PROTECTION OF PERSONAL DATA
From May 25, 2018. a new General Data Protection Regulation adopted by the European Union enters into force. The regulation aims to ensure the protection of data of individuals from all EU Member States and to harmonize the regulations for their processing.
As a controller of personal data for ordering and purchasing goods, LILIAN EDWARDS (FRISH AND ASSOCIATES EOOD) meets all the requirements of the new regulation, collecting only personal data to the extent necessary for the provision of the service, and keep them responsible and lawful.
Information about the Personal Data Administrator
1 Name Frisch and Associates Ltd.
2 UIC / BULSTAT: 201235697
3 Headquarters and address of management: Sofia, 1504, 11 Vasil Aprilov Str
4 Address for exercising the activity: Sofia, 1504, 11 Vasil Aprilov Str
5 Correspondence data: Sofia, 1504, 11 Vasil Aprilov Str
6 Email: email@example.com
7 Phone: 0895 545454 and 0888 836809
8 Personal data controller certificate number №
Information on the competent supervisory authority
1 Name: Commission for Personal Data Protection
2 Headquarters and address of management: Sofia 1592, bul. „Prof. Tsvetan Lazarov ”№ 2
3 Correspondence data: Sofia 1592, Prof. Tsvetan Lazarov ”№ 2
4 Phone: 02 915 3 518
5 Email: firstname.lastname@example.org, email@example.com
6 Website: www.cpdp.bg.
The administrator collects and processes your personal data in connection with the use of the online store www.lilianedwards.com and concluding contracts with the company pursuant to Art. 6, para. 1, Regulation (EU) 2016/679 (GDPR), and in particular on the following grounds:
-Explicit consent received from you as a client;
– Fulfillment of the obligations of the Administrator 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;
We collect and process the personal data you provide to us in connection with the use of the online store www.lilianedwards.com and the conclusion of a contract with the company, including for the following purposes:
-creation of a profile and provision of full functionality when using the online store;
-individualization of a party to the contract;
-protection of information security;
-ensuring the implementation of the contract for the provision of the respective service.
-sending an information bulletin and emails with special offers if you wish;
We follow the following principles when processing your personal data:
-legality, good faith and transparency;
– restriction of the purposes of processing;
-relationship with the purposes of processing and minimizing the collected data;
-accuracy and timeliness of data;
-restriction of storage in order to achieve the objectives;
-completeness and confidentiality of the processing and ensuring an appropriate level of security of personal data.
During the processing and storage of personal data, the Administrator may process and store personal data in order to protect the following legitimate interests:
– fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal bodies.
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 selling – the purpose of this operation is to create a profile for using the e-shop to purchase goods and provide contact information for delivery of purchased goods.
Sending a 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 that they wish to receive.
Exercising the right of withdrawal or making a claim – the purpose of this operation is to administer the process of exercising the right of withdrawal or claim by the customer for the goods in respect of which these rights may be exercised.
The administrator does not collect or process personal data relating to the following: The administrator does not collect or process personal data relating to the following:
• reveal racial or ethnic origin;
• disclose political, religious or philosophical beliefs, or trade union membership;
• genetic and biometric data, health data or data on sexual life or sexual orientation.
Personal data is collected by the Administrator from the persons to whom it relates.
The administrator does not perform automated data decision making.
The company does not collect data on persons under 16 years of age, except with the express consent of their parent or legal representative.
The controller processes the following categories of personal data and information for the following purposes and on the following grounds:
• Your personal data (e-mail, name, etc.)
◦ Purpose for which the data is collected: 1) Making contact with the user and sending information to him, 2) for the purposes of user registration in the online store, as well as 3) to send a newsletter, emails with special offers, promotions, promo codes, news and new features.
◦ 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, on which basis we process your personal data – Art. 6, para. 1, p. (б) GDPR. Your data for sending a newsletter and emails are processed with your explicit consent – Art. 6, para. 1, p. (а) GDPR.
• Delivery details (names, phone, address, etc.)
◦ Purpose for which the data is collected: Fulfillment of obligations of the administrator under a contract of sale and delivery of purchased goods.
◦ 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, on which basis we process your personal data – Art. 6, para. 1, p. (б) GDPR.
• Data from your social media accounts (publicly available information from your Google+, Facebook accounts)
◦ 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 – By accepting the general conditions and registration in the e-shop through a social network profile, a contractual relationship is created between the Administrator and you, on which basis we process your personal data – Art. 6, para. 1, p. (б) GDPR.
Term of storage of your personal data
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 or completing the order, the Administrator takes the necessary care to delete and destroy all your data without undue delay or to anonymize it (ie to make it in a form that does not reveal your identity).
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, and accounting documents are stored for the relevant statutory period.
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.
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.
The Administrator stores the personal data of the legal representatives of its business partners for the term of the contract, for compliance with the legitimate interests and legal obligations of the Administrator, and this term may exceed the term of the contract.
Transfer of your personal data for processing
The controller 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).
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
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 profile or by request in free text.
The administrator may ask you to verify your identity and the identity of the data subject.
By withdrawing the consent for the processing of 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.
If there is an order made by you that is in the process of processing, the earliest moment at which you can withdraw your consent for processing is upon successful completion of the order.
You may at any time withdraw your consent to the processing of your personal data for the purposes of direct marketing.
The withdrawal of the consent does not affect the legality of the processing of personal data, which the Administrator has performed so far.
Right of access
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.
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.
Upon request, the administrator provides you with a copy of the processed personal data related to you in electronic or other appropriate form.
Providing access to the data is free of charge, but the Administrator reserves the right to impose an administrative fee in case of repetitive or excessive requests.
Right of correction or completion
You may correct or complete inaccurate or incomplete personal information relating to you directly through your account on the Website or by making a request to the Administrator.
Right to delete (“to be forgotten”)
You have the 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 them without undue delay when there is 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 the purposes of direct marketing, 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 Controller;
• personal data have been collected in connection with the provision of information society services.
The administrator is not obliged to delete personal data if it stores and processes:
• 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 conferred on him;
• for reasons of public interest in the field of public health;
• for archiving purposes in the public interest, for scientific or historical research or for statistical purposes;
• to establish, exercise or defend legal claims.
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 about the operation of the online store, which information cannot be connected in any way with your personality;
• e-mail with which you registered in the online store.
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;
• To provide a unique identification code for performing the action, which will be sent to you by e-mail to the e-mail address associated with the registration in the online store;
• To identify yourself as an account holder;
After verifying the identity of the person making 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.
If there is an order placed by you that is being processed, the earliest time you can ask to be “forgotten” is when the order is successfully completed.
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.
The administrator does not delete the data that he has a legal obligation to store, including for protection in connection with court claims against him or proof of his rights.
Right of restriction
You have the right to ask the Administrator to restrict the processing of data related to you when:
• challenge 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 their use to be restricted;
• The controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or protection of your legal claims;
• You have objected to the processing pending verification of whether the legal grounds of the Administrator take precedence over your interests.
In case of exercising your right of restriction, the Company will stop processing your data, but will not remove the publications you have made in the online store.
Right of portability
If you have consented to 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 may, after identifying yourself with 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.
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
You can ask the Administrator to inform you about all recipients to whom the personal data for which correction, deletion or restriction of processing has been requested have been disclosed. The administrator may refuse to provide this information if this would be impossible or would require a disproportionate effort.
Right to object
You may object at any time to the processing of personal data by the Administrator relating to him, including if they are processed for profiling or direct marketing purposes.
Your rights in the event of a breach of the security of your personal data
If the Administrator finds a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, he shall notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken.
The administrator is not obliged to notify you if:
• 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
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 processors of personal data:
Processing personal data
Purpose of personal data processing
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.
The administrator does not transfer your data to third countries.
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:
Commission for Personal Data Protection
Headquarters and address of management
Sofia 1592, Prof. Tsvetan Lazarov ”№ 2
Sofia 1592, Prof. Tsvetan Lazarov ”№ 2
02 915 3 518
You can exercise all your rights regarding the protection of your personal data through the forms attached to this information or through the functionalities in your account. Of course, these forms are optional and you can submit your requests in any form that contains a statement to that effect and identifies you as the data holder.
If the consent relates to a transfer, the Controller shall describe the possible risks for the transfer of the data to third countries in the absence of a decision on adequate protection and appropriate means of protection.