Privacy Policy

Privacy Policy of “Polybet-Export” Ltd.

I. SUBJECT MATTER

This Privacy Policy, hereinafter referred to for brevity as the “Privacy Policy”, provides information on how “Polybet-Export” Ltd., hereinafter referred to for brevity as the “Provider”, “Controller”, “we” and/or “us”, owner/operator of the website: https://polybet-export.com/, hereinafter referred to for brevity as the “Website”, processes (including, but not limited to, collects and stores) personal data of data subjects, such as users of the Website and the Provider’s services, hereinafter referred to for brevity as “User(s)”, “You” and/or “Your”, as well as information regarding the rights of the latter in this regard.
The term “personal data”, as used in the Privacy Policy, has the meaning given to it in 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 and repealing Directive 95/46/EC, hereinafter referred to for brevity as the “General Data Protection Regulation” and/or “GDPR”, namely: “any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
Below you can find brief information regarding:

  • the Provider,
  • the competent supervisory authority,
  • the legal basis on which we process personal data,
  • the purposes for which we use personal data,
  • principles for processing personal data,
  • what personal data we collect,
  • the retention period for personal data,
  • access to and transfer of personal data, and
  • the rights and safeguards provided by the GDPR to data subjects.

II. INFORMATION REGARDING THE PROVIDER

1. Company name: “Polybet-Export” Ltd., UIC 201872103
2. Registered office and management address: Kazanlak, 16 Mazalat St., building ., entrance B, floor 3, apartment 6
3. Tel.: +359 897 881 604, e-mail: sales@polybet.bg
4. Registration in public registers: Commercial Register maintained by the Registry Agency at the Ministry of Justice of the Republic of Bulgaria.

III. INFORMATION REGARDING THE COMPETENT SUPERVISORY AUTHORITY

1. Name: Commission for Personal Data Protection of the Republic of Bulgaria
2. Address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
3. Telephone: 02 915 3 518
4. E-mail: kzld@cpdp.bg
5. Website: https://www.cpdp.bg/

IV. BASIS FOR THE COLLECTION, PROCESSING AND STORAGE OF PERSONAL DATA

We process (including, but not limited to, collect and store) Your personal data solely in connection with our activities and in accordance with the requirements of applicable legislation, including the Personal Data Protection Act of the Republic of Bulgaria and the General Data Protection Regulation.
We process Your personal data on the basis of at least one of the following grounds:

  • The User’s consent to the processing of personal data;
  • The processing of personal data is necessary for the performance of the Provider’s contractual obligations towards the User;
  • The processing of personal data is necessary for taking steps at the User’s request prior to entering into a contract;
  • The processing of personal data is necessary for compliance with the Provider’s legal obligations;
  • The processing of personal data is necessary for the purposes of the Provider’s legitimate interests in carrying out its activities.

V. PURPOSES FOR THE COLLECTION, PROCESSING AND STORAGE OF PERSONAL DATA

We collect, process and store Users’ personal data in connection with the provision of our services and communication related to the use of the Website, as well as for the following purposes:

  • Communication and identification in the performance of a service agreement and a sale and purchase agreement (including the performance of the respective agreement);
  • Communication, identification, processing and fulfillment of inquiries, orders, requests, reservations, purchases of goods or services (including preparation for entering into a contract, acceptance of orders, dispatch of goods, resolution of problems related to cancellation of orders, reservations, return of purchased goods, refunds of paid amounts and others);
  • Compliance with tax and other legal obligations;
  • Accounting purposes in connection with the use of our services;
  • Protection of our legitimate interests in connection with the performance of our obligations towards state and municipal authorities (for example: National Revenue Agency, Ministry of Interior);
  • Protection of our legitimate interests in connection with the storage of information for the purpose of protection against legal or tax claims and for the purpose of improving the performance of the Website;
  • Protection of the information security of the Website;
  • Statistical information regarding the use of the Website;
  • Provision of advertising content based on the User’s interests;

If a data subject refuses to provide us with some or all of the personal data necessary for the respective purpose specified above, we may not be able to provide the relevant service (for example, to perform a contract concluded with the respective User) or comply with the relevant legal requirements (for example, to enable the data subject to exercise their rights under the GDPR).

VI. PRINCIPLES FOR THE COLLECTION, PROCESSING AND STORAGE OF PERSONAL DATA

We comply with the following principles when collecting, processing and storing Your personal data:

  • lawfulness, fairness and transparency;
  • purpose limitation;
  • storage limitation with regard to achieving the purposes for which the data is processed;
  • data minimization;
  • accuracy and currency of the data;
  • integrity and confidentiality in the processing of data and ensuring an appropriate level of security of personal data.

VII. PERSONAL DATA

We collect the following categories of Users’ personal data for the following purposes and on the following grounds:

  • Your identifying data (first and last name, telephone number and e-mail address), as well as other data that You voluntarily provide to us, for the purposes of processing Your inquiries, providing offers for services and providing services by us, upon Your expressed wish, including communication with You in this regard, and on the basis of taking steps at Your request for the possible conclusion of a contract, performance of a contract to which You are a party, or consent to processing provided by You;
  • Your identifying data (first and last name, telephone number and e-mail address) and information related to payment and selected payment methods for the purposes of issuing and sending accounting/tax documents (invoices) in connection with services used by You, including communication with You in this regard, and on the basis of taking steps at Your request for the possible conclusion of a contract, performance of a contract to which You are a party, or compliance with our legal obligation;
  • Your identifying data (first and last name, telephone number and e-mail address), information related to the delivery address (only in cases where You have indicated that You wish to have the delivery made to a specific address rather than to a courier office or for collection from a store) and information related to payment and selected payment methods for the purposes of payment for orders, reservations and/or purchased goods or services, including the issuance and sending of accounting/tax documents (invoices) in connection with account registration, Your orders, reservations, purchased goods or services, and on the basis of taking steps at Your request for the possible conclusion of a contract and/or performance of a contract to which You are a party;
  • Your IP address, browser settings and preferred language, visited pages, as well as actions performed for the purposes of sending Push notifications, upon Your expressed wish to receive such notifications;
  • Your IP address, visited pages, for the purposes of protecting information security;
  • Other data that may be necessary in certain cases or related to the provision of services to Users by us, including data necessary for the performance of contractual obligations (for example: date of birth, signature, personal identification number) or other data that Users decide to voluntarily share with us, and on the basis of performance of a contract to which You are a party, consent to processing provided by You or compliance with our legal obligation.

We use “cookies” on the Website, which are small files downloaded to Your computer in order to improve Your experience as a user of the website. You can find more information in this regard on our dedicated page with “cookie” rules here.
We do not process, and accordingly do not collect from Users, special categories of personal data (for example: data revealing racial or ethnic origin, political opinions, genetic or biometric data, as well as data concerning the sex life and sexual orientation of the data subject).
We do not make decisions based solely on automated processing of data, including profiling.
We usually receive personal data directly from the data subject. However, it is possible that we may receive personal data from other persons, such as: other employees of the company in which the respective data subject works, as well as from publicly accessible sources such as the Commercial Register and the Register of Non-Profit Legal Entities maintained by the Registry Agency at the Ministry of Justice of the Republic of Bulgaria.

VIII. RETENTION PERIOD FOR PERSONAL DATA

We store Users’ personal data for no longer than necessary to fulfill the respective purpose of processing or for the legally established period, where applicable. For example:

  • personal data provided by You when completing the contact form will be stored until the request is fulfilled or the inquiry for which You contacted us has been answered, and for a maximum of one year thereafter for statistical and marketing analysis;
  • personal data of our clients processed in connection with contracts concluded between us and the respective User will be stored for a period not exceeding ten years, starting from January 1 of the year following the year in which the contract was accounted for tax purposes;
  • personal data of our clients processed in connection with the issuance of tax documents (invoices) will be stored for a period not exceeding ten years, starting from January 1 of the year following the year in which the document was accounted for tax purposes;
  • personal data of our partners/suppliers processed in connection with contracts concluded between us and the respective partner/supplier will be stored for a period not exceeding ten years, starting from January 1 of the year following the year in which the contract was accounted for tax purposes;
  • personal data of participants in recruitment and selection procedures will be stored for a period not exceeding six months from the final completion of the recruitment/selection procedure in which the respective data subject participated, respectively after the expiry of the period for appealing the relevant procedure, unless the respective data subject has given consent for their personal data to be stored for a longer period, in which case the data subject has the right at any time and without giving reasons to withdraw their consent.

The retention period depends, among other things, on the duration of the legal relationships established between us and the respective User, as well as on the purposes for which the personal data is processed. Where there are indications of potential legal claims or liability, these periods will be extended accordingly. Where processing is based on the User’s consent (for example: in cases of personal data provided by third parties for direct marketing), we store such personal data for as long as we have valid consent for its processing.
After the expiry of the above periods, we take the necessary measures to delete and/or destroy the respective personal data without undue delay.

IX. ACCESS TO PERSONAL DATA AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES

In principle, Users’ personal data that we process is accessible to our employees, representatives and partners who need it for the performance of legal obligations and/or contractual obligations (for example: provision of a particular service under a contract with a User). In this regard, at our discretion and in compliance with the requirements of the GDPR, we may transfer all or part of Your personal data to third parties such as accountants, professional consultants, including lawyers (for the purposes of financial-accounting and administrative servicing of our activities), cloud platforms for processing/storing data (for the purposes of organizational servicing of our activities, for example: storing and processing contracts with Users on cloud platforms for greater security), companies providing postal services (for the purposes of organizational servicing of our activities, for example: sending paper copies of contracts to Users), IT service providers, system administration and marketing service providers (for the purposes of providing more reliable and high-quality operation of the Website and more secure processing of data), providers of services for storing third-party information (i.e. hosting companies) (for the purposes of performing contracts with Users).
Based on applicable legislation or at the request of public authorities, all or part of Your personal data may also be accessible to public authorities.
We do not intend to transfer Your personal data to countries outside the European Economic Area or to international organizations.

X. RIGHTS OF DATA SUBJECTS

At any time while we process Your personal data, and subject to the limitations set out in applicable legislation, You, the data subject, have the following rights:

  • Right of access – You have the right to request information as to whether we process Your personal data, as well as to obtain access to and a copy of such personal data; if You request more than one copy of such personal data, You may be required to pay a corresponding fee for each additional copy;
  • Right to rectification/correction – You have the right to request that Your personal data be corrected if You believe that it is inaccurate or incomplete. We will make such corrections without undue delay;
  • Right to erasure/right to be forgotten – under certain circumstances (for example: the respective personal data is no longer necessary for the purposes for which it was collected; You have withdrawn Your consent to the processing of certain personal data for which there is no other legal basis), You may request that Your personal data processed by us be deleted from our records/our database without undue delay. In certain cases, We may refuse to delete such personal data (for example: the processing of personal data is necessary for compliance with a specific legal obligation or for the establishment, exercise or defense of legal claims);
  • Right to restriction of processing – where certain conditions are met (for example: the processing of certain personal data is unlawful, but You do not wish such data to be deleted), You have the right to request restriction of the manner in which Your personal data is processed;
  • Right to data portability – where Your personal data has been provided by You and is processed by automated means, You have the right to request that such personal data be provided to You in a structured, commonly used and machine-readable format, as well as to have it transferred to another personal data controller, where technically feasible;
  • Right to object – You have the right, at any time, to object to the processing of Your personal data for certain purposes, in which case we will stop using the personal data for the specific purpose, unless we have overriding legitimate grounds for doing so (for example: You have the right, at any time, to object to the processing of Your personal data for direct marketing purposes, in which case we will stop processing Your personal data for these purposes without undue delay);
  • Right to object to automated processing, including profiling – You have the right not to be subject to a decision based solely on automated processing of Your personal data, including profiling, and You also have all rights arising for You in the event that You are subject to the legal consequences of such processing;
  • Right to withdraw consent to processing – where we process Your personal data on the basis of consent provided by You, You have the right to withdraw Your consent at any time. Withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal.

If, at the User’s request, we delete their personal data from our database, we will retain only the information that may be necessary to protect our legitimate interests or for public authorities.
You have the right to request that we inform You of all recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested has been disclosed. We may refuse to provide this information if doing so would be impossible or require disproportionate effort.
If we are required to transfer personal data to another controller, to rectify or delete personal data, to restrict the processing of personal data or to terminate such processing, to provide information regarding the recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested has been disclosed, or to provide access to personal data, and if we have concerns regarding the identity of the User making the respective request, we may first request additional information in order to confirm the identity of the respective data subject.
In the event that a third party is involved in the processing of Your personal data, to whom all or part of Your personal data has been transferred (as indicated in Section IX above), all of the requests mentioned above will be forwarded to that third party.
The exercise of the above rights is free of charge for Users, except where the requests made are manifestly unfounded or excessive. In such cases, we may either charge a reasonable fee for fulfilling the request or refuse to act on the request.
Users may exercise the above rights by contacting us by e-mail at: sales@polybet.bg

XI. COMPLAINT TO A SUPERVISORY AUTHORITY

If You believe that Your personal data is not being processed lawfully or that any of Your rights related to the protection of personal data has been violated, You have the right to lodge a complaint with the competent supervisory authority for the protection of personal data specified in Section III above of the Privacy Policy. You also have the right to seek protection of Your rights through the courts.
If the Website contains links to other websites, we recommend that You carefully review the personal data protection/privacy policies of those other websites, because when You visit those websites, Your personal data may be processed by the respective websites, which processing is not covered by this Privacy Policy.
We reserve the right to amend the Privacy Policy at our discretion and whenever we deem appropriate.

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