Personal data protection policy

Information about the Controller responsible for the processing of personal data

1. Name: ITR Bulgaria OOD

2. Unified Identification Code/BULSTAT: 200751593

3. Seat and address of management: City of Burgas, 18 Yanko Komitov Blvd.

4. Correspondence details: 8005 Burgas, 18 Yanko Komitov Blvd., Iskra warehouse, fl. 4

5. Telephone numbers: +359 700 15 666, +359 56 88 36 75

6. Website: www.itr.bg; shop.itr.bg

7. Controller responsible for the processing of personal data Certificate No.: 274996.

Information about the competent supervisory body

1. Name: Commission for personal data protection

2. Seat and address of management: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd.

3. Contact details: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd.

4. Telephone: +359 2 91 53 518

5. E-mail: kzld@cpdp.bg

6. Website: www.cpdp.bg

ITR Bulgaria OOD operates in line with the Personal Data Protection Act and 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.

Grounds for collecting, processing and storing your personal data

Art. 1. ITR Bulgaria OOD shall collect and process your personal data with regards to the performance of our main business activity – trade with computer equipment, pursuant to art. 6, para. 1 а), b), c) and f) of Regulation (EU) 2016/679, and namely:

• An explicit consent given by you as a client;
• Performance of contractual obligations under a contract that ITR Bulgaria OOD has signed with you;
• Compliance with a legal obligation which ITR Bulgaria OOD is subject to
• For the purposes of the legitimate interest of ITR Bulgaria OOD.

Purposes and principles in the collection, processing and storing of your personal data

Art. 2. (1) ITR Bulgaria OOD shall collect and process the personal data you provide us with in regards to the processing of your orders — to contact the client in order to confirm order details and delivery means, payment methods, to prepare the necessary documentation accompanying the order; for the purpose of entering into a contract with the company; to create a profile and ensure the full functionality of the online shop shop.itr.bg; for accounting purposes; statistical purposes; to protect the information security; to ensure the performance of the contract for the provision of the relevant service; to send notifications; when completing the contact form on our website www.itr.bg.
(2) ITR Bulgaria OOD shall ensure compliance with the following principles when processing your personal data:

• lawfulness, fairness and transparency;
• purpose limitation;
• relevance with the purposes for which they are processed and data minimisation;
• ensuring the data are accurate and up-to-date;
• storage limitation in view of achieving the purposes;
• integrity and confidentiality of the processing and ensuring an appropriate level of security of the personal data.

What types of data does ITR Bulgaria collect, process and store

Art. 3. (1) ITR Bulgaria shall process the following categories of personal data and information for the following purposes and on the following grounds:

• Identity-related data (name and last name, e-mail, address, telephone)
  • Purpose of data collection: user registration; contacting the user and sending notifications to him/her, including in the case of professed consent — for the purpose of sending newsletters and advertisements.
  • Grounds for processing your personal data – as a result of accepting the general terms and conditions and upon registering on the website and purchasing a product a contractual relationship is created between ITR Bulgaria and yourself, based on which we process your personal data – art. 6, para. 1 b) of GDPR.
• Other data which we process – upon visiting our website or logging into your profile, ITR Bulgaria shall collect data about the IP address, browser, products viewed.
  • Purpose of data collection: improvement of the security of the service and localisation of the interface, statistical and marketing purposes.
  • Grounds for data processing: processing is necessary for the performance of the contract which the data subject is party to — art. 6, para. 1 b) of GDPR. Prior to the creation of a user profile, the data shall be collected in line with the legitimate interests of the controller — art. 6, para. 1 f) of GDPR.
• Your data for the purpose of issuing an invoice to a natural person – if you wish to have an invoice issued in your capacity as a natural person, you should provide your Unified Citizen Number (UCN).
  • Purpose of data collection: issuing an invoice for the purpose of transferring payments under a contract for the sale and purchase of goods.
  • Grounds for processing your personal data – as a result of accepting the general terms and conditions and upon registering on the website and purchasing a product a contractual relationship is created between ITR Bulgaria and yourself, based on which we process your personal data – art. 6, para. 1 b) of GDPR.
• Video recording – when visiting the company buildings.
  • Purpose of data collection: improving the security on the ITR Bulgaria OOD premises.
  • Grounds for processing your personal data – an explicit consent given by visitors of the company (through information boards, positioned in a visible place, for the use of technical means for surveillance and control of the premises) – art. 6, para. 1 а) of GDPR.

(2) ITR Bulgaria OOD shall not collect and shall not process personal data which relate to the following:

• racial or ethnic background;
• political, religious or philosophical beliefs or trade union membership;
• genetic or biometric data, data concerning health or data relating to one’s sexual life or sexual orientation.

(3) Personal data shall be collected by ITR Bulgaria from the entities the data relate to.

(4) The company shall not implement an automatic decision-making process with regards to data.

Time limit for storing your personal data

Art. 4. (1) ITR Bulgaria shall store your personal data for a time period which shall not exceed the time period for which your profile is in existence. After the expiry of this time limit, ITR Bulgaria shall ensure to erase and destroy all of your personal data without any unnecessary delay.

(2) ITR Bulgaria shall inform you in the case the time period for storing your personal data needs to be extended in view of achieving the purposes for which they have been collected, performing the contract in view of the legitimate interests of ITR Bulgaria, or due to a legal obligation which ITR Bulgaria is subject to.

(3) ITR Bulgaria shall store the personal data, which it needs to protect, in accordance with the applicable legislation for the relevant time period provided for, which may surpass the time period in which your registration is in existence.

(4) Video recordings shall be stored for a period of 3 months.

Your rights with regards to the collection, processing and storing of your personal data

Withdrawal of the consent for the processing your personal data

Art. 5. (1) ) If you do not wish ITR Bulgaria to continue processing all or part of your personal data for a specific purpose or for all processing purposes, you may withdraw your consent for processing at any time.

(2) ITR Bulgaria may ask you to authenticate your identity for the purpose of ensuring that you are the same person the data are related to.

(3) Upon withdrawing your consent for the processing of personal data, which are mandatory for the creation and maintenance of your registration for the purpose of using the services, your account shall become inactive.

Right to access

Art. 6. (1) You have the right to request and receive a confirmation from ITR Bulgaria as to whether your personal data are being processed.

(2) You have the right to receive access to your personal data, as well as information relating to the collection, processing and storage of your personal data.

(3) Upon request, ITR Bulgaria shall provide information about the personal data being processed, relating to you, in electronic form or via other suitable means.

(4) ITR Bulgaria may ask you to authenticate your identity for the purpose of ensuring that you are the same person the data are related to.

Right to rectification or completion

Art. 7. You may rectify or complete the incorrect or incomplete personal data relating to you by submitting a request to ITR Bulgaria. ITR Bulgaria may ask you to authenticate your identity for the purpose of ensuring that you are the same person the data are related to.

Right to erasure (“to be forgotten”)

Art. 8.(1) You have the right to request from ITR Bulgaria to erase your personal data and ITR Bulgaria shall be obliged to erase them without any unnecessary delay when one of the conditions listed below is met:

• the personal data are no longer needed for the purposes for which they have been collected;
• you withdraw your consent on which the processing of your data is based and there is no other legal basis for the processing;
• you object to the processing of your personal data, including for the purposes of direct marketing, and there is no legal basis for processing which may take precedence;
• the personal data have been processed unlawfully;
• the personal data have to be erased in view of ensuring compliance with a legal obligation under the EU law or the law of a Member State which ITR Bulgaria is subject to.

(2) ITR Bulgaria shall not be obliged to erase personal data, if they are being stored and processed:

• for the purpose of exercising the right of freedom of speech and right to information;
• in order to ensure compliance with a legal obligation, which requires processing, as provided for in the EU law or the law of the Member State, which the controller is subject to, or in order to fulfill a task of public interest, or to exercise official powers which have been granted to the controller;
• for reasons of public interest in the area of public health;
• for archiving purposes in the public interest, for scientific or historical research purposes or statistical purposes;
• for the purpose of establishing, exercising or defending legal claims.

(3) In order to exercise the right ‘to be forgotten’, you should submit a written request and you should authenticate your identity so as to ensure that you are the same person the data are related to.

(4) ITR Bulgaria shall not erase the data which it is legally obliged to store, including for defence purposes in relation to court claims raised against it or to prove its own rights.

Right to restriction

Art. 9. You have the right to request from ITR Bulgaria to limit the processing of your data when:

• you dispute the accuracy of your personal data within a time frame which would allow ITR Bulgaria to check the accuracy of the personal data;
• the processing is unlawful but you do not wish your personal data to be erased, only to limit their use;
• ITR Bulgaria no longer needs your personal data for processing purposes but you request them for the purpose of establishing, exercising or defending your legal claims;
• You have objected to the processing pending a check as to whether the legal basis of ITR Bulgaria takes precedence over your interest.

Right to portability

Art. 10. You can, at any time, send an e-mail request for ITR Bulgaria to provide you with all of your data in a structured, widely used and machine-readable format.

Right to objection

Art. 11. You may object, at any time, to the processing of your personal data by ITR Bulgaria, including if they are being processed for the purpose of profiling or direct marketing.

Your rights in case of breach of the security of your personal data

Art. 12. (1) If ITR Bulgaria establishes a breach of the security of your personal data, which may put your rights and freedoms at high risk, we shall inform you about the breach without any unnecessary delay, as well as about the measures taken or which are about to be taken.

(2) ITR Bulgaria shall not be obliged to inform you if:

• it has undertaken the appropriate technical and organisational measures to ensure the protection of the data affected by the breach of security;
• it has subsequently taken measures which guarantee that the breach shall not put your rights at high risk;
• the notification would require disproportional efforts.

Entities to which your personal data are provided

Art. 13. In order to perform the delivery of a product purchased from the online shop, ITR Bulgaria shall provide the necessary information to the relevant courier company of your choice.

Other provisions

Art. 14. In case of a breach of your rights in accordance with the above-mentioned or applicable legislation on the protection of personal data, you shall have the right to submit a complaint to the Commission for personal data protection:

1. Name: Commission for personal data protection

2. Seat and address of management: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd.

3. Contact details: 1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd.

4. Telephone: +359 2 91 53 518

5. E-mail: kzld@cpdp.bg

6. Website: www.cpdp.bg

 

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