Confidentiality

Information about the company that processes your data:

Name: L.A.V. Moda LTD

UIC/BULSTAT: 205350280

Headquarters: Bulgaria, region Varna, Varna municipality, c. Varna 9000, district Mladost, zh.k. Vazrazhdane 29, ent. А, fl. 8, ap. 29

Address of Correspondence: Bulgaria, region Varna, Varna municipality, c. Varna 9000, district Mladost, zh.k. Vazrazhdane 29, ent. А, fl. 8, ap. 29

Phone: 0898 502 272

Е-mail: ana_marius@abv.bg

Website: www.lavmoda.com

Information about the competent supervisory authority for personal data protection:

Name: Personal Data Protection Commission

Head office and address of management: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Correspondence address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Telephone: 02 915 3 518

Webpage: www.cpdp.bg

L.A.V. Moda LTD (hereinafter referred to as the “Administrator” or the “Company”) operates in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. This information is intended to inform you about all aspects of the processing of your personal data by the Company and the rights you have in relation to this processing.

Grounds for collecting, processing and storing your personal data:

Art. 1. The Administrator collects and processes your personal data in connection with the use of the e-shop www.lavmoda.com and concluding contracts with the company on the basis of Art. 6, para. 1, Regulation (EU) 2016/679 (GDPR), and in particular on the following grounds:

Explicit consent received from you as a customer;
Performance of the Administrator's obligations under a contract with you;
Compliance with a legal obligation applicable to the Administrator;
For the purposes of the legitimate interests of the Administrator or a third party;

Purposes and principles for collecting, processing and storing your personal data:

Art. 2. (1) We collect and process the personal data that you provide to us in connection with the use of the online store and concluding a contract with the company, including for the following purposes:

creating a profile and providing full functionality when using the online store;
concluding and executing a distance contract;
individualization of a party to the contract;
accounting purposes;
statistical purposes;
protection of information security;
ensuring the execution of the contract for the provision of the relevant service.
sending a newsletter if you express a wish;

(2) We comply with the following principles when processing your personal data:

lawfulness, good faith and transparency;
limitation of the purposes of processing;
relevance to the purposes of processing and minimization of the data collected;
accuracy and timeliness of the data;
limitation of storage in order to achieve the objectives;
integrity and confidentiality of processing and ensuring an appropriate level of security of personal data.

(3) When processing and storing 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 authorities.

What types of personal data does our company collect, process and store:

Art. 3. (1) The company carries out the following operations with the personal data provided by you for the following purposes:

Registration of a user in the online store and execution of a distance purchase contract - the purpose of this operation is to create a profile for using the online store to purchase goods and provide contact details for delivering purchased goods. Registration and creating a profile for using the online store is not a mandatory step in providing the service and it is accessible to a significant extent without creating a profile.
Conclusion of the impact assessment - Based on the impact assessment carried out, the operation "Registration of a user in the online store and execution of a distance purchase contract" is permissible for implementation and provides sufficient guarantees for the protection of the rights and legitimate interests of data subjects in accordance with the requirements of the GDPR.
Conclusion and execution of a commercial transaction with a client or partner – the purpose of this operation is to conclude and execute a contract with a commercial partner or client and its administration. Given the limited scope of the personal data collected and the fact that some of them are collected from publicly available sources, conducting an impact assessment is not necessary to conduct an impact assessment of the operation.
Sending an information bulletin (newsletter) – the purpose of this operation is to administer the process of sending newsletters to clients who have stated that they wish to receive them. Given the limited scope of the personal data collected, conducting an impact assessment is not necessary to conduct an impact assessment of the operation.
Exercising the right of withdrawal or making a complaint – the purpose of this operation is to administer the process of exercising the right of withdrawal or complaint by the client. Given the limited scope of the personal data collected, conducting an impact assessment is not necessary to conduct an impact assessment of the operation.

(2) The Administrator processes the following categories of personal data and information for the following purposes and on the following grounds:

Your individualizing data (e-mail, name, etc.)
Purpose for which the data is collected: 1) Establishing contact with the user and sending information to him, 2) for the purposes of registering a user in the online store, as well as 3) for sending a newsletter.
Grounds for processing your personal data - By accepting the general terms and conditions and registering in the online store or placing an order without registration, or upon concluding a written contract, a contractual relationship is created between the Administrator and you, on the basis of which we process your personal data - Art. 6, para. 1, b. (b) GDPR. Your data for sending a newsletter are processed on the basis of your explicit consent - Art. 6, para. 1, b. (a) GDPR.
Delivery data (names, telephone, address, etc.)
Purpose for which the data is collected: Fulfillment of the administrator's obligations under a purchase and sale contract and delivery of the purchased goods.
Grounds for processing your personal data - By accepting the general terms and conditions and registering in the online store or placing an order without registration, or upon concluding a written contract, a contractual relationship is created between the Administrator and you, on the basis of which we process your personal data - Art. 6, para. 1, b. (b) GDPR.

(3) The Administrator does not collect and does not process personal data that relate to the following:

reveal racial or ethnic origin;
reveal political, religious or philosophical beliefs, or membership in trade unions;
biometric data, data on health or data on sex life or sexual orientation.

(4) The personal data are collected by the Administrator from the persons to whom they relate.

(5) The Company does not perform automated decision-making with data.

Art. 4. (1) The Company performs the following operations with the personal data provided by you, as legal representatives or proxies of legal entities-business partners, for the following purposes:

Conclusion and execution of a commercial transaction: For the conclusion and execution of a commercial transaction with a commercial company, we process only the two names of the legal representative or the person authorized by the company.
Conclusion of the impact assessment: Given the small volume of individuals whose data is processed and given the limited volume of personal data collected, conducting an impact assessment is not necessary for this operation.

(2) The personal data are collected by the Administrator from the persons to whom they relate and from the Commercial Register at the Registry Agency.

(3) The Company does not perform automated decision-making with data.

Art. 5. The Administrator may use the so-called "cookies" for the purposes of providing full functionality of the website, improving the user experience, statistical purposes, easier access, etc., to which you agree by using our website. You can control and/or delete "cookies" at any time through the settings of the browser you use. "Cookies" do not constitute personal data and are not used to identify visitors and users of the e-store.

Period of storing your personal data

Art. 6. (1) 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, the Administrator takes the necessary care to delete and destroy all your data without undue delay or to anonymize them (i.e. to bring them into a form that does not reveal your identity).

(2) The Administrator processes your personal data that you provided when placing an order without registering in the online store until the order is completed, unless you have given your explicit consent when placing the order for your data to be processed for the purposes of improving the service, providing recommended content for you, individual conditions, promotions, as well as for statistical purposes.

(3) The Administrator stores your personal data provided in connection with online orders for a period of 5 years for the purposes of protecting the Administrator's legal interests in legal or administrative disputes with users of the online store.

(4) The Administrator shall notify you in the event that the data storage period needs to be extended in order to fulfill a regulatory obligation or in order to pursue the legitimate interests of the Administrator or otherwise.

(5) The Administrator shall store the personal data that it is required to keep under applicable law for the relevant stipulated period, which may exceed the term of your profile in the e-shop or until the order is completed.

Art. 7. The Administrator shall store the personal data of the legal representatives of its business partners for the term of performance of the contract, to comply with the legitimate interests and legal obligations of the Administrator, and this term may exceed the term of the concluded contract.

Transfer of your personal data for processing

Art. 8. (1) The Administrator may, at its own discretion, transfer part or all of your personal data to personal data processors for the purposes of processing to which you have consented, subject to the requirements of Regulation (EU) 2016/679 (GDPR).

(2) The Administrator shall notify you in the event of an intention to transfer part or all of your personal data to third countries or international organizations.

Your rights with regards to collecting, processing and storing your personal data

Withdrawal of consent to the processing of your personal data

Art. 9. (1) If you do not want the personal data you have provided to be processed for marketing purposes and receiving a newsletter, you may withdraw your consent to processing at any time by filling out the consent withdrawal form in Appendix No. 1 or by sending us a free text request by email.

(2) After we receive your request, we will send you a letter to the email address you provided for receiving newsletters and advertising messages with detailed instructions for verifying you as a recipient of newsletters and the subject of the personal data for which withdrawal of consent is requested.

(3) The withdrawal of consent does not affect the lawfulness of the processing of personal data that the Administrator has carried out up to that point.

Right of access

Art. 10. (1) You have the right to request and receive from the Administrator confirmation as to whether personal data relating to you are being processed by sending a request in free text by email.

(2) You have the right to access the data relating to you, as well as the information relating to the collection, processing and storage of your personal data.

(3) After we receive your request, we will send you a letter to the email address you used to register or place orders in the online store with detailed instructions for your verification as the subject of the personal data to which access is requested.

(4) After verification, pursuant to paragraph 3, the Administrator shall provide you upon request with a copy of the processed personal data relating to you, in electronic or other appropriate form.

(5) 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 to rectification or completion

Art. 11. (1) You may at any time correct or complete inaccurate or incomplete personal data relating to you through the “Edit profile” option.

(2) You may correct or complete inaccurate or incomplete personal data relating to you directly through your profile on the website or by sending a request to the Administrator by email using the form in Appendix No. 4 or by sending a free text request.

Right to erasure

Art. 12. (1) You have the right to request from the Administrator the erasure of some or all of your personal data, and the Administrator is obliged to erase them without undue delay where one of the following grounds applies:

The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
You withdraw your consent on which the processing of the data is based and there is no other legal basis for the processing;
You object to the processing of personal data relating to you, including for direct marketing purposes, and there are no overriding legitimate grounds for the processing;
The personal data have been processed unlawfully;
The personal data must be erased for compliance with a legal obligation under EU law or Member State law to which the Controller is subject;
The personal data have been collected in connection with the provision of information society services.

(2) The Controller is not obliged to erase personal data if it stores and processes them:

for the exercise of the right to freedom of expression and the right to information;
for compliance with a legal obligation which requires processing under EU law or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in it;
for reasons of public interest in the field of public health;
for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes;
for the establishment, exercise or defense of legal claims.

(3) In order to exercise your right to be forgotten, you must send an email request for the deletion of your personal data that the Administrator processes by filling out the form in Appendix No. 2 or by means of a free text request, after which the Administrator will send to the email address you used for registration or placing orders in the e-shop a letter with detailed instructions for your verification as a user of the shop and the subject of the personal data for which a request for deletion has been made.

(4) After we verify the identity of the person who made the request and the person to whom the data relate in accordance with the instructions sent to you, we will delete all data that we process for you in accordance with para. 3.

(5) If there is an order placed by you that is in the process of being processed, the earliest time you can request to be "forgotten" is upon successful completion of the order.

Right to restriction

Art. 13. You have the right to request the Administrator to restrict the processing of data relating to you by sending us a free text request by email when:

you contest the accuracy of the personal data, for a period that allows the Administrator to verify the accuracy of the personal data;
the processing is unlawful, but you do not want the personal data to be deleted, but only their use to be restricted;
the Administrator no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims;
you have objected to the processing pending verification of whether the legitimate grounds of the Administrator override your interests.

(2) After receiving your request, we will send you a letter to the email address you used to register or place orders in the online store with detailed instructions for your verification as a user of the store and the subject of the personal data for which a request for restriction of processing has been made.

(3) After verification in accordance with paragraph 2, the Company will cease processing your data, but will not remove the publications you have made in the online store, if any.

Right to portability

Art. 14. (1) 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:

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 specified by you, where this is technically feasible.

(2) You can exercise the right to data portability by sending us by email the completed form according to Appendix No. 3 or a free text request, after which the Administrator will send to the email address you used for registration or placing orders in the online store a letter with detailed instructions for your verification as a user of the store and the subject of the personal data for which a request for data portability has been made.

(3) After verification according to para. 2, the Company will send to the email address you specified the data it processes for you in XML format.

Right to obtain information

Art. 15. You may request the Administrator to inform you of all recipients to whom the personal data for which rectification, erasure 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 involve a disproportionate effort.

Right to object

Art. 16. You may object at any time to the processing of personal data concerning you by the Administrator, 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

Art. 17. (1) If the Administrator identifies a breach of the security of your personal data which may result in a high risk to your rights and freedoms, he shall notify you without undue delay of the breach and of the measures that have been taken or are to be taken.

(2) The administrator is not obliged to notify you if:

it has taken appropriate technical and organizational measures to protect the data affected by the security breach;
it has subsequently taken measures to ensure that the breach will not result in a high risk to your rights;
notification would require disproportionate effort.

Persons to whom your personal data is provided

Art. 18. (1) 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 the data to the following persons who are data processors:

Personal data processor Purpose of personal data processing

............................................... .....................................................................

(2) The personal data processors comply with all requirements for legality and security in the processing and storage of your personal data.

Art. 19. The administrator does not transfer your data to third countries.

Art. 20. In case of violation of your rights under the above or applicable legislation on personal data protection, you have the right to file a complaint with the Personal Data Protection Commission, as follows:

Name: Personal Data Protection Commission

Head office and registered office: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Correspondence address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Telephone: 02 915 3 518

Webpage: www.cpdp.bg

Art. 21. You can exercise all your rights regarding the protection of your personal data through the forms attached to this information. Of course, these forms are not mandatory and you can make your requests in any form that contains a statement to this effect and identifies you as the data owner.

Art. 22. If the consent concerns a transfer, the Administrator describes the possible risks of the transfer of data to third countries in the absence of an adequate protection solution and appropriate remedies.

Appendix No. 1

Form for withdrawing consent for processing purposes

Your name*: .........................

Your email address that you used in the e-shop*: .........................

Feedback details (e-mail)*: .........................

To

Name: .........................

UIC/BULSTAT: .........................

Headquarters and address of management: .........................

Correspondence address: .........................

Telephone: .........................

E-mail: .........................

Website: .........................

I hereby withdraw my consent to the processing of the personal data provided by me for the purposes of receiving a newsletter, advertising messages or other marketing materials, and I am familiar with the conditions for withdrawing consent in accordance with the Mandatory Information on the Rights of Individuals on the Protection of Personal Data of the e-shop.

In case of violation of your rights under the above or applicable personal data protection legislation, you have the right to file a complaint with the Personal Data Protection Commission, as follows:

Name: Personal Data Protection Commission.

Registered office and management address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Correspondence address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Telephone: 02 915 3 518

Webpage: www.cpdp.bg

Appendix No. 2

Request to be "forgotten" - to delete personal data related to me

Your name*: .........................

Your email address with which you registered or used for orders in the online store*: .........................

Feedback details (e-mail)*: .........................

I request that all personal data that you collect, process and store, provided by me or by third parties related to me, according to the specified identification, be deleted from your databases.

I declare that I am aware that part or all of my personal data may continue to be processed and stored by the administrator for the purposes of fulfilling its legal obligations.

In the event of a violation of your rights under the above or applicable personal data protection legislation, you have the right to file a complaint with the Personal Data Protection Commission, as follows:

Name: Personal Data Protection Commission.

Registered office and management address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Correspondence address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Telephone: 02 915 3 518

Webpage: www.cpdp.bg

Appendix No.3

Request for personal data transferability

Your name*: .........................

Your email address with which you registered or used for orders in the online store*: .........................

Feedback details (e-mail)*: .........................

I request that all personal data related to me, which are collected, processed and stored in your databases, be sent in XML format to:

E-mail: .........................

Administrator – receiving the data: .........................

Name: .........................

Identification number (UIC, BULSTAT, reg. number in the CPDP): .........................

Webpage: www.cpdp.bg

Appendix No. 4

Request for Personal Data Correction

Your name*: .........................

Your email address with which you registered or used for orders in the online store*: .........................

Feedback details (e-mail)*: .........................

I request that the following personal data that you collect, process and store, provided by me or by third parties related to me, be corrected as follows:

Data subject to correction:

..................................................

I request that it be corrected as follows:

..................................................

Webpage: www.cpdp.bg

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Confidentiality