Protection of personal data

  1. Introduction

VIAN 2102 Ltd. respects the privacy of its customers and ensures the maximum protection of their personal data. This Privacy and Personal Data Protection Policy (hereinafter referred to as “Privacy Policy”) has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection.

This Privacy Policy governs the processing of personal data of individuals or representatives of legal entities of our customers or prospective customers, and users of our website: www.vian21.com (the “Site”), in connection with the services provided by VIAN , including those provided through and accessible on the Site.

This Privacy Policy, together with the Website Terms of Use, the Cookie Policy and any other documents referred to on the Site, sets out the rules that VIAN will follow when processing personal data that we collect from or about you, or that you provide to us. This Privacy Policy does not affect, restrict or override your rights under the Personal Data Protection Act (“PDPA”) or other relevant legislation.

If you have any questions or comments about this Privacy Policy, please contact us at: office@vian21.com

Please read this Policy carefully before using the Site or providing your Personal Data, whether electronically on the Site or on paper, as by providing your Personal Data you agree to its terms. If you do not want us to process your personal data in the manner described in this Privacy Policy, please do not provide it to us. The provision of personal data by you is voluntary, in order to use certain services provided by us and to use and/or access the Site, as well as to shop online on the Site. Please note that in some cases we will not be able to provide you with the service and/or sell the goods you have requested if you do not provide us with the necessary information. Please also note that in certain cases, your consent to the processing of personal data may not be necessary if VIAN has another legal basis, e.g. compliance with statutory obligations.

  1. Who processes and is responsible for your personal data?

VIAN 2102 EOOD (“VIAN”, “we”) is the commercial company registered in the Commercial Register of the Registry Agency with UIC 205417462, which collects, processes and stores your personal data under the terms of this Privacy Policy. VIAN is a personal data controller within the meaning of the Personal Data Protection Act (PDPA). You can contact us at any of the following addresses:

Management address. Registered office, бул./ул. 4, app. 90886210286; e-mail: office@vian21.com

Data Protection Officer: Elena Ruseva

III. Categories of personal data processed by VIAN.

  1. VIAN may process publicly available personal data and/or personal data provided by you. The main types of personal data processed are:

(i) Personal identification information (including name, email address, language of communication, etc.);

(ii) Contact details (including postal and email addresses, telephone and fax numbers of you or your nominated contact person, etc.);

(iii) Financial information (bank account, etc.);

(iv) Information about a representative (legal representative or proxy of such) of our client legal entity;

(v) Site profile data (including name, postal and e-mail addresses, telephone number, date of birth, etc.);

(vi) Details of contracts of sale, dealership, wholesale, deferred payment, etc., with natural or legal persons (such as names, PINs, etc.).

  1. VIAN may process data prepared and generated by VIAN in the process of providing the Services:

(i) details of the terminal electronic communications device used, type of device, operating system used, IP address, location;

(ii) details of your preferred goods and services

(iii) Data from communication between us and you, your habits, preferences, satisfaction with our services (activity in using the services, complaints, requests, etc.);

(iv) Information regarding visits to and use of the Site, including Site operations and usage history;

(v) Data obtained in the performance of obligations arising from regulations (i.e., data arising from inquiries, regulations, investigative authorities, notary, tax services, court, bailiff);

(vi) Video recording of visits to stores or head office; voice recording – calls made to VIAN’s contact centre;

(vii) Video footage or photography produced in accordance with the previously announced terms and conditions for participation in games and/or other promotional campaigns organised by VIAN.

  1. In order to ensure the proper performance of services and obligations arising from customer contracts, VIAN is entitled to process any information available in public records (including public databases and data published on the Internet) as well as information obtained from third parties in connection with the implementation of legal provisions concerning customers.

4 VIAN has the right and obligation to verify the accuracy of the personal data recorded in the database, for this purpose requiring you to verify the data and, if necessary, to correct or confirm the accuracy of your data.

  1. The different types of personal data may be processed individually or in combination.
  2. Purposes and legal grounds for processing personal data
  3. Processing of personal data which is necessary for entering into or performance of contracts with us or in connection with the preparation for entering into contracts with us.

VIAN processes your data for the following purposes:

(i) Identification of a client when: entering into a new or amending an existing contract with us; clarification of the services used; performance of a contract.

(ii) Preparing contract proposals, sending pre-contract information and draft contract; managing pre-sales activities;

(iii) Data obtained from you in the performance of obligations arising from contracts entered into with you or a company you represent, the exercise of rights and the enforcement of contracts by our customers;

(iv) Administering and responding to customer complaints/inquiries/complaints/recommendations; refunds and returns; product exchanges;

(v) Technical assistance in creating account(s) and recovering forgotten password(s) to access our Site for electronic invoice processing.

(vi) Identification and validation of the legal age for online shopping;

(vii) Payment of debts, rescheduling of amounts due; management of collections;

(viii) Warranty and Service;

(ix) Updating suggestions to dealers; sharing important information regarding changes to our policies and other administrative information;

(x) Management and administration of online shopping activities; payment management.

  1. In compliance with its legal obligations, VIAN processes your data for the following purposes:

(i) Issuance of invoices;

(ii) For tax and social security control by the relevant competent authorities;

(iii) Compliance with obligations in relation to distance selling, off-premises selling provided for in the Consumer Protection Act;

(iv) Provision of information to the Personal Data Protection Commission in relation to obligations under the legal framework for personal data protection – Personal Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016, etc.;

(v) Obligations provided for in the Accounting Act and the Tax and Social Security Procedural Code and other related regulations in connection with the keeping of proper and lawful accounting.

  1. VIAN shall process the relevant data provided with the customer’s explicit written consent to their processing for the following purposes:

(i) Creating and managing a personal profile on the Site; technical assistance in creating profile(s) and recovering a forgotten password to access our Site;

(ii) Direct marketing of products and services;

(iii) Participation and management of surveys, giveaways, promotional campaigns;

(iv) VIAN participation and management.

  1. The processing is necessary for the purposes of VIAN’s legitimate interests.

(i) In order to safeguard and protect the property, interests and safety of VIAN, its visitors and employees, VIAN uses video surveillance equipment.

(ii) Evaluate and establish consumer satisfaction and the effectiveness of the advertising we offer to you and others and meet your expectations by presenting relevant advertising;

(iii) Analysis of purchase history data, customer preferences and behaviour;

(iv) Ensuring quality customer service (video recording, audio recording)

  1. Categories of third parties who access and process your personal data

(i) Transport/courier companies, postal operators in order to fulfill our contractual obligations, send correspondence and communications in connection with the contract between us, send purchased goods;

(ii) Persons commissioned by VIAN to maintain equipment and software used to process your personal data;

(iii) Debt collection service providers, notary, lawyer, bailiff or other third party if the customer has breached an obligation arising from a contract with us;

(iv) The banks servicing payments made by and to you;

(v) Persons to whom VIAN has outsourced the performance of part of the activities or obligations related to a specific service that we owe to you; processors who, on the basis of a contract with VIAN, process your personal data on behalf of VIAN;

(vi) Persons providing consultancy services in various fields – lawyers, accountants, marketing agencies, etc.;

(vii) Bodies, institutions and persons to whom we are obliged to provide personal data under applicable law;

(viii) Security companies licensed to conduct private security activities, processing video footage from VIAN sites/offices and/or maintaining other records in the process of securing access to the same sites;

  1. For how long is your personal data stored?

The duration of storage of your personal data depends on the purposes of the processing for which it was collected:

  1. Personal data processed for the purpose of concluding/amending and executing contracts between VIAN and you or a company represented by you – for the duration of the contract and until final settlement of all financial relations between the parties. VIAN may also store some of your personal data for a longer period until the expiry of the relevant statute of limitations in order to protect itself in the event of any customer claims in connection with the performance/termination of contracts with us, as well as for a longer period in the event of a legal dispute that has already arisen until its final resolution by a final court/arbitration decision;
  2. Personal data processed for the purpose of issuing accounting/financial documents for tax and social security control, such as, but not limited to, invoices, debit and credit notes, acceptance protocols, contracts for the provision of services/goods shall be kept for at least 11 years after the expiry of the limitation period for the repayment of the public claim, unless the applicable legislation provides for a longer period.
  3. Personal data processed for the purpose of participation in the VIAN club and profile management on the Site – until the explicit withdrawal of consent or receipt of an objection to the processing of personal data for profile management or participation in the VIAN club.
  4. Personal data processed for direct marketing purposes – until the explicit withdrawal of the consent given for direct marketing or receipt of an objection to the processing of personal data for direct marketing.
  5. Security camera footage data – up to 60 days from the creation of the footage. Phone calls are stored for up to 360 days from the time of the call.

VII. Your Rights in relation to the processing of your Personal Data

1.General rights

In relation to the processing of personal data, you have the following rights, which you can exercise at any time while we are storing or processing your personal data, by sending an application to the VIAN address listed above, or electronically to: office@vian21.com

You have the right to ask VIAN:

a copy of your personal data and access to it at any time;

to correct, without undue delay, your inaccurate personal data as well as data that is no longer up to date;

your personal data in a form convenient for transfer to another data controller, or to request that we do so without hindrance from us (right to portability);

to delete your personal data without undue delay if one of the legal grounds for doing so exists;

restrict the processing of your personal data, in which case your data will only be stored but not processed. Our refusal to restrict will only be expressly in writing, and we are obliged to state the legitimate reason for it;

You are entitled too:

to withdraw your consent to the processing of your personal data at any time by a separate request to VIAN, where processing is based on consent;

object to the processing of your personal data;

object to automated processing, including profiling;

not to be the subject of a decision based solely on automated processing, including profiling;

  1. You have the right to complain to the supervisory authority

You have the right to lodge a complaint directly with the supervisory authority, the competent authority being the Commission for Personal Data Protection, address. The authority responsible for the protection of personal data is. “1595 Prof. Tsvetan Lazarov” No. 2 (www.cpdp.bg).

If you wish to lodge a complaint about the processing of your personal data by VIAN, you may do so at the contact details of the Data Controller or directly to the Data Protection Officer (at the contact details above).

  1. Automated processing and profiling

When you visit our Site, we use automated processing to tailor products and services to your needs in the best possible way.

  1. Objection to use for direct marketing

You have the right to object to the future processing of your personal data for direct marketing and advertising purposes, as well as to their disclosure to third parties and their use on their behalf for direct marketing and advertising purposes, by withdrawing your consent at any time. For this purpose, you can send an e-mail with a corresponding request to stop the use of your data for direct marketing purposes to: office@vian21.com

  1. Can you refuse to provide personal data to VIAN and what are the consequences?

In order to enter into a contract with you and/or to provide you with the requested products and/or services and/or to deliver the ordered goods in accordance with our statutory and subsequently contractual obligations, VIAN needs certain data to identify the contracting party, its proxy, contact details, payment details.

Failure to provide such data prevents us from entering into a contract with you.

In order to make a purchase from our Site and for us to deliver the goods or services you have ordered, you must have created an account on the Site. During the account creation process, VIAN needs certain data to identify you, contact details, payment details. Failure to provide such data prevents the purchase and delivery of goods or services from you.

VIII. How we protect your data

VIAN implements organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and the monitoring of the processing of personal data.

Among other things, such security measures include the following activities:

– VIAN has established the requirements for the processing, registration and storage of personal data with internal procedures, compliance with which is monitored on an ongoing basis;

– VIAN employees’ access to personal data and permission to process personal data in VIAN’s database is limited, depending on their duties;

– VIAN has established confidentiality obligations for its employees;

– Access to VIAN office equipment and each employee’s computers is restricted.

– we apply all necessary organisational and technical measures provided for in the Data Protection Act as well as best practices from international standards

– In order to maximize the security of the processing, transmission and storage of your data, we may use additional security mechanisms such as encryption, pseudonymization, etc.

The security measures we apply are subject to constant improvement and adaptation to the latest technologies.

  1. Link to other sites

Sometimes the Site may contain links/references (hyperlinks) to other sites. We do not operate the linked sites and do not endorse the content, services and products on those sites. We encourage you to use the linked sites with care and with due regard to their content and terms of use. VIAN is not responsible for the privacy policies or content of such sites and we encourage you to review their privacy policies. However, as soon as VIAN receives information about illegal activities or illegal information on such websites, VIAN will take immediate measures to remove the electronic references (links) to them.

  1. Cookies Policy

To read the Cookie Policy, please visit the Cookie Policy page

Personal data for children

We do not knowingly collect personal information from children under the age of 16. If we become aware that we have collected personal information of a child under the age of 16, we will take steps to delete the information as soon as possible or obtain the consent of the person with parental responsibility for the child.

Amendments to the Privacy Policy

We may update our Privacy Policy from time to time. In the event of a change to this policy, a notice will be posted on our website as well as the updated Privacy Policy. Any amendments to the Privacy Policy will be implemented only after the publication of its current content, available through our Site.