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