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GDPR – Privacy notice

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Privacy notice

Information on the company that processes your data:                             

Name Perilis Trading EOOD
UIC 103825820
Main office and management address Bulgaria, village of Kichevo, district of Varna
Mailing address Bulgaria, village of Kichevo, district of Varna
Phone 0359 877237723
E-mail info@probioaction.bg
Website https://www.probioaction.bg/

Information on the competent data protection supervisory authority

Name Commission for Personal Data Protection
Main office and management address Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Mailing address Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Phone 02 915 3 518
Website www.cpdp.bg

Perilis Trading EOOD (hereinafter referred to as “Administrator” or “the Company”) operates in accordance 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 individuals with regard to the processing of personal data and on its free movement. This information is intended to inform you about all aspects of the processing of your personal data by the Company and the rights you have in this connection.

Reason for collecting, processing and storing your personal data

Art. 1. The administrator collects and processes your personal data in connection with the use of the online store www.probioaction.bg and the conclusion of contracts with the company on the grounds of Art. 6, para. 1, Regulation (EU) 2016/679 (GDPR), and in particular on the following grounds:

  • Explicit consent from you as a customer;
  • Fulfillment of the Administrator’s obligations under a contract with you;
  • Compliance with a legal obligation that applies to the Administrator;
  • For the purposes of the legitimate interests of the Administrator or a third party;

Goals and principles in the collection, processing and storage of your personal data

Art. 2. (1) We collect and process the personal data you provide to us in connection with the use of the online store www.probioaction.bg and concluding a contract with the company, including for the following purposes:

  • creating an account and providing full functionality when using the online store;
  • individualization of a party to the contract;
  • accounting purposes;
  • statistical objectives;
  • protection of information security;
  • ensuring the implementation of the contract for the provision of the respective service;
  • sending a newsletter and e-mails with special offers if you wish;
  • sending advertising materials and samples of products from other companies through Perilis Trading EOOD upon your request;
  • replying to inquiries made through the feedback form on our website;

 (2) We comply with the following principles when processing your personal data:

  • conformity with the law, good faith and transparency;
  • restriction of processing purposes;
  • relevance to the purposes of processing and minimizing the data collected;
  • accuracy and timeliness of the data;
  • limitation of storage in order to achieve the objectives;
  • integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.

(3) When processing and storing personal data, the Administrator may process and store personal data in order to protect its following legitimate interests:

  • fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal bodies.

What types of personal data our company collects, processes and stores

Art. 3. (1) The company performs the following operations with the personal data provided by you as customers, for the following purposes:

  • Registration of a customer in the e-shop and execution of a contract for distance purchase and sale – The purpose of this operation is to create an account for the use of the e-shop for purchasing of goods and provision of contact information for the delivery of purchased goods. Based on the impact assessment, the Data Protection Officer considers that the operation “Registration of a user in the e-shop and execution of a distance contract for purchase and sale” is admissible and provides sufficient guarantees for the protection of the rights and the legitimate interests of data subjects in accordance with the requirements of the GDPR;
  • Sending a news bulletin (newsletter) – the purpose of this operation is to administer the process of sending newsletters, emails with special offers, promotions, promo codes, news and new features to customers who have stated their desire to receive them. Given the limited scope of the personal data collected, the Data Protection Officer considers that carrying out an impact assessment of the operation is not necessary.
  • Exercising the right of refusal or complaint – the purpose of this operation is to administer the process of exercising the right of withdrawal or complaint by the customer for the goods in respect of which these rights may be exercised. Given the limited scope of the personal data collected, the Data Protection Officer considers that an impact assessment of the operation is not necessary.
  • Provision of advertising materials and sampling by other companies through Perilis Trading EOOD – the purpose of this operation is to administer the process of sending advertising materials and samples of products from other companies through Perilis Trading EOOD to customers who have stated that they wish to receive them. Given the limited scope of the personal data collected, the Data Protection Officer considers that an impact assessment of the operation is not necessary.
  • Sending inquiries through the feedback form on the website info@probioaction.bg – the purpose of this operation is to send a response to a query. Given the limited scope of the personal data collected, the Data Protection Officer considers that an impact assessment of the operation is not necessary.

(2) The administrator does not collect or process personal data relating to the following:

  • revealing racial or ethnic origin;
  • disclosing political, religious or philosophical beliefs, or trade union membership;
  • genetic and biometric data, health data or data on sexual life or sexual orientation.

(3) Personal data is collected by the Administrator from the persons to whom it relates.

(4) The administrator does not perform automated data decision making.

(5) The company does not collect data on persons under 16 years of age, except with the express consent of their parent or legal representative.

Art. 4. (1) The administrator processes the following categories of personal data and information for the following purposes and on the following grounds:

  • Your individual data (e-mail, name etc.)
    • Purpose for which the data is collected: 1) Contacting the user and sending information to him, 2) for the purpose of registering a user in the online store, as well as 3) to send a newsletter, emails with special offers, promotions, promo codes, news and new features and 4) to send a response to an inquiry through the form of our website.
    • Grounds for processing your personal data – By accepting the general conditions and registration in the e-shop or placing an order without registration, or concluding a written contract, a contractual relationship is created between the Administrator and you, on which basis we process your personal data – Art. 6, para. 1, l. (b) GDPR. Your data for sending a newsletter and emails, as well as for sending a response to an inquiry through the form of our website, are processed with your explicit consent – Art. 6, para. 1, l. (a) GDPR.
  • Delivery details (names, telephone, address, etc.)
    • Purpose for which the data is collected: 1) Fulfillment of  administrator obligations under a contract for purchase and sale and delivery of purchased goods and 2) Sending advertising materials and samples of products from other companies through “Perilis Trading” EOOD to customers who have stated that they wish to receive them.
    • Grounds for processing your personal data – By accepting the general conditions and registration in the e-shop or placing an order without registration, or by concluding a written contract, a contractual relationship is created between the Administrator and you, based on which we process your personal data – Art. 6, para. 1, l. (b) GDPR.Your data for sending advertising materials and samples of products are processed with your explicit consent – Art. 6, para. 1, p. (a) GDPR.
  • Data from your social media accounts (publicly available information from your accounts in Google+, Facebook)
    • Purpose for which the data is collected: 1) Making contact with the user and sending information to him and 2) for the purposes of user registration in the online store.
    • Grounds for processing your personal data – With the acceptance of the general conditions and registration in the e-shop through an account in a social network, a contractual relationship is created between the Administrator and you, on the basis of which we process your personal data – Art. 6, para. 1, l. (b) GDPR.

Retention period for your personal data

Art. 5. (1) The administrator stores your personal data for a period not longer than the existence of your account in the online store. After deleting your account, the Administrator takes the necessary care to delete and destroy all your data without undue delay or to anonymize it (i.e. to transform it so that it does not reveal your identity).

(2) The Administrator stores your personal data provided in connection with online orders for a period of 5 years for the purpose of protecting the legal interests of the Administrator in court or administrative disputes with users of the online store, while accounting documents are stored for the relevant statutory period.

(3) The Administrator notifies you in case the data retention period needs to be extended in order to fulfill a regulatory obligation or in view of the legitimate interests of the Administrator or otherwise.

(4) The administrator stores the personal data that it is necessary to keep in accordance with the applicable legislation for the relevant period, which may exceed the period of existence of your account in the e-shop or until the completion of the order.

Art. 6. (1) The Administrator keeps the personal data of the legal representatives of its business partners for the term of the contract, for observance of the legitimate interests and legal obligations of the Administrator, and this term may exceed the term of the concluded contract.

Transfer of your personal data for processing

Art. 7. (1) The administrator may, at its discretion, transfer some or all of your personal data to personal data processors for the fulfillment of the processing purposes with which you have agreed, subject to the requirements of Regulation (EU) 2016/679 (GDPR).

(2) The administrator notifies you in case of intention to transfer part or all of your personal data to third countries or international organizations.

Your rights in the collection, processing and storage of your personal data

Withdrawal of consent for the processing of your personal data

Art. 8. (1) If you do not want all or part of your personal data to continue to be processed by the Company for specific or all purposes of processing, you can at any time withdraw your consent to processing by filling out the form in your account or by request in free text.

(2) The administrator may request that you verify your identity with the person to whom the data relate.

(3) By withdrawing the consent for processing personal data, which is mandatory for creating and maintaining an account in the online store, your account will become inactive. Of course, you will be able to browse the online store and the products offered and place orders as a guest or make a new registration.

(4) If there is an order made by you, which is being processed, the earliest moment in which you can withdraw your consent for processing is upon successful completion of the order.

(5) You may at any time withdraw your consent to the processing of your personal data for the purposes of direct marketing.

(6) The withdrawal of the consent shall not affect the legality of the processing of personal data, which the Administrator has performed so far.

Right of access

Art. 9. (1) You have the right to request and receive confirmation from the Administrator whether personal data related to you are processed, and you can at any time see in your account, if you are a registered user, the data we process for you.

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

(3) The administrator shall provide you, upon request, a copy of the processed personal data related to you, in electronic or other appropriate form.

(4) The provision of access to the data is free of charge, but the Administrator reserves the right to impose an administrative fee in case of recurrence or excessiveness of the requests.

Right of correction or completion

Art. 10. You may correct or fill in inaccurate or incomplete personal data relating to you directly through your account on the Website or by making a request to the Administrator.

Right to delete (“to be forgotten”)

Art. 11. (1) You have a right to request from the Administrator the deletion of part or all of the personal data related to you, and the Administrator has the obligation to delete it without undue delay in case of any of the following reasons:

  • personal data are no longer needed for the purposes for which they were collected or otherwise processed;
  • You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
  • You object to the processing of personal data related to you, including for direct marketing purposes, and there are no legal grounds for processing to take precedence;
  • personal data have been processed illegally;
  • personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the Administrator;
  • personal data have been collected in connection with the provision of services to the information society.

(2) The administrator is not obliged to delete personal data if it stores and processes them:

  • to exercise the right to freedom of expression and the right to information;
  • to comply with a legal obligation requiring processing provided for in EU law or the law of the Member State applicable to the Administrator or for the performance of a task in the public interest or in the exercise of official powers provided to him;
  • for reasons of public interest in the public health field;
  • for archiving purposes in the public interest, for scientific or historical research or for statistical purposes;
  • to establish, exercise or defend legal claims.

(3) In case of exercising your right to be forgotten, the Company will delete all your data, except for the following information:

  • information needed to verify that your right to be forgotten has been exercised – email, IP address;
  • technical information on the operation of the online store, which cannot be connected to you in any way;
  • e-mail with which you made a registration in the online store.

(4) To exercise your right to be forgotten, you need to take the following steps:

  • Apply through your account in the online store or by email;
  • Submit a unique identification code to perform the action, which will be sent to you by email at the email address associated with the registration in the online store;
  • Identify yourself as an account holder;

(5) After verifying the identity of the person who made the request and the person to whom the data relates in accordance with the above steps, we will delete all data that we process for you, in accordance with para. 3.

(6) If there is an order placed by you that is being processed, the earliest time you can request to be “forgotten” is when the order is successfully completed.

(7) By deleting your personal data, your account will become inactive. Of course, you will be able to browse the online store and the products offered and place orders as a guest or make a new registration.

(8) The administrator shall not delete the data, which it has a legal obligation to store, including for protection on the occasion of court claims against it or proof of its rights.

Right of restriction

Art. 12. You have the right to ask the Administrator to restrict the processing of data related to you when:

  • you dispute the accuracy of personal data for a period that allows the Administrator to verify the accuracy of personal data;
  • the processing is illegal, but you do not want the personal data to be deleted, only its use to be restricted;
  • The controller no longer needs personal data for the purposes of processing, but you require them to establish, exercise or defend your legal claims;
  • You have objected to the processing pending verification of whether the legal grounds of the Administrator take precedence over your interests.

(2) In case of exercising your right of restriction, the Company will suspend the processing of your data, but will not remove the publications you have made in the online store.

Right of portability

Art. 13. (1) If you have given your consent for the processing of your personal data or the processing is necessary for the performance of the contract with the Administrator, or if your data is processed in an automated manner, you can, after identifying yourself before the Administrator:

  • request the Administrator to provide you with your personal data in a readable format and transfer them to another Administrator;
  • request the Administrator to directly transfer your personal data to an administrator designated by you, when this is technically feasible.

(2) You may at any time download or receive in machine-readable format the data stored and processed for you in connection with the use of the Administrator’s services, directly through your account via the data export option or by e-mail request.

Right to receive information

Art. 14. You can ask the Administrator to inform you on all recipients to whom personal data have been disclosed, for which there has been a request for correction, deletion or restriction of processing. The administrator may refuse to provide this information if this would be impossible or would require a disproportionate effort.

Right to object

Art. 15. You may object at any time to the processing of personal data by the Administrator relating to him, including if processed for the purposes of profiling or direct marketing.

Your rights in the event of a breach of the security of your personal data

Art. 16. (1) If the Administrator finds a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, it shall notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken.

(2) The administrator is not required to notify you if:

  • he has taken appropriate technical and organizational protection measures with regard to data affected by the security breach;
  • has subsequently taken steps to ensure that the breach does not pose a high risk to your rights;
  • notification would require a disproportionate effort.

Persons to whom your personal data is provided

Art. 17. For the purposes of processing your personal data and providing the service in its full functionality and in view of your interests, the Administrator may provide your data to the following personal data processors:

Personal data processors Purpose of personal data processing
Supplier Delivery to address

The specified processors of personal data comply with all requirements for legality and security in the processing and storage of your personal data.

Art. 18. The administrator does not transfer your data to third countries.

Art. 19. In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission as follows:

Name Commission for Personal Data Protection
Main office and address of management Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Mailing address Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Phone 02 915 3 518
Website www.cpdp.bg

Art. 20. You can exercise all your rights regarding the protection of your personal data by submitting your requests in any form that contains a statement to that effect and identifies you as the data owner.

Art. 21. If the consent relates to a transfer, the administrator shall describe the possible risks for the data transfer to third countries in the absence of a solution for adequate protection and the appropriate means for it.

Art. 22. The Company may amend the Privacy Notice by posting a message in relation to it on its website.

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