marketing and advertising agencies, Facebook, Google or other similar social networks.

Withdrawal of consent

The provided Consents can be withdrawn at any time. 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 set out above. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To withdraw the consent you only need to use our website or simply our contact details.

When we delete data collected on this basis

We delete data collected on this basis upon your request or 12 months after its initial collection.

PROCESSING OF ANONYMIZED DATA DATA

We process your data for static purposes, that is, for analyses in which the results are only aggregated and therefore the data is anonymous. It is not possible to identify a specific person from this information.

Your data can also be anonymized. Anonymization is an alternative to deleting data. With anonymization, all personally identifiable elements/elements that allow you to be identified are irreversibly deleted. There is no statutory obligation to delete anonymized data, as it does not constitute personal data.

How we protect your personal data

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

Personal data that we have received from 3rd parties

We do not receive data from 3rd parties.

User Rights

Each User of the site enjoys all rights to protect personal data in accordance with Bulgarian legislation and European Union law. 

 

The User can exercise his rights through the contact form or by sending a message to our email. 

 

Each User has the right to:

  • Information (in connection with the processing of his personal data by the controller);
  • Access to one's own personal data;
  • Correction (if the data are inaccurate);
  • Erase of personal data (right to be forgotten);
  • Restriction of processing by the controller or processor of personal data;
  • Portability of personal data between different controllers;
  • Objection to the processing of his/her personal data;
  • The data subject 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/her;
  • Right to judicial or administrative redress in the event that the rights of the data subject have been infringed.

 

The user may request erasure 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 or her consent on which the processing of the data is based and there is no other legal basis for the processing;
  • The user objects to the processing and there are no overriding legitimate grounds for the processing;
  • The personal data have 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 offering of information society services to children and consent has been given by the holder of parental responsibility for the child.

 

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

  • Disputes the accuracy of the personal data. In this case, the restriction of processing is for a period that allows the administrator 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 requests instead the 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;
  • Objects to the processing pending verification whether the legitimate grounds of the Administrator override the interests of the User.

Right to portability.

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to an Administrator, 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 personal data administrator is obliged to terminate the processing unless he 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. If you object to the processing of personal data for direct marketing purposes, the processing should be stopped immediately.

Complaint to the supervisory authority

Each User has the right to file a complaint against unlawful processing of their personal data with the Personal Data Protection Commission or the competent court.

Maintenance of a register

We maintain a register of the processing activities for which we are responsible. This register shall contain all the information set out below:

  • Name and contact details of the controller
  • The purposes of the processing;
  • Description of the categories of data subjects and of the categories of personal data;
  • The categories of recipients to whom the personal data have been or will be disclosed,
  • Including recipients in third countries or international organisations;
  • Where possible, the time limits envisaged for the erasure of the different categories of data;
  • Where possible, a general description of the technical and organisational security measures