What law applies?
In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Bulgaria`s Personal Data Protection Act (“PDPA”) and the EU`s counterpart the General Data Protection Regulation (“GDPR”).
What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address.
What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
Who is responsible for data processing?
The responsible party within the meaning of the PDPA and the GDPR is KVS TECHNOLOGY EOOD trading as Audiophoria of 5 Trepetlika Str, 1407 Sofia, Bulgaria (“Audiophoria”, “we”, “us”, or “our”). If you have any questions about this policy or our data protection practices, please email [firstname.lastname@example.org], or write to us at the above address.
What are the legal bases of processing?
In accordance with the PDPA and GDPR, we have to have at least one of the following legal bases to process your Personal Data:
- Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
- Contract – This is where we process your information to fulfill a contractual arrangement we have made with you or reply to your messages, e-mails, posts, calls, etc.
- Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm.
- Legal Obligation – This is where we have a statutory or other legal obligation to process the information, such as for archiving or the investigation of crime.
Data we collect automatically
When visiting our website, you transmit data (technically necessary) to our web server via your internet browser. The following data is recorded during your visit: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.
To provide our website, we use the services of Siteground Ltd who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.
Content Management System (CMS)
We also use the Content Management System (CMS) of WordPress by Automattic Inc to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us is transferred to WordPress. This represents a legitimate interest.
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).
Our website uses a cookie consent tool to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to CookieYes: a) Your consent(s) or revocation of your consent(s); b) Your IP address; c) Information about your browser; d) Information about your device; d) Time of your visit to the website. The basis for processing is our legitimate interest and your consent.
Provision of the Shop
We use the shop system WooCommerce by Automattic Inc, for the purpose of displaying the shop. All data collected in our shop is processed on Automattic’s servers. The legal basis for the data processing is our legitimate interest in providing our shop.
Third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services. This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,
- Analytics: Google Analytics by Google LLC,
- Tag Management: Google Tag Manager and Google Site Tag by Google LLC,
- Fonts: Font Awesome by Fonticons Inc,
On the basis of our legitimate interests and your consent (i.e., interest in the analysis, optimisation, and economic operation of our website) Google Analytics, a web analytics service provided by Google LLC. The information generated by the cookie about the use of the online offer by the users is usually transmitted to a Google server and stored there.
Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous user profiles can be created from the processed data.
The IP address transmitted by your browser will not be merged with other data from Google. You can prevent the storage of cookies by setting your browser accordingly. You can also prevent the collection of the data generated by Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Data we collect directly
If you contact us, the data you provide will be stored so that your message can be forwarded to the correct contact person. This is done to process your request and your data will not be used for any other purposes, in particular not for advertising. The legal basis for the data processing is contract.
We are present on social media. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contract.
We process your first name, last name, e-mail address, shipping, and billing address, if different, and the data related to your contract with us data to handle the contractual relationship between you and us. The legal basis for the data processing is contract.
If you make a purchase your payment will be processed via our payment service providers MyPos, Klarna, PayPal. Payment data will solely be processed through MyPos, Klarna, PayPal and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the contract.
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of e-mail but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
We may also use remarketing and retargeting services to advertise. If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only).
Principles of processing Personal Data
Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.
Do Not Sell
We do not sell your Personal Data.
Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services including our shipping forwarders and order fulfillment service providers and, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.
Your Rights and Privileges
Under the PDPA and the GDPR, you can exercise the following rights:
- Right to information
- Right to rectification
- Right to deletion
- Right to data portability
- Right of objection
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.
Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.
Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Bulgaria is the Commission for Personal Data Protection, 2, Prof. Tsvetan Lazarov Blvd. Sofia – 1592, Bulgaria www.cpdp.bg
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using the details provided above.
Friday, 12 May 2023