PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA: The Sole-Owner Limited Liability Company "IVEL-CO" EOOD, operating the E-Store on the Website www.ivel-co.eu, hereby declares that all Personal Data (hereinafter referred to as the “Data”) are considered strictly confidential in compliance with all applicable legal provisions in the field of Personal Data protection. The privacy of your Personal Data is our priority. Therefore, we pay close attention to all Personal Data and their protection. In these Principles relating to the Processing of Personal Data (the “Principles”) we would like to inform you about what Personal Data we collect and how we use it afterwards. 1. Personal Data and their processing What is Personal Data ? Personal Data within the meaning of Article 2, paragraph 1 of the Law on Personal Data Protection means any information relating to a natural person who has been identified or can be identified, directly or indirectly, by an identification number or by one or more specific attributes. Several examples of Personal Data are: names, personal identification number [EGN], address, telephone, place of birth, passport data of the person (physical identity). This information may refer to employees, managers, customers, suppliers, contractors, business contacts and other natural persons with whom the Controller has a relationship or wants to establish a business contact. 1.1 Categories of Personal Data We collect different data depending on what services you use. When you buy from us, we collect: • Name and contact details: name and surname, e-mail address, postal address, billing address, phone number, bank account. • Demographic data: gender, date of birth, country and preferred language. • Data resulting from existing contracts – purchased products, consumer segment, scope of services provided. If you are a Registered User, we collect: • Name and contact details: name and surname, email address, postal address, billing address, phone number, bank account. • Demographic data: gender, country and preferred language, date of birth. • Registered login details. Login names and passwords. We don't have access to the actual password. If you receive marketing messages from us, we collect: • Name and contact details – email address and name. • Demographics – country, gender reference. Also, we process the following Personal Data : • Data on the communication between the seller and the customer. • Data from video surveillance at the shops and spaces of the Company “IVEL – CO” EOOD. • Records with the behaviour on the Websites operated by the Company “IVEL–CO” EOOD. 1.2 Purposes of processing Personal Data : • Provision of services and their improvement. We process your Personal Data in order to provide the services offered and to improve them to your satisfaction. Specifically, these include o Processing of orders for goods or services made either on our Website, through the mobile applications or by phone. Here, the need to perform a Sale Contract, a Registered User Contract, as well as to fulfil a legal obligation in case of selected data (e.g. accounting documents) is the legal grounds. o Customer care. In order to provide customer service and eliminate possible problems in the performance of a Sales Contract or a Registered User Contract, we process your Personal Data on the grounds of the need to perform these contracts. o Communication. We use the collected Data for the purpose of communicating with you and its individual adaptation. We may contact you by phone, e-mail, through the Application or any other form in order to remind you that you have goods in the online basket, to help you complete your order, to inform you of the current status of your request, order or claim, or to receive other information from you about it or to alert you that you need to take action in order for the status of your account to remain active. In case that you are a Registered User, we process the data for this purpose in performance of the Sales Contract. In case that you are not a Registered User but you buy from us, we process the data for a legitimate interest, which is namely the legitimate interest of the Company as described above. o Improving services. We use data to continuously improve our services and system, including to create new features, and simultaneously to make informative decisions using aggregate analysis and business research, all of which are based on our legitimate interest arising from the freedom of business and consisting of the need to improve the services provided in order to succeed in economic competition. To ensure sufficient protection of your rights and interests, we use personal data in anonymous form for the purpose of improvement. • Protection, safety and dispute resolution. We may process the Data for legitimate interest, which consists in ensuring the protection and safety of our systems and our customers, detecting and preventing fraud, resolving disputes and implementing our agreements on the grounds of legitimate interest. • Recording from Video Surveillance. The Company “IVEL – CO” EOOD has cameras in its stores and spaces in order to protect our legitimate interests. The locations where cameras are fixed are always marked with a warning signs. • Marketing offers o Commercial communication • We send you commercial messages about any products similar to those you have purchased. • You can always stop receiving these commercial communications by using the cancellation link you will find in each email. • In case that you unsubscribe from the commercial communications, we will not subsequently use your electronic contacts for this purpose. We will start using them again if you register or explicitly request it. o The marketing offers you are shown may be selected based on any other information we have acquired about you over time from the contact data, demographics data, bookmarks data and data about our products you have used and the e-store (cookies, IP address, data provided by your browser, click data, displayed commercial messages, products visited). We do not perform fully automated processing, which for you would have legal consequences. o If you are a Registered User, we process data for this purpose in performance of the contract. If you are not a member but you buy from us, we process this data for legitimate interest, which is namely a legitimate conventional marketing. o If you are not our customer, we process on the grounds of your consent. o You have the right to object to such processing, free of charge, at any time. The contact details are indicated at the end of this document. Processing of Cookies from the E-Store operated by the Company "IVEL-CO" EOOD o In case that you have enabled the Cookies in your web browser, we process the records on the behavior from the Cookies located on the E-Store operated by the Company IVEL-CO EOOD in order to ensure better functioning of the E-Store and for the purpose of internet advertising of the Company "IVEL-CO" EOOD. More information can be found in a separate section of this Policy. 1.3 Provision of Personal Data to third parties Your Personal Data will only be provided to third parties or intermediary parties if necessary in the framework of the performance of the Sales Contract, the Registered User Contract, based on a legitimate interest, or if you have given prior consent to it. a) to subsidiaries and processing organizations on the basis of the performance of the Sales Contract or the Registered User Contract for the performance of internal processes and implementation; b) to companies issuing credit card, providing payment services for the purpose of processing payments, and banks on the basis of your order, for the performance of the Sales Contract; c) to suppliers, to transport and/or courier companies for the purpose of delivering the products or services ordered by you and to resolve claims, including withdrawal from a contract; d) to security guard companies holding a license to carry out private security guard activities and processing the video recordings on sites of the Company "IVEL-CO" EOOD and/or maintaining other registers in the process of securing the access regimen at the said sites; e) to other service providers, to third parties involved in the processing of data, including persons who provide maintenance services for the equipment and software used for the processing of your Personal Data, following an assignment by the Company "IVEL-CO" EOOD, as well as persons providing technical support services for terminal equipment; f) to third parties, e.g. legal representatives, courts, for the purpose of collecting receivables or concluding different contracts with you; g) to state, competent authorities, which, by virtue of a legal act, have the power to request the Company "IVEL-CO" EOOD to provide information, including Personal Data , such as the National Revenue Agency, the Bulgarian Court or the court of another country, various supervisory/regulatory authorities, in the framework of proceedings before a court, in accordance with the requirements of procedural and substantive legal acts applicable to the proceedings; Consumer Protection Commission or third parties provided for in the Law on Consumer Protection; h) to third parties conducting customer surveys; If any third parties use any data in the framework of their legitimate interest, the Controller may not be held liable for such processing. This processing is governed by the principles for the processing of the Personal Data of the respective companies and individuals. 1.4 Principles 2. Customer account and purchase without registration • a) As part of a Registered User Contract signed, we open a customer account for you that is password protected. You get direct access to your data, including their editing, so you can see both your personal data for completed and unfinished orders and change the newsletter subscription within the customer account. You can also manage your Personal Data and send the newsletter through your customer account. • b) If you do not want to open a customer account for a purchase you have made, you can also shop in our e-store without registration, i.e. without being a ‘Registered User’. • c) You have the right to terminate the Registered User Contract in accordance with the relevant General Terms and Conditions. 3. Protection of Personal Data and retention period 3.1. Protection of Personal Data a) Your Personal Data is transmitted to us in encrypted form. We use the SSL (Secure Socket Layer) encryption system. On our e-store and other systems, we maintain technical and organizational measures against the loss and destruction of your data, against access of unauthorized persons to your data, their modification or dissemination. b) From our processing organizations, we require a proof of compliance of their systems with the guidelines under the GDPR (General Data Protection Regulation). c) Access to your Customer account is only possible after setting your personal password. In this context, please note that you should not share your access data with any third-party, and after completing your activity in the Customer account, you should always close the window of your web browser, especially when using the computer along with other users. The Company "IVEL-CO" EOOD is not responsible for any misuse of the passwords used, unless this situation is directly caused by the Company. 3.2. Processing period Processing and storage of Personal Data • for a time unconditionally necessary to secure all rights and obligations arising from a Sales Contract, i.e. for the time of the order and the warranty period. • for the duration of a Registered User Contract. • 1 year after the end of the warranty period in order to resolve any potential disputes. • for the time during which the Company "IVEL-CO" EOOD ,as a Controller, is obliged to store them according to the generally mandatory legal regulations. Accounting documents, e.g. invoices issued by the Company "IVEL-CO" EOOD are archived in accordance with the law for a period of 10 years from their issuance. • The consent for the notifications on the availability of goods remains in force until the information on the availability is sent, but no longer than for a period of up to 1 year or until its cancellation. • The consent for the marketing offers remains valid for up to 4 years or until its cancellation. • The Video Surveillance recordings at the stores of the Company "IVEL-CO" EOOD and around the buildings of the Company "IVEL-CO" EOOD are processed for a maximum period of 60 days from the day of the acquired video surveillance recording. • In other cases, the processing time is determined by the purpose of processing or set by the legal requirements in the field of Personal Data protection. 4. Rights of data subjects • a) If we process your Personal Data, you may request free information about the processing of your Personal Data at any time. • b) In the event that you believe that we are carrying out the processing of Personal Data contrary to the protection of your Personal Data and the legal requirements for the protection of Personal Data, you may request an explanation, request remedy of the condition thus arising, or you may request the rectification, addition, deletion of Personal Data or blocking of Personal Data . • c) Also, you have the right to contact the Data Protection Officer or the Commission for Personal Data Protection at any time. • d) You may withdraw your consent to the processing of Personal Data at any time. If you withdraw your consent to the processing of Personal Data, your Personal Data will be deleted or replaced by anonymous ones; however, this does not apply to the Personal Data that are necessary for the Company "IVEL-CO" EOOD in order to fulfil legal obligations (e.g. to implement an order already placed) or to protect its own legitimate interests. The destruction of Personal Data will also occur if the Personal Data are not necessary for the purpose or the storage of your data is inadmissible for other reasons provided for by law. 5. E-Stores 5.1 Cookies Our e-store uses the so-called ‘Cookies’ in order to make our offer for you relevant, interesting and user-friendly. Cookies are small text files that are stored on your computer, smartphone, or other device that is used by your web browser. More information about cookies can be found here. We use Cookies e.g.: • For the proper functioning of the cart/basket in order to complete your order as easily as possible. • To remember your input data so you don't have to enter it again. • To the best possible adaptation of our e-store to your requirements by monitoring the presence, your movement on the e-store and the features used. • To receive information on ads tracking because we are unable to offer you advertising for a product you are not interested in. Some cookies may collect information that is subsequently used by third parties and that, for example, is used by such third parties to directly support our advertising activities (so-called "third-party cookies"). For example, information about the products purchased from our e-store may be displayed by an advertising agency as part of the displaying and adapting the internet advertising banners on the images of the webpages you have selected. It is not possible for you to be identified by this data. 5.2 . Use of Cookies Cookies used on our e-store can be divided into two main types. Short-term, the so-called ‘Session Cookies’ are deleted as soon as the visit to our e-store is completed. Long-lasting, the so-called ‘Persistent Cookies’ remain stored on your device much longer or until you manually remove them (the time for which the Cookies files remain on your device depends on the Cookies themselves and the setting of your browser). Cookies can also be divided according to their functionality into: • Analytical, which help us to improve the consumer comfort on our e-store by understanding how consumers use it. • Conversion, which allow us to analyse the effectiveness of different sales channels. • Tracking, which in combination with Conversion, help us to analyse the performance of different sales channels. • For re-marketing, which we use to personalize the content of ads and their correct targeting. • Sessions, which are essential for the functionality of the e-store. 5.3 Disable Cookies The setting for using Cookie files is part of your Internet browser. Most browsers automatically accept Cookie files by default. Cookie files may be disabled or restricted in your browser by types of your selection. Information about browsers and how to set Cookie file preferences can be found on the following web pages or other documentation of internet browsers: • Chrome • Firefox • Internet Explorer • Android • Iphone и Ipad An effective cookie management tool is also available on the following website: http://www.youronlinechoices.com/bg/ 5.4 Links Our e-store contains links to websites that are practical and contain information. Please note that these sites may be owned by and operated by other companies and organizations and have other principles of security and protection of Personal Data. Our Company has no control over and is not responsible for any information, materials, products or services contained or available through these websites. 6. Contact us If you have any questions, comments and queries about these Principles, do not hesitate to contact us at the address or contact details. Data Protection Officer: Mrs. Elena Georgieva Contact: office@ivel-co.eu , 0897 299 525 7. Validity These Principles relating to the Processing of Personal Data entered into force as of 25th May 2018. Your IVEL-CO EOOD’s Team