Dear Sir / Madam,
A Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation), hereinafter referred to as „GDPR“ is in force from 25 May 2018.
As a responsible company, we at www.vinello.com have always followed all legal requirements and regulations and have taken the necessary measures to fully respond to the new European regulation
In connection with the GDPR requirements on our site www.vinello.bg, you will find mandatory information on the rights of individuals for personal data protecton in the "Privacy Policy" section. There, we have described in detail what types of personal data we keep, for what purpose, for what period, how we process them, and complete information about your rights as users of the My Vinello service when collecting, storing and processing your personal data.
In order to provide our services in accordance with our Privacy Policy and GDPR, we need to obtain your specific endorsements by providing your consent to processing your personal information.
Please note that if we do not receive your consent to process your data in accordance with our Privacy Policy and your consent to sharing your data with our third party co-contractors in relation to the service we provide to you (sharing will only be done if there is an explicit need in order to provide you with services), we will not be able to provide you with the services at www.vinello.bg and our My Vinello loyalty program.
Information about the Privacy Data Controller:
"Vayk Wines" EAD, registered in the Commercial Register at the Registry Agency under UIC / PIC 175086039, with registered office and address of management: Sofia 1528, Sofia Municipality - Iskar Area, 7, Iskarsko Shose Blvd., correspondence address: Sofia 1528, Sofia Municipality - Iskar Area, 7, Iskarsko shose Blvd., phone: +359 02 405 33 07, e-mail: info@vaykwines.com , registration of a personal data administrator in the Commission for Personal Data Protection: 34940.
Information about the competent supervisory authority:
Commission for Personal Data Protection, with registered office and address of management: Sofia 1592, "Prof. Tsvetan Lazarov "№ 2, with correspondence address: Sofia 1592," Prof. 2 Tzvetan Lazarov Str., Phone: +359 02 915 35 18, website: www.cpdp.bg
1. The Administrator collects and processes your personal data in connection with the use of the site www.vinello.bg and your use of the benefits of our My Vinello Loyalty Program in connection with the conclusion and execution of contracts with the company pursuant to Art. 6, para. (1) of Regulation (EC) 2016/679 (GDPR ), and in particular on the following grounds:
2. (1) We collect and process the personal data you provide to us in connection with the use of the site www.vinello.bg and your benefit of our My Vinello loyalty program in connection with the conclusion and execution of contracts with the company, including for the following objectives:
(2) We comply with the following principles when processing your personal information:
(3) When processing and storing personal data, the Administrator may process and store personal data to protect its legitimate interests: fulfill its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.
3. The Company performs the following operations with the personal data you provide for the following purposes:
4. (1) The administrator processes the following categories of personal data and information for the following purposes and for the following reasons:
Sign-up and newsletter details (names, e-mail, date of birth, gender, age, mobile phone number / when provided), IP address, cookie
Purpose for which data is collected: Contacting and sending information to the user, for the purpose of registering a user of www.vinello.bg for our loyalty program My Vinello, as well as to send a newsletter and advertisements.
Reason for processing your personal information: By accepting the Terms of Service and registering on www.vinello.bg for the My Vinello program or upon entering into a contract, a contractual relationship is created between the Administrator and you, on which basis we process your personal data - . 6, para. 1, b. (b) from GDPR. Your data for sending newsletters and advertising messages are processed on the basis of your explicit consent - Art. 6, para. 1, b. (s) GDPR.
Additional data provided by you – If you want to add your profile, you can fill in your full name, address, and location.
Purpose for which data is collected: Adding user information to his / her profile (account).
My Vinello grounds for data processing: You have explicitly given your consent to process the personal data for one or more specific purposes - 6, para. 1, b. (a) of the GDPR at the moment of registration on the website www.vinello.bg for the My Vinello program.
Delivery details (names, mobile phone number (when provided), e-mail, delivery address)
Purpose for which data is collected: Execution of obligations of the administrator under a contract for the purchase and sale of the purchased goods, including the exercise of the right of return and the replacement or refusal of purchased goods.
Reason for processing your personal data: By accepting the Terms and Conditions and registering on www.vinello.bg for the My Vinello program or upon entering into a contract between the Administrator and you, a contractual relationship is created, on which basis we process your personal data - art. 6, para. 1, b. (b) GDPR.
My Vinello user purchases data (names, mobile phone number (when provided), e-mail, number of purchases, date and time of purchases, used number of "Vinello-drops", amount of purchases)
Purpose for which data is collected: Execution of obligations of the administrator under a contract for purchase and sale of the purchased goods, including the exercise of the right of return and the replacement or renunciation of purchased goods.
Reason for processing your personal data: By accepting the Terms and Conditions and registering on www.vinello.bg for the My Vinello program or upon entering into a contract between the Administrator and you, a contractual relationship is created, on which basis we process your personal data - art. 6, para. 1, b. (b) GDPR.
(2) The administrator does not collect or process any personal data related to the following:
(3) The personal data are collected by the Administrator from the persons to whom they refer.
(4) The Company does not make automated decision making with data.
(5) The Company does not collect and process data for persons who have declared at the time of their registration that they are under the age of 18 years.
5. (1) The administrator keeps your personal data for no longer than your existing account www.vinello.bg . After deleting your account, the Administrator takes the necessary care to erase and destroy all your data without undue delay or to anonymize them (ie to bring them in a form that does not reveal your personality).
(2) The Administrator stores your personal data provided in connection with purchases made at our sites (stores) where you have benefited from the advantages of the My Vinello program for a period of 5 years from the date of the purchase in question for the purpose of protecting the legal interests of the Administrator in legal or administrative disputes with users of the My Vinello program, the accounting documents being kept for the relevant statutory period.
(3) The Administrator notifies you in case the data retention period is required to be extended in order to comply with a statutory obligation or with respect to the legitimate interests of the Administrator or otherwise.
6. (1) The Administrator may, at its own discretion, transmit all or part of your personal data to processors for the purposes of processing you have agreed to, subject to the requirements of EU Regulation 2016/679 (GDPR).
(2) The Administrator notifies you in the event of intention to transfer part or all of your personal data to third countries or international organizations.
7. (1) If you do not want all or part of your personal data to continue to be processed by the company for specific or for all processing purposes, you may at any time withdraw your consent to processing by a free text request.
(2) The administrator may ask you to verify your identity and identity with the data subject by asking you to enter an email address and password to access the site on site at the Company's office in front of our employee.
(3) By withdrawing the consent to process personal data that is required to create and maintain a user account on www.vinello.com in connection with our My Vinello loyalty program, your account will become inactive and you can no longer take advantage of the My Vinello program
(4) If there is a purchase order you have made to purchase a product from our site (store) for which you have used your account in our My Vinello loyalty program and is being processed, the earliest time you can withdraw your consent to processing is when the order is completed successfully.
8. (1) You have the right to request and obtain from the Administrator a confirmation that personal data relating to you are being processed, as if you are a registered user, you may at any time see in your account the personal data you have provided and which are being processed for you.
(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) The Administrator provides you with a copy of the personal data processed with you, on request, in an appropriate form.
(4) Providing access to the data is free of charge, but the Administrator reserves the right to impose an administrative fee in the event of recurrence or excessive claims.
9. You can correct or fill in the inaccurate or incomplete personal data that is related to you directly through your account at www.vinello.bg
10. (1) You have the right to ask the Administrator to delete any or all personal data related to you and the Administrator has the obligation to delete them without undue delay when any of the following reasons exists:
(2) The administrator is not obliged to delete personal data if he / she keeps and processes them:
(3) In the event that you exercise your right to be forgotten, the company will delete all of your data except for the following information:
(4) To exercise your right to be forgotten, you need to send an email request to the Administrator.
(5) The administrator may ask you to verify your identity and sameness with the person to whom the data relate.
(6) If there is an order you made to purchase a product from our site (store) for which you have used your My Vinello loyalty program account and is being processed, the earliest time you can request to be "forgotten" is upon the successful completion of the order.
(7) By deleting your personal information, your account will become inactive and you will no longer be able to take advantage of the My Vinello program.
(8) The administrator does not delete data that is legally required to store, including for protection against claims brought against him or proof of his or her rights.
11. You have the right to require the Administrator to restrict the processing of your related data when:
12. (1) You may at any time download or receive in a machine-readable format the data that is stored and processed for you in connection with the use of the Administrator's services by email request.
(2) You can ask the Administrator to directly transfer your personal data to an administrator you specify when it is technically feasible.
13. You may request the Administrator to inform you of any recipients to whom the personal data for which the correction, deletion, or limitation of the processing has been requested has been disclosed. The administrator may refuse to provide this information if this would not be possible or would require disproportionate effort.
14. You may object at any time to the processing of personal data by the Administrator that apply to you, including if it is being processed for profiling or direct marketing purposes.
15. (1) If the Administrator detects a security breach of your personal information that may pose a high risk to your rights and freedoms, he notifies you without undue delay of the violation as well as of the measures taken or to be taken.
(2) The administrator is not required to notify you if:
17. For the purpose 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 data processors - GENCLAUD LTD, registered in the Commercial Register at the Registry Agency with UIC / PIC 203378562, with registered office and address of management: Sofia 1836, Metropolitan Municipality - Poduyane District, bc. "Levski - B", 90, Vladimir Vazov Blvd., ent. "B", floor 2, apt. 2, with address for correspondence: Sofia 1836, Metropolitan Municipality - Poduyane District, bc. "Levski - B", 90, Vladimir Vazov Blvd., ent. "B", floor 2, apt. 2. These processing personal data comply with all legal and security requirements for the processing and storage of your personal data.
18. The administrator does not transfer your data to third countries.
19. In case of violation of your rights under the above or applicable data protection laws, you have the right to submit a complaint with the Commission for Personal Data Protection as follows: Commission for Personal Data Protection with registered office and management address: Sofia 1592, "Prof. Tsvetan Lazarov "№ 2, with address for correspondence: Sofia 1592," Prof. 2 Tzvetan Lazarov Str., Phone: +359 02 915 35 18, website: www.cpdp.bg .
20. You may exercise all of your rights to protect your personal data in any form that contains a statement and identifies you as the data holder.
21. If the consent relates to a transfer, the Administrator shall describe the possible risks for the transfer of data to third countries in the absence of a decision on adequate protection and appropriate remedies.
