Privacy policy

Privacy policy

1) Information about the collection of personal data and the controller’s contact details
1.1 We are delighted that you are visiting our website and would like to thank you for your interest in our products. Below, we have provided you with information about how we handle your personal data when you use our website. Personal data, in this regard, is all data which can be used to identify you personally.
1.2 The controller for data processing on this website under the terms of the General Data Protection Regulation (GDPR) is 3A Trade Ltd  , 1618 Sofia , Liubliana str.46, J&L Center Email: info@bumot.eu

2) Data collection during visits to our website
When you are merely using our website for information purposes, i.e. if you do not register or otherwise transfer information to us, we only collect data which your browser transfers to our server (known as “server log files”). When you visit our website, we collect the following data, which is technically necessary for us to enable you to view the website:
• The web page being visited
• The date and time of access
• The amount of data sent in bytes
• The source / reference from which you accessed the page
• The browser used
• The operating system used
• The IP address used (in anonymised form if necessary)
Processing is carried out according to Art. 6, Para. 1, lit. f of the GDPR based on our legitimate interest in improving our website’s stability and functionality. The data is not distributed or used in any other way. However, we reserve the right to subsequently check the server log files if there is concrete evidence of unlawful use.
3) Cookies
We use what are known as “cookies” on various pages of our website to make your visit to our website attractive and to enable the use of certain functions. Cookies are small text files that are stored on your terminal device. Some of the cookies we use are deleted once the browser session has ended, i.e. after you close your browser (“session cookies”). Other cookies remain on your terminal device and enable us or our partner companies (cookies from third-party providers) to recognize your browser the next time you visit our website (persistent cookies). If cookies are used, they individually collect and process certain user information such as browser and location data as well as IP address values. Persistent cookies are automatically deleted after a specified period of time, which can vary depending on the cookie in question.
Sometimes, cookies are used to simplify the ordering process by saving settings (e.g. bookmarking the content of a virtual shopping basket for a subsequent visit to the website). If personal data is also processed by individual cookies implemented by us, such processing is carried out according to Art. 6, Para. 1, lit. b of the GDPR, either for the performance of the contract, or according to Art. 6, Para. 1, lit. f of the GDPR for the purpose of preserving our legitimate interests in the best possible website functionality and in making your visit to the site customer-friendly and effective.
Under certain circumstances, we work together with advertising partners who help us to make our website more interesting for you. To this end, cookies from partner companies (cookies from third-party providers) are also saved on your hard drive on this basis when you visit our website. If we work together with the aforementioned advertising partners, you will be individually and separately informed of the use of such cookies and the extent of the collected information within the paragraphs below.
Please note that you can make settings in your browser so that you are informed of cookies being set and can decide on a case-by-case basis on whether to accept them, or whether to accept cookies for certain cases or categorically prevent their use. Each browser is different in the way that it manages cookie settings. This is described in every browser’s Help menu, which explains to you how you can change your cookie settings. You will find this information for the browser in question at the following links:
Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Chrome:  https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
Safari: https://support.apple.com/kb/ph21411?locale=en_EN
Opera: http://help.opera.com/Windows/10.20/en/cookies.html
Please note that refusal to accept cookies may restrict the functionality of our website.
4) Contact
Personal data is collected in the context of contact with us (e.g. using the contact form or by email). Please see the contact form in question to find out what data is collected from a contact form. This data is only saved and used for the purpose of responding to your enquiry or for making contact and performing the associated technical administrative tasks. The legal basis for data processing is our legitimate interest in responding to your enquiry according to Art. 6, Para. 1, lit. f of the GDPR. If you have contacted us with the aim of concluding a contract, Art. 6, Para. 1, lit. b of the GDPR forms an additional legal basis. Your data will be deleted once your enquiry has been conclusively processed; this is the case if the circumstances indicate that the situation concerned has been conclusively clarified and if there are no legal retention obligations to the contrary.
5) Data processing when opening a customer account and for contract processing purposes
According to Art. 6, Para. 1, lit. b of the GDPR, personal data will continue to be collected and processed if you share it with us for the purpose of performing a contract or when opening a customer account. Please see the entry forms in question to find out what data is collected. Your customer account can be deleted at any time by sending a message to the controller’s address mentioned above. We save and use the data you share with us for contract processing purposes. Once the contract has been processed in full or your customer account has been deleted, your data will be blocked taking the retention periods set down in tax and commercial law into account and deleted once these periods have elapsed, unless you have expressly consented to further use of your data or our site reserved the right to legally permissible and further data use, which we provide you with corresponding information about below.
6) Comment function
In the context of the comment function on this website, information about the time the comment was created and your chosen commentator name are saved and published on the website along with your comment. Your IP address is also logged and saved. The IP address is saved for security reasons and in the event that the data subject infringes third-party rights with a submitted comment or posts unlawful contents. We need your email address to contact you if a third party complains that the content you published is unlawful. The legal bases for saving your data are Art. 6, Para. 1, lit. b and lit. f of the GDPR. We reserve the right to delete comments if third parties complain that they are unlawful.
7) Use of your data for direct advertising purposes
7.1 Subscription to our email newsletter
If you subscribe to our email newsletter, we will regularly send you information about the products and services we offer. Only your email address is required for sending the newsletter. Any other data which may be provided is voluntary and used to address you personally. We use the “double opt-in procedure” to send the newsletter. This means that we only send you an email newsletter if you have expressly confirmed to us that you consent to being sent newsletters. We then send you a confirmation email with which you are asked to confirm, by clicking on a corresponding link, that you would like to receive newsletters in future.
By activating the confirmation link, you give us your consent to use your personal data according to Art. 6, Para. 1, lit. a of the GDPR. When you subscribe to the newsletter, we save your IP address registered by your internet service provider (ISP) as well as the date and time of your subscription so that we can track potential misuse of your email address at a later time. The data collected when you subscribe to the newsletter is only used for the purposes of promotional advertising through the newsletter. You can unsubscribe from the newsletter at any time using the link provided for this purpose in the newsletter or by sending a message to this effect to the controller mentioned at the beginning. Once you have successfully unsubscribed, your email address is immediately deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we have reserved the right to further and legally permissible data use, which we inform you of in this policy.
7.2 Sending the email newsletter to existing customers
If you provided us with your email address when purchasing goods or services, we reserve the right to regularly email you offers relating to goods or services that are similar to the ones you have already bought from our range. We do not have to obtain any separate consent from you for this according to Section 7, Para. 3 of the Bulgarian  Unfair Competition Act. In this respect, data processing is carried out only based on our legitimate interest in personalized direct advertising according to Art. 6, Para. 1, lit. f of the GDPR. If you objected to the use of your email address for this purpose at the beginning, we will not send you any emails. You are entitled to object to the use of your email address for the aforementioned advertising purpose at any time with effect for the future by sending a message to the controller mentioned at the beginning. You will only incur transmission costs according to the basic rates for this. Following receipt of your objection, use of your email address for advertising purposes is immediately stopped.
7.3 Postal advertising
Based on our legitimate interest in personalized direct advertising, we reserve the right to save your first name, surname, postal address and – provided that we have received this additional information from you in the context of the contractual relationship – your title, academic degree, and your professional, industry or business title according to Art. 6, Para. 1, lit. f of the GDPR and to use the same to send interesting offers and information relating to our products by post.
You can object to your data being saved and used for this purpose at any time by sending a message to this effect to the controller.
8) Data processing for order processing purposes
8.1 To process your order, we work with the following service provider(s) who provide us with complete or partial support in performing concluded contracts. Certain pieces of personal data are transferred to these service providers according to the following information.
The personal data collected by us is passed on to the transport companies tasked with delivery in the context of contract processing, provided that doing so is necessary for delivery of the goods. We will pass your payment details on to the commissioned credit institute in the context of payment processing, provided that doing so is necessary for the same. If payment service providers are used, we will explicitly inform you to this effect below. The legal basis for data transfer in this regard is Art. 6, Para. 1, lit. b of the GDPR.
8.2 We work with external shipping partners to fulfil our contractual obligations vis-à-vis our customers. We pass your name and delivery address on to one of the shipping partners selected by us for the sole purposes of delivering goods according to Art. 6, Para. 1, lit. b of the GDPR.
8.3 Use of payment service providers
- BORICA bank services
If you opt to pay by credit card using the payment service provider BORICA, the payment will be processed via the payment service provider BORICA bank services, 41 Tsar Boris III Blvd. Sofia, to whom we will pass on the information you provided in the context of the ordering process along with the information about your order according to Art. 6, Para. 1, lit. b of the GDPR. Your data is only transferred for the sole purposes of payment processing with the payment service provider BORICA  and only to the extent necessary for this purpose.
- PayPal
If you pay via PayPal, credit card via PayPal, direct debit via PayPal or – if offered – “purchase on account” or “payment by instalments” via PayPal, we will pass your payment details on to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter referred to as “PayPal”) in the context of payment processing. Your information is passed on according to Art. 6, Para. 1, lit. b of the GDPR and only to the extent necessary for payment processing.
PayPal reserves the right to perform a credit check for the payment methods credit card via PayPal, direct debit via PayPal or – if offered – “purchase on account” or “payment by instalments” via PayPal. To this end, your payment details will, if necessary, be passed on to credit agencies according to Art. 6, Para. 1, lit. f of the GDPR based on PayPal’s legitimate interest in determining your ability to pay. PayPal uses the result of the credit check relating to the statistical probability of default for the purposes of making a decision on providing the respective payment methods. The credit check may contain probability values (“score values”). If score values are included in the credit check result, they are based on a scientifically recognized mathematical and scientific method. Address data is also used in the calculation of the score values, but not exclusively. For further information relating to data protection law, including the credit agencies used, please refer to PayPal’s privacy policy: https://www.paypal.com/bg/webapps/mpp/paypal-safety-and-security
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may remain entitled to process your personal data if doing so is necessary for the purposes of contractual payment processing.
9) Contact for the purpose of reminding you about reviews
Personal review reminder (not sent by a customer review system)
We use your email address to send a one-off reminder about leaving a review of your order for the review system we use, provided that you have given us your express consent to this effect according to Art. 6, Para. 1, lit. a of the GDPR either while or after placing your order.
You can revoke your consent at any time by sending a message to the controller responsible for data processing.
10) Use of social media: Videos
Use of YouTube videos
This website uses the YouTube embedding function to show and play back videos offered by the provider “YouTube”, which belongs to Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”).
In this regard, the advanced data protection mode is used, which according to the provider’s information only starts saving user information when the video(s) is/are played back. If playback of an embedded YouTube video is started, the provider “YouTube” uses cookies to collect information about user behaviour . According to information provided by “YouTube”, cookies are also used to collect video statistics which improve user-friendliness and prevent fraudulent actions. If you are logged into Google, your data will be assigned directly to your account if you click on a video. If you do not want this information to be assigned to your YouTube profile, you must log out before activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates the same. Such evaluation is carried out particularly according to Art. 6, Para. 1, lit. f of the GDPR based on Google’s legitimate interests in showing personalized advertising, performing market research and/or designing its website in an appropriate way. You have a right to object to the creation of such user profiles, whereby you must contact YouTube to exercise the same.
Regardless of whether or not an embedded video is played back, every time this website is accessed a connection is established to the “DoubleClick” Google network, which may trigger further data processing activities without any influence on our part.
Google LLC based in the USA is certified for the US-European “Privacy Shield” data protection convention, which guarantees compliance with the data protection level applicable in the EU.
You will find further information about data protection in relation to “YouTube” in the provider’s privacy policy at: https://policies.google.com/privacy
11) Web analytics services
Google (Universal) Analytics – Google Analytics
This website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”). Google Analytics uses “cookies”, which are text files that are saved on your computer and enable analysis of your use of this website. The information generated by the cookie about your use of this website (including the truncated IP address) is generally transmitted to and stored on a Google server in the USA.
This website uses Google Analytics only with the “_anonymizeIp()” extension, which ensures anonymization of the IP address by means of truncation and eliminates the possibility of direct reference being made to a particular individual. Use of the extension means that Google will truncate your IP address beforehand within Member States of the European Union or other states which are parties to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and be truncated there. In these exceptional cases, this processing will be carried out according to Art. 6, Para. 1, lit. f of the GDPR based on our legitimate interest in statistically analyzing user behaviour for optimization and marketing purposes.
On our behalf, Google will use this information for the purpose of evaluating your use of this website, compiling reports on website activities and providing us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not associated with any other data held by Google.
You can prevent the storage of cookies by changing the relevant setting in your browser software; however, please note that if you do so, you may not be able to use all the functions of this website. Furthermore, you can prevent Google’s collection and processing of the data generated by the cookie and related to your use of the website (including your IP address) by downloading and installing the browser plugin available at: http://tools.google.com/dlpage/gaoptout?hl=en
As an alternative to the browser plugin, or within browsers on mobile devices, please click on the following link to set an opt-out cookie, which will prevent any collection by Google Analytics within this website in future (this opt-out cookie only works in this browser and only for this domain; if you delete your cookies in this browser, you must click on this link again): Disable Google Analytics
Google LLC based in the USA is certified for the US-European “Privacy Shield” data protection convention, which guarantees compliance with the data protection level applicable in the EU.
You will find more information about the handling of user data in relation to Google Analytics in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de
12) Retargeting / remarketing / recommendation advertising
Google AdWords Remarketing
Our website uses the functions of Google AdWords Remarketing, which we use to place ads for this website in Google search results and on third-party websites. The provider is Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”). To this end, Google sets a cookie in your terminal device’s browser, which automatically enables interest-based advertising using a pseudonymous cookie ID and based on the pages you visit. Processing is carried out based on our legitimate interest in optimum marketing of our website according to Art. 6, Para. 1, lit. f of the GDPR.
Further data processing only takes place if you have agreed with Google that it can link your internet and app browser history to your Google account and use information from your Google account to personalise the adverts which you see online. If you are logged into Google in this case while visiting pages of our website, Google uses your data together with Google Analytics data to create and define lists of target groups for remarketing across devices. To this end, Google temporarily links your personal data with Google Analytics data to create target groups.
You can permanently disable the setting of cookies for ad preferences by downloading and installing the browser plugin available at the following link: https://www.google.com/settings/ads/onweb/
Alternatively, you can find out about the setting of cookies from the Digital Advertising Alliance at www.aboutads.info and make settings to this effect. Finally, you can make settings in your browser so that you are informed of cookies being set and can decide on a case-by-case basis on whether to accept them, or whether to accept cookies for certain cases or categorically prevent their use. The functionality of our website may be impaired if you refuse to accept cookies.
Google LLC based in the USA is certified for the US-European “Privacy Shield” data protection convention, which guarantees compliance with the data protection level applicable in the EU.
You can view further information and the data protection provisions concerning advertising and Google here: http://www.google.com/policies/technologies/ads/
13) Tools and miscellaneous
13.1 Google reCAPTCHA
We also use the reCAPTCHA function provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”) on this website. This function is primarily used to distinguish between whether an entry is made by a natural person or made improperly through machine-based and automated processing. This service includes sending the IP address and, if necessary, additional data which Google requires for the reCAPTCHA service to Google and is provided according to Art. 6, Para. 1, lit. f of the GDPR based on our legitimate interest in determining the willingness of actions performed online and in preventing misuse and spam.
Google LLC based in the USA is certified for the US-European “Privacy Shield” data protection convention, which guarantees compliance with the data protection level applicable in the EU.
You will find further information about Google reCAPTCHA and Google’s privacy policy at: https://policies.google.com/privacy?hl=en
13.2 Google Maps
We use Google Maps (API) provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”) on our website. Google Maps is a web service for showing interactive (geographical) maps to visually display geographical information; using this service shows you our location and makes it easier for you to potentially find your way there.
Even when you access those pages in which the Google Maps map is integrated, information about your use of our website (such as your IP address) is sent to Google servers in the USA and stored there. This is done regardless of whether Google provides a user account via which you are logged in, or whether such a user account does not exist. If you are logged into Google, your data will be assigned directly to your account. If you do not want this information to be assigned to your Google profile, you must log out before activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates the same. Such evaluation is carried out particularly according to Art. 6, Para. 1, lit. f of the GDPR based on Google’s legitimate interests in showing personalized advertising, performing market research and/or designing its website in an appropriate way. You have a right to object to the creation of such user profiles, whereby you must contact Google to exercise the same.
Google LLC based in the USA is certified for the US-European “Privacy Shield” data protection convention, which guarantees compliance with the data protection level applicable in the EU.
If you do not agree to your data being transferred to Google in future in the context of using Google Maps, you can also fully disable the Google Maps web service by disabling the JavaScript application in your browser. You will then be unable to use Google Maps and therefore the map screen on this website.
You can view Google’s terms of use at https://developers.google.com/maps/terms
you will find additional terms of use for Google Maps at https://www.google.com/intl/en_US/help/terms_maps.html
You will find detailed information about data protection in connection with using Google Maps on Google’s website (“Google Privacy Policy”): https://policies.google.com/privacy?hl=en
13.3 Google web fonts
This site uses “web fonts” provided by Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as “Google”) to display fonts in a uniform way. When a page is accessed, your browser loads the required web fonts in your browser cache to display texts and font types correctly.
The browser you use must establish a connection to Google’s servers for this purpose. Google thereby receives information that our website has been accessed using your IP address. Google web fonts are used in the interest of displaying our website in a uniform and appealing way. This is a legitimate interest under the terms of Art. 6, Para. 1, lit. f of the GDPR. If your browser does not support web fonts, a standard font is used by your computer.
Google LLC based in the USA is certified for the US-European “Privacy Shield” data protection convention, which guarantees compliance with the data protection level applicable in the EU.
You will find further information about Google web fonts at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/
14) Rights of the data subject
14.1 The applicable data protection legislation grants you extensive data subject rights (rights of information and intervention) vis-à-vis the controller and with regard to the processing of your personal data, which we provide you with information about below:
Right of access according to Art. 15 of the GDPR: In particular, you have a right of access concerning your personal data processed by us, the purposes of processing, the categories of personal data processed, the recipients or categories of recipients to whom your data has been or is being disclosed, the planned storage period or the criteria for defining the storage period, the existence of a right to correction, deletion and restriction of processing, a right of objection to processing, a right to lodge a complaint with a supervisory authority, the origin of your data if it was not collected by us, the existence of automated decision-making including profiling and, if necessary, meaningful information about the logic involved and the scope concerning you, as well as the intended implications of such processing, plus your right to information, and the existence of guarantees according to Art. 46 of the GDPR if your data is transferred to third countries;
Right to correction according to Art. 16 of the GDPR: You have a right to immediately correct incorrect data concerning you and/or to complete any incomplete data concerning you and saved by us;
Right to deletion according to Art. 17 of the GDPR: You have the right to request that your personal data be deleted if the requirements set down in Art. 17, Para. 1 of the GDPR are met. However, this right does not exist if processing is necessary for exercising the right to freedom of expression and information, for fulfilling a legal obligation, for reasons of public interest or for establishing, exercising or defending legal claims;
Right to restriction of processing according to Art. 18 of the GDPR: You have the right to request that processing of your personal data be restricted as long as the disputed correctness of your data is checked, if you refuse deletion of your data due to impermissible data processing and instead request restriction of your data’s processing if you require your data to assert, exercise or defend legal claims after we no longer require this data to achieve the purpose, or if you have submitted an objection based on your particular situation if it has not yet been determined whether our legitimate grounds take precedence;
Right to information according to Art. 19 of the GDPR: If you have asserted your right to correction, deletion or restriction of processing vis-à-vis the controller, the controller is obliged to inform all the recipients to whom the personal data concerning you was disclosed of this correction or deletion of data or of the restriction of processing, unless doing so proves to be impossible or would involve a disproportionate effort. You are entitled to receive information about these recipients.
Right to data portability according to Art. 20 of the GDPR: You have the right to receive your personal data which you provided us with in a structured, common and machine-readable format or to request transfer to another controller if doing so is technically feasible;
Right to revocation of any consent granted according to Art. 7, Para. 3 of the GDPR: You have the right to revoke any consent granted concerning data processing at any time with effect for the future. In the event of revocation, we will immediately delete the data concerned if further processing cannot be carried out pursuant to a legal basis for processing without consent. Revocation of consent does not affect the lawfulness of processing carried out based on consent up until the same is revoked;
Right to lodge complaints according to Art. 77 of the GDPR: If you believe that processing of personal data concerning you is in violation of the GDPR, regardless of another administrative or judicial legal remedy you have the right to lodge a complaint with a supervisory authority, particularly in the member state of your place of residence, your workplace or the place of the suspected violation.
14.2 Right of objection
When we process your personal data in the context of balancing of interests based on our overriding legitimate interest, you have the right at any time to object to such processing with effect for the future for reasons resulting from your particular situation.
If you exercise your right of objection, we will stop processing the data concerned. However, we reserve the right to further processing if we can demonstrate compelling and legitimate grounds which take precedence over your interests, fundamental rights and fundamental freedoms, or if processing serves the purpose of asserting, exercising or defending legal claims.
If we process your personal data for the purpose of carrying out direct advertising, you have the right at any time to file an objection against the processing of the personal data concerning you for the purposes of such advertising. You can exercise your right of objection as described above.
If you exercise your right of objection, we will stop processing the data concerned for direct advertizing purposes.
15) Personal data storage period
The personal data storage period is calculated using the respective legal retention period (e.g. retention periods under commercial and tax law). Once the period has elapsed, the corresponding data is routinely deleted if it is no longer required to fulfil the contract, initiate the contract and/or we have no legitimate interest in continuing to store the same.

If you have questions or complaints regarding our privacy policy or use of your information, please contact us at info@bumot.eu, or by mail at

3 A Trade Ltd
1618 Sofia
Bulgaria
Liubliana str. 46
J&L Center

• You can also contact us, during our normal business hours, by telephone at
+359886332284