Privacy Policy

for o-skari.bg

Personal Data Processing Policy

Information about the Data Controller:

“O SKARI” Ltd. is a company registered in the Commercial Register of the Registry Agency under UIC 114598204, with registered office and management address at:

309 Druzhba III Residential District, Pleven, Bulgaria; Tel.: 00359887551523; email: o.skari.pleven@gmail.com

Contact Details of the Data Protection Officer:

Email address: dpo@o-skari.bg

Legal Grounds and Purposes for Which We Use Your Personal Data

We process your personal data on the following legal grounds:

  • A contract concluded between you and us, for the purpose of fulfilling our obligations under it;
  • Your explicit consent – the purpose is specified in each individual case;
  • Where processing is required by law.

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

For the Performance of a Contract or in the Context of Pre-contractual Relations

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

Purposes of Processing:

  • establishing your identity;
  • preparing an offer for the conclusion of a contract;
  • retaining correspondence relating to orders placed, processing requests, reporting problems, etc.;
  • notifying you about matters related to the services you use from us;
  • identifying and/or preventing unlawful actions or actions contrary to our terms applicable to the relevant services;
  • direct marketing;
  • fulfilling our contractual obligations towards Users.

The User consents to the processing of their personal data for direct marketing purposes by ticking the checkbox located below the contact form on the “Contacts” page.

The User may withdraw the consent given at any time by unticking the checkbox located below the contact form on the “Contacts” page or by contacting the Data Protection Officer.

Users’ personal data are stored for a period of 2 years.

Data We Process on This Legal Ground

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

  • personal contact data – email address and telephone number;
  • identification data – first name and surname;
  • correspondence relating to the overall service – emails, letters, information about your requests for resolving problems, complaints, applications, claims and feedback received from you;
  • IP address when visiting our website;
  • information about your actions on the website.

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

Disclosure of Personal Data to Third Parties

We provide your personal data to third parties, with our main purpose being to offer you high-quality, prompt and comprehensive service. We do not provide your personal data to third parties before ensuring that all necessary technical and organisational measures have been implemented to protect such data, and we strive to exercise strict control over compliance with this requirement. In this case, we remain responsible for the confidentiality and security of your data.

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

  • postal operators and courier companies;
  • persons engaged by us to maintain equipment, software and hardware used for the processing of personal data and necessary for the company’s activities;
  • persons providing consultancy services in various fields.

When We Delete Data Collected on This Legal Ground

Data collected on this legal ground are deleted 5 years after termination of the contractual relationship, regardless of whether termination is due to expiry of the contract, cancellation or another legal ground. This period is determined by the 5-year limitation period for potential claims arising from the contract.

For Compliance with Legal Obligations

The law may require us to process your personal data. In such cases, we are obliged to carry out the processing, for example:

  • obligations under the Measures Against Money Laundering Act;
  • compliance with obligations relating to distance sales and off-premises sales provided for under the Consumer Protection Act;
  • providing information to the Consumer Protection Commission or to third parties where required under the Consumer Protection Act;
  • providing information to the Commission for Personal Data Protection in connection with obligations provided for in data protection legislation;
  • obligations provided for under the Accountancy Act, the Tax and Social Security Procedure Code and other related legislation concerning lawful accounting;
  • providing information to courts and third parties in the course of judicial proceedings, in accordance with the requirements of the legislation applicable to such proceedings;
  • age verification when shopping online.

When We Delete Personal Data Collected on This Legal Ground

Data collected pursuant to a legal obligation are deleted once the obligation to collect and retain them has been fulfilled or ceases to apply. For example:

  • under the Accountancy Act, for the storage and processing of accounting data (11 years);
  • obligations to provide information to courts, competent state authorities and on other grounds provided for under applicable legislation (5 years).

Disclosure of Data to Third Parties

Where we are subject to a legal obligation, we may provide your personal data to the competent state authority, natural person or legal entity.

Following Your Consent

We process your personal data on this legal ground only after your explicit, unambiguous and freely given consent. We will not impose any adverse consequences on you if you refuse the processing of your personal data.

Consent is a separate legal ground for processing your personal data, and the purpose of the processing is specified in the consent itself and is not covered by the purposes listed in this Policy. If you provide the relevant consent, and until it is withdrawn or until all contractual relations with you are terminated, we may prepare product offers tailored to you.

Data We Process on This Legal Ground

On this legal ground, we process only the data for which you have given your explicit consent. The specific data are determined for each individual case. Usually, these data include your email address and name.

Withdrawal of Consent

Consent that has been provided may be withdrawn at any time. Withdrawal of consent does not affect the performance of contractual obligations. If you withdraw your consent to the processing of personal data for any or all of the purposes described above, we will no longer use your personal data and information for those purposes. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

To withdraw your consent, you only need to use our website or contact us using our contact details.

When We Delete Data Collected on This Legal Ground

Data collected on this legal ground are deleted upon your request or 12 months after their initial collection.

Processing of Anonymised Data

We process your data for statistical purposes, meaning analyses in which the results are aggregated only and the data are therefore anonymous. It is impossible to identify a specific individual from this information.

Your data may also be anonymised. Anonymisation is an alternative to deleting data. During anonymisation, all personally identifiable elements/elements enabling your identification are irreversibly removed. There is no statutory obligation to delete anonymised data because they do not constitute personal data.

Why and How We Use Automated Algorithms

For the processing of your personal data, we use partially automated algorithms and methods in order to continuously improve our products and services and adapt them to your needs in the best possible way. This process is called profiling.

How We Protect Your Personal Data

To ensure adequate protection of the company’s and its customers’ data, we apply all necessary organisational and technical measures provided for under the Personal Data Protection Act.

The company has established rules to prevent misuse and security breaches and has appointed a Data Protection Officer who supports the processes for protecting and ensuring the security of your data.

For maximum security when processing, transmitting and storing your data, we may use additional protection mechanisms such as encryption, pseudonymisation and others.

Personal Data We Have Received from Third Parties

We do not receive data from third parties.

Processing of Data for Direct Marketing Purposes

With the explicit consent of a User, we may process their data for direct marketing purposes. The data we process on this legal ground are:

  • Name;
  • Email address and telephone number;
  • Data relating to the history of use of our website.

For direct marketing purposes, Users’ personal data may be subject to automated processing by algorithms that determine products and services to be offered to the relevant User based on their usage history and orders for services.

Users’ Rights

Every User of the Website enjoys all personal data protection rights under Bulgarian law and European Union law.

The User may exercise their rights through the contact form or by sending a message to our email address.

Every User Has the Right To

  • Be informed (in relation to the processing of their personal data by the controller);
  • Access their own personal data;
  • Rectification (where the data are inaccurate);
  • Erasure of personal data (the ‘right to be forgotten’);
  • Restriction of processing by the controller or processor;
  • Data portability between different controllers;
  • Object to the processing of their personal data;
  • Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects them;
  • Seek judicial or administrative protection where the rights of the data subject have been infringed.

The User May Request Erasure Where One of the Following Conditions Applies

  • The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • The User withdraws the consent on which the processing is based and there is no other legal ground for the processing;
  • The User objects to the processing and there are no overriding legitimate grounds for the processing;
  • The personal data have been unlawfully processed;
  • The personal data must be erased in order to comply with a legal obligation under Union law or the law of a Member State applicable to the controller;
  • The personal data have been 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 Their Personal Data by the Controller Where:

  • The accuracy of the personal data is contested. In this case, processing is restricted for a period enabling 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 erased and instead requests restriction of their use;
  • The controller no longer needs the personal data for the purposes of processing, but the User requires them for the establishment, exercise or defence of legal claims;
  • The User has objected to processing pending verification of whether the controller’s legitimate grounds override the User’s interests.

Right to Data Portability

The data subject has the right to receive the personal data concerning them which they have 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 which the personal data were provided, where the processing is based on consent or on a contractual obligation and the processing is carried out by automated means. When exercising the right to data portability, the data subject also has the right to have the personal data transmitted directly from one controller to another, where technically feasible.

Right to Object

Users have the right to object to the controller against the processing of their personal data. The data controller must cease processing unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or where processing is necessary for the establishment, exercise or defence of legal claims. Where an objection is made to the processing of personal data for direct marketing purposes, the processing must cease immediately.

Complaint to the Supervisory Authority

Every User has the right to lodge a complaint regarding unlawful processing of their personal data with the Commission for Personal Data Protection or with the competent court.

Obligations of the Data Controller

The data controller has the following obligations:

  • Processes data in accordance with the personal data protection principles laid down in the Regulation and is able to demonstrate compliance with those principles (accountability);
  • Ensures data protection by design and by default;
  • Notifies the supervisory authority and the data subject in the event of a personal data breach and documents each personal data breach, including the facts relating to the breach, its consequences and the measures taken to address the breach;
  • Carries out data protection impact assessments;
  • Implements appropriate technical and organisational measures to ensure data security, including:
        • Pseudonymisation;
    • Encryption;
    • Ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
    • Timely restoration of the availability of and access to personal data in the event of a physical or technical incident;
    • Regular testing, assessment and evaluation of the effectiveness of technical and organisational measures;
    • Cooperation with the personal data protection supervisory authority in fulfilling obligations arising from the Regulation;
    • Preparing and implementing internal procedures for receiving, reviewing and responding within one month to requests from Users exercising their rights as data subjects.

Maintaining a Record

o-skari.bg maintains a record of the processing activities for which it is responsible. This record contains all of the following information:

  • the name and contact details of the controller;
    the purposes of the processing;
  • a description of the categories of data subjects and 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 envisaged time limits for erasure of the different categories of data;
  • where possible, a general description of the technical and organisational security measures.

Regulatory Authority

The authority regulating the activities of “o-skari.bg” is the Commission for Personal Data Protection (CPDP), with the following contact details:

Website: https://www.cpdp.bg/

Tel.: 02/91-53-518

Email: kzld@cpdp.bg

Address: 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria