This Privacy Policy (Privacy Policy and Data Protection) has been made in the obligations fulfillment by “VINI ITALIA” EOOD, UIC: 200286849 (hereinafter referred to as “VINI ITALIA” EOOD and/or “We”) according to Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) of the European Parliament and of the Council as of 27 April 2016 and the Personal Data Protection Act. The policy is informative and aims to explain what personal data has been collected by “VINI ITALIA” EOOD , for what purpose, on what legal basis, how they process and store them, as well as when it is necessary to disclose personal data to any third parties. This policy has also provided information on the rights that subjects have in relation to their personal data processing and the applied technical and organizational measures for protection against them.
About us
Administrator of the collected and processed personal data is: “VINI ITALIA” EOOD , UIC: 200286849
Headquarters and address of management
Headquarters and registered address: city of Sofia 1421, Region Lozenets, 36 Bogatitsa Str.
Email: info@divanidea.net
Web page : www.divanidea.bg
Information on our Data Protection Officer:
„VINI ITALIA” EOOD takes greater care with regard to the storage and processing of personal data and in this point it has a Data Protection Officer, whose role is to be a contact person for all matters related to the processing of your personal data, including upon exercising the rights provided by law.
Name: Olga Kostadinova Damyanova
Details for Correspondence: city of Sofia 1421, Region Lozenets, 36 Bogatitsa Str.
Email: info@divanidea.net
Personal data subjects
“VINI ITALIA” EOOD collects and processes your personal data in the course of its business activity, as well as upon various types of statutory obligations performance. In a sense, personal data can be, but not only data:
- of private entities processed in connection with the conclusion and contracts execution, including legal representatives of other trading companies -partners and customers;
- to persons involved in promotional campaigns and games carrying out, including on Facebook and Instagram or through partners – marketing agencies;
- to persons for the purposes of direct marketing;
- to persons participating in surveys conducted by “VINI ITALIA” EOOD;
- of visitors to our sites and others.
Personal data collected and processed, legal grounds and purpose of the processing
We may collect personal information about you when you participate in our games, surveys, promotional and marketing campaigns, and when you use our website. In most cases, we process your personal data on the basis of your unambiguous and specific consent. In other processing, we require your personal data for the purpose of concluding a contract, to comply with a legal obligation or to protect our legitimate interest. In all cases, we process only the minimum information needed to the specific goal accomplishing.
We may collect and process the following information about you:
| Categories of personal data | Purpose of processing | Legal basis (applied alternatively, according to the specified category and purpose of processing) |
|
– notifications related to our products and services. The data can also be used for: – fulfillment of obligations provided for in the Accounting Act and the Tax and Social Security Procedure Code, and other related normative acts, in connection with the maintenance of correct and lawful accounting, as well as in connection with the observance of other normative obligations; – fulfillment of obligations for providing information to all state commissions and regulatory bodies; – providing information to the court and law enforcement agencies. Filing and conducting court proceedings. |
Processing is necessary for the purpose of preserving our legitimate interests as a data controller. |
|
For the purposes of: – participation in campaigns and games; – publishing part of the data as a winner; – sending the won prize; – participation in research; – direct marketing for our products and services; |
Processing is based on your freely expressed, specific, informed and unambiguous consent. |
|
Answering your inquiries using the contact form. Responding to your requests for information and/or complaints. |
Processing is necessary for the purpose of preserving our legitimate interests as a data controller. |
Your information sharing:
“VINI ITALIA” EOOD shall not provide personal data to any third parties until it has been ensured that all technical, organizational and legal measures (by signing agreements) have been taken to protect this data. We shall exercise strict control to achieve this aim. In this regard, we may use third parties to support certain contractual activities. Some of these third parties (service providers) could be: law and accounting offices, auditors, couriers, carriers, contractors or providers with public authorities, as well as with other private or legal entities – for example, software and/or hardware solutions and/or infrastructure, external consultants in connection with the establishment or rights exercising, on the basis of a legal obligation or in view of their legitimate interest in the specific case.
The provision of personal data in some cases is mandatory in order to comply with our legal requirements and in this regard we shall provide information to: public and municipal authorities, ministries, NRA, NSSI, Commission for Protection of Competition (CPC), Commission for Consumer Protection (CCP), and other regulatory authorities and commissions.
Automated algorithms
We do not use automated decision making tools.
Security
The data security you confide us is very important to us. That is why we protect your data by applying all appropriate technical and organizational means at our disposal to prevent unauthorized access, unauthorized or malicious use, loss or premature deletion of information.
“VINI ITALIA” EOOD takes measures to protect your personal data from accidental loss and unauthorized access, use, alteration or disclosure. There are policies and procedures intended to protect information from loss, misuse and improper disclosure. In addition, we take additional information security measures, including access control, strict physical protection and reliable practices for collecting, storing and processing information. Some of the implemented measures are:
- Protection of the collected personal data from unjustified use and monitors their processing;
- Support for secure computer systems by which personal data has been processed. Adequate control mechanisms for data division and management have been applied to our systems;
- Adopt strict policies and procedures applicable to our staff, in order to minimize the risks of personal data processing;
- The employees of “VINI ITALIA” EOOD are familiar with the applicable rules and are trained to process personal data with the greatest care and compliance with established good practices;
- Upon performing our activities, “VINI ITALIA” EOOD has only worked with established organizations and avoids working with companies that may endanger the security of individuals personal data;
- Adopted good practices in the implementation and security systems administration and monitors technological developments in terms of possible risks to the company information security;
- Observance of the computer systems security and the personal data contained in them, including the possibilities for access to certain types of personal data by its employees;
- Providing access only to those personal data that are necessary for the performance of the work of the employee.
On the other hand, we apply technical measures such as encryption, pseudonymization and anonymization of the collected personal data, where possible.
When do we delete your personal data?
“VINI ITALIA” EOOD has deleted the collected and processed personal data in a certain order within the statutory deadlines (e.g. in the Accounting Act), and if there are none, then within the deadlines set by us in the Policy for limitation of storage and after final settlement of all our relations and the expiration of the limitation period. Personal data is not stored more than necessary for the specific purposes.
In case of anonymization of personal data, the deadlines shall not apply, as we cannot identify you.
Transfer between countries
“VINI ITALIA” EOOD in its normal activity shall not transfer personal data outside the EU.
Your rights with respect to personal data
You have a right to be informed, to get access and to obtain a copy of your personal data processed by “VINI ITALIA” EOOD. If you consider your information provided to “VINI ITALIA” EOOD is inaccurate or incomplete, you may request editing of your personal data.
In addition, you have the right:
- to an objection concerning your personal data processing;
- to request deletion of your personal data when the legal basis for their processing has ceased to exist;
- to request restrictions on the processing of your personal data; and/or
- to withdraw your consent when “VINI ITALIA” EOOD processes your personal data on the basis of consent (without such withdrawal affecting the lawfulness of the processing carried out before the withdrawal);
- on a complaint to the supervisory body – CPDP (Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd. or https://www.cpdp.bg/ ).
“VINI ITALIA” EOOD shall comply with requests, withdrawals or disagreements in accordance with the requirements of the applicable rules on personal data protection, but these rules are not absolute: they are not always applicable and there may be exceptions. In response to a request, you need to confirm your identity and/or provide additional information to help you better understand your request.
When you have re-exercised the right of access to information or a copy of the data in a machine-readable format, “VINI ITALIA” EOOD may charge a reasonable fee based on the administrative costs necessary to provide them.
How to practice them?
Each of the rights provided by law may be exercised by submitting a request to exercise the relevant right. A request for the exercise of the rights of personal data subjects may be submitted as follows:
- Electronically to the following email address: info@divanidea.net
- In personal at the following address: c. 1421, 36 Bogatitsa Str.
- The request for personal data rights exercising should contain the following information:
- Person Identification – names and Personal Identification No.;
- Contacts for feedback – address, phone, email;
- Request – description of the request.
“VINI ITALIA” EOOD provides information on the actions taken in connection with a request to exercise your rights within two months of receiving the request, according to Art. 53 Personal Data Protection Act.
If necessary, this period may be extended by another month, taking into account the complexity and number of requests from a particular person. ”VINI ITALIA” EOOD informs the person about any such extension within one month of receiving the request, indicating the reasons for the delay. The information provided to the subject and any communication and actions to exercise the data subject’s rights shall be provided free of charge (except in case of granted rights misusing).
We may request the provision of additional information needed to verify your identity when there are concerns about the identity of the requesting individual. Upon exercising your rights through a representative, we should be provided with Power of Attorney sealed by Notary Public.
“VINI ITALIA” EOOD has no obligation to respond to a request in case it is unable to identify the data subject.
Where the request is made by electronic means, the information shall be provided by electronic means, where possible, unless you have requested otherwise.
Use of Cookies
„VINI ITALIA” EOOD collects or processes personal data using cookies, and more information can be found in the Use of Cookies Policy on our website.
Update of the personal data protection policy
This policy is subject to amendment by ”VINI ITALIA” EOOD and it was last updated on 22.06.2020. Any future amendments or additions to this policy shall be duly noted.