OF SPORT-DEPO JSC
Effective from 25.05.2018
I. Introduction
Sport-Depot AD ("Sport-Depot") respects the privacy of its customers and guarantees the maximum protection of their personal data. This Privacy and Personal Data Protection Policy (hereinafter referred to as the "Privacy Policy") has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection.
Sport-Depot AD ("Sport-Depot") respects the privacy of its customers and guarantees the maximum protection of their personal data. This Policy for confidentiality and protection of personal data (hereinafter referred to as "Privacy Policy") has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection.
This Privacy Policy regulates the processing of personal data of individuals or representatives of legal entities of our customers or potential customers, as well as users of our website: www.ats.sportdepot.bg ("Site"), in connection with the services provided from Sport-Depot, including those provided through and available on the Site.
This Privacy Policy, together with the General Terms of Use of the Internet Site, the Policy for the Use of "Cookies" and any other documents that are mentioned on the Site, determine the rules that Sport-Depo will follow when processing personal data that we collect by you or for you or that you provide to us. This Privacy Policy does not affect, limit or waive your rights under the Personal Data Protection Act (“PPA”) or other relevant legislation.
If you have any questions or comments about this Privacy Policy, please contact us at: [email protected]
Please read this Policy carefully before using the Site or providing your Personal Data, whether electronically on the Site or on paper, as by providing your Personal Data you agree to its terms. If you do not wish us to process your personal data in the manner described in this Privacy Policy, please do not provide it to us. The provision of personal data by you is voluntary, with a view to the use of certain services provided by us and the use of the Site and/or access to it, as well as with a view to online shopping on the Site. Please note that in some cases we will not be able to provide you with the service and/or sell the goods you have requested if you do not provide us with the necessary information. Please also note that in certain cases your consent to the processing of personal data may not be necessary if Sport-Depo has another legal basis, e.g. fulfillment of legally established obligations.
II. Who processes and is responsible for your personal data?
Sport-Depo AD ("Sport-Depo", "we") is the commercial company registered in the Commercial Register at the Registration Agency with EIK 175399518, which collects, processes and stores your personal data under the terms of this Privacy Policy. Sport-Depot is the controller of personal data within the meaning of the Personal Data Protection Act (PPA). You can contact us at any of the following coordinates:
Management address: Sofia, Vasil Radoslavov St. No. 6, Sport depot building, 3rd floor
telephone: 0701 90009
e-mail: [email protected]
Personal data protection officer: Denitsa Milkova
III. Categories of personal data processed by Sport-Depo.
1. Sport-Depot may process publicly available personal data and/or personal data provided by you. The main types of personal data processed are:
(i) Personally Identifiable Information (including name, email address, language of communication and others);
(ii) Contact details (including postal and email addresses, telephone and fax numbers of you or your designated contact person and others);
(iii) Financial information (bank account and others);
(iv) Information about a representative (legal representative or proxy of such) of our client legal entity;
(v) Site profile data (including name, postal and email addresses, telephone number, date of birth, etc.);
(vi) Data for entering into contracts for sale, dealership, wholesale, deferred payment, etc. with natural or legal persons (such as names, social security number, etc.).
2. Sport-Depot can process data prepared and generated by Sport-Depot in the process of providing the services:
(i) data on the end electronic communication device used, device type, operating system used, IP address, location;
(ii) data about your preferred goods and services
(iii) Data from the communication between us and you, your habits, preferences, satisfaction with our services (activity when using the services, complaints, requests, etc.);
(iv) Information regarding visits to the Site and use of the Site, including operations and history of use of the Site;
(v) The data obtained in the performance of the obligations arising from the normative acts (ie data arising from inquiries, regulations, investigative bodies, notary public, tax authorities, court, bailiff);
(vi) Video recording when visiting the stores or head office; voice recording - calls made to the Sport-Depot contact center;
(vii) Video recording or photography made in accordance with the previously announced conditions for participation in games and/or other promotional campaigns organized by Sport-Depot.
3. In order to ensure the good performance of the services and the obligations arising from customer contracts, Sport-Depot has the right to process any information that is available in public registers (including public databases and data published on the Internet) as well as information received from third parties on the occasion of the fulfillment of legal provisions regarding customers.
4. Sport-Depot has the right and obligation to verify the accuracy of the personal data recorded in the database, and for this purpose requires you to verify the data and, if necessary, correct it or confirm the accuracy of your data.
5. Different types of personal data can be processed independently or in combination with each other.
IV. Purposes and legal grounds for processing personal data
1. Processing of personal data, which is necessary for the conclusion or performance of contracts with us or in connection with the preparation for the conclusion of contracts with us.
Sport-Depo processes your data for the following purposes:
(i) Identifying a customer when: entering into a new or amending an existing contract with us; explanations about the services used; performance of a concluded contract.
(ii) Preparing proposals for concluding contracts, sending pre-contractual information and a draft contract; management of pre-sales activities;
(iii) Data received by you in the performance of obligations arising from contracts concluded with you or a company represented by you, exercising rights and ensuring the performance of contracts by our clients;
(iv) Administering and responding to customer complaints/inquiries/complaints/complaints; return of amounts and goods; product replacement;
(v) Technical assistance to create an account/s and recover a forgotten password to access our Site, for electronic service of electronic invoices.
(vi) Identification and validation of legal age when shopping online;
(vii) Payment of obligations, rescheduling of amounts due; debt collection management;
(viii) Warranty and service;
(ix) Update offers to dealers; sharing important information regarding changes to our policy and other administrative information;
(x) Manage and administer online shopping activities; payment management.
2. In fulfillment of its legal obligations, Sport-Depot processes your data for the following purposes:
(i) Issuance of invoices;
(ii) To carry out tax-insurance control by the relevant competent authorities;
(iii) Fulfillment of obligations in relation to distance selling, off-premises sales, provided for in the Consumer Protection Act;
(iv) Provision of information to the Commission for the Protection of Personal Data in connection with obligations provided for in the legal framework for the protection of personal data - Personal Data Protection Act, Regulation (EU) 2016/679 of April 27, 2016, etc. ;
(v) Obligations provided for in the Accounting Act and the Tax-Insurance Procedure Code and other related legal acts, in connection with keeping proper and lawful accounting.
3. Sport-Depot processes the relevant data provided with the express written consent of the client for their processing for the following purposes:
(i) Creation and management of a personal profile on the Site; technical assistance for creating a profile/s and recovering a forgotten password to access our Site;
(ii) Direct marketing of products and services;
(iii) Participate in and administer surveys, giveaways, promotional campaigns;
(iv) Participation and management of Sport Depot Club.
4. The processing is necessary for the purposes of the legitimate interests of Sport-Depot.
(i) In order to protect and ensure the protection of the property, interests and security of Sport-Depot, its visitors and employees, Sport-Depot uses video surveillance equipment.
(ii) Assess and determine user satisfaction and the effectiveness of the advertising we offer to you and others, and to meet your expectations by presenting adequate advertising;
(iii) Analysis of customer purchase history data, preferences and behavior;
(iv) Guarantee quality of customer service (video recording, audio recording)
V. Categories of third parties who access and process your personal data
(i) Transport/courier companies, postal operators with a view to fulfilling our contractual obligations, sending correspondence and communications, in connection with the contract between us, sending purchased goods;
(ii) Persons assigned by Sport-Depot to maintain equipment and software used to process your personal data;
(iii) Debt collection service providers, notary public, solicitor, bailiff or other third party if the customer has breached an obligation arising from a contract with us;
(iv) Banks servicing payments made by and to You;
(v) Persons to whom Sport-Depot has provided the performance of part of the activities or obligations related to a specific service that we owe to you; persons processing personal data who, based on a contract with Sport-Depot, process your personal data on behalf of Sport-Depot;
(vi) Persons performing consulting services in various fields - lawyers, accountants, marketing agencies, etc.;
(vii) Authorities, institutions and persons to whom we are obliged to provide personal data under current legislation;
(viii) Security companies holding a license to carry out private security activities, processing the video recordings from Sport-Depot sites/offices and/or maintaining other registers in the process of ensuring the access regime in the same sites;
VI. How long are your personal data kept?
The duration of storage of your personal data depends on the processing purposes for which they were collected:
1. The personal data processed for the purpose of concluding/amending and executing contracts between Sport-Depo and you or a company represented by you - for the duration of the contract and until the final settlement of all financial relations between the parties. Sport-Depot may store some of your personal data for a longer period until the expiry of the relevant statute of limitations in order to protect against possible customer claims in connection with the performance/termination of contracts with us, as well as for a longer period in case of a legal dispute that has already arisen until its final resolution with an effective court/arbitration decision;
2. Personal data processed for the purpose of issuing accounting/financial documents for the implementation of tax-insurance control, such as but not limited to – invoices, debit, credit notices, handover protocols, contracts for the provision of services/goods are stored at least 11 years after the expiration of the limitation period for repayment of the public claim, unless the applicable legislation provides for a longer period.
3. The personal data processed for the purpose of participation in the Sport Depot club and account management on the Site - until the express withdrawal of the given consent or receipt of an objection to the processing of personal data for account management or participation in the Sport-Depot club.
4. Personal data processed for the purpose of direct marketing - until the express withdrawal of the given consent for direct marketing or receiving an objection to the processing of personal data for direct marketing.
5. Data from video recordings from security cameras - up to 60 days from the creation of the recording. Telephone conversations are stored for up to 360 days from the date of the conversation.
VII. Your Rights in relation to the processing of your Personal Data
1. General rights
In relation to the processing of personal data, you have the following rights, which you may exercise at any time while we store or process your personal data, by sending a request to the address of Sport-Depo indicated above, or electronically to email: [email protected]
You have the right to request from Sport-Depo:
- to have your personal data deleted without undue delay where there is any legal basis for doing so;
- to correct, without undue delay, your inaccurate personal data, as well as data that is no longer up-to-date;
- a copy of your personal data and access to them at any time;
- your personal data in a form convenient for transfer to another personal data controller, or to request that we do so without being hindered by us (right to portability);
- to limit the processing of your personal data, in which case your data will only be stored, but not processed. Our refusal to limit will be expressly only in writing, and we are obliged to motivate it with the lawful reason;
You also have the right to:
- to object to automated processing, including profiling;
- to withdraw your consent to the processing of your personal data at any time with a separate request addressed to Sport-Depo, in case of processing based on given consent;
- object to the processing of your personal data;
- not be subject to a decision based solely on automated processing involving profiling;
2. You have the right to appeal to the supervisory authority
You have the right to file a complaint directly with the supervisory authority, the competent authority being the Commission for the Protection of Personal Data, address: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2 (www.cpdp.bg).
In the event that you wish to file a complaint regarding the processing of your personal data by Sport-Depo, you can do so at the indicated contact details of the Administrator or directly to the Data Protection Officer (at the contact details indicated above).
3. Automated processing and profiling
When you visit our Site, we use automated processing to adapt products and services to your needs in the best possible way.
4. Objection to use for direct marketing
You have the right to object to the future processing of your personal data for the purposes of direct marketing and advertising, as well as to their disclosure to third parties and their use on their behalf for the purposes of direct marketing and advertising, by withdrawing your consent under anytime. For this purpose, you can send an electronic message with the corresponding request to stop using your data for direct marketing purposes to the address: [email protected]
5. Can you refuse to provide personal data to Sport-Depo and what are the consequences of this?
In order to conclude a contract with you and/or to provide you with the requested products and/or services and/or to deliver the ordered goods in accordance with our legal and subsequently contractual obligations, Sport-Depo needs certain data to identify the country under the contract, her attorney, contact details, payment details.
Failure to provide such data prevents us from entering into a contract with you.
In order to make a purchase from our Site and to deliver the goods or services you have ordered, you must have an account on the Site. During the profile creation process, Sport-Depo needs certain data to identify you, contact data, payment data. Failure to provide such data prevents the possibility of purchase and delivery of goods or services from you.
VIII. How we protect your data
Sport-Depot implements organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and the monitoring of the processing of personal data.
Among other things, such security measures include the following activities:
- Sport-Depot has established the requirements for processing, registration and storage of personal data with the internal procedures, compliance with which is constantly monitored;
- the access of Sport-Depot employees to personal data and the permission to process personal data in the Sport-Depot database is limited, depending on their duties;
- Sport-Depot has established confidentiality obligations for its employees;
- access to the office equipment of Sport-Depot and the computers of each employee is limited.
- we implement all the necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as the best practices of international standards
- For the purpose of maximum security when processing, transferring and storing your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.
The security measures we apply are subject to constant improvement and adaptation to the latest technologies.
IX. Link to other sites
Sometimes the Site may contain links/references (hyperlinks) to other sites. We do not operate the linked sites and do not endorse the content, services or products of those sites. We advise you to use the linked sites carefully and with due regard to their content and terms of use. Sport-Depo is not responsible for the privacy policy or content of such sites and we advise you to review their privacy policies. However, as soon as Sport-Depot receives information about illegal activities or illegal information on such Internet pages, Sport-Depot will take immediate measures to remove electronic references (links) to them.
X. Cookie Policy
To familiarize yourself with the Cookie Policy, please visit the Cookie Policy page.
Personal data for children
We do not knowingly collect personal information from children under the age of 16. If we learn that we have collected personal information from a child under the age of 16, we will take steps to delete the information as soon as possible or obtain the consent of the person with parental responsibility for the child.
Changes to the Privacy Policy
We may periodically update our Privacy Policy. In the event of a change to this policy, a notice will be published on our website, as well as the updated Privacy Policy. All amendments and additions to the Privacy Policy will be applied only after publication of its current content, available through our Site.
