Personal Data Protection Policy
Your personal data privacy and security have always been of foremost importance for us. For this reason, we have compiled this Personal Data Protection Policy which covers the procedures and regulations in accordance with which we collect, use, store, disclose and erase, or in brief "process" your personal information.
Bittel Ltd., as personal data controller, controls and processes your personal data in agreement with:
- the Personal Data Protection Act (PDPA) of the Republic of Bulgaria
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in relation to the processing of personal data and on the free movement of such data.
If you have any questions about this Personal Data Protection Policy, you can contact us at: email@example.com
Please read our Personal Data Protection Policy carefully before using our sites or providing us with your personal data. If you do not want us to process your personal data in the manner described in this Personal Data Protection Policy, please do not provide it to us. Bear in mind that in some cases we will not be able to provide you with/sell you the item or service you desire if you do not provide us with the necessary information.
User profile registration on our sites
Bittel Ltd. owns the sites www.bittel.bg, www.carmen.bg, www.klimaticite.bg, www.nippon.bg and www.farfisa.bg. It is completely voluntary and free of charge to register a user profile on our sites.
By registering a profile on one of our sites you get a universal user profile that you can use on all the other sites of Bittel Ltd. This means that any user profile registered on www.bittel.bg is also valid for www.carmen.bg, www.klimaticite.bg, www.nippon.bg and www.farfisa.bg, and vice versa.
Only one universal user profile can be registered using one e-mail address.
In order to register a user profile on our sites and place orders you need to be over 16 years old. User registration of individuals under 16 years old is completely prohibited on all sites, owned by Bittel Ltd. Bittel Ltd. does not deliberately collect personal data of persons under 16 years old. If
we find out we have collected personal data of a child under 16 years old, we shall take all necessary measures to erase this information as soon as possible.
In order to register on our sites it is necessary to agree to our General terms and Personal Data Protection Policy.
In case you do not wish to register a user profile, you can place your orders on our sites as a guest, and the personal data provided in this case is processed only for the purpose of fulfilling the specific order and is not stored for your next orders.
What is personal data?
Personal data means any information that can be used to identify a natural person.
Who processes and takes responsibility for your personal data?
Bittel Ltd is a trading company registered in the Trade Register of the Registry Agency under UIC 115163890 which collects, processes and stores your personal data under the conditions of this Personal Data Protection Policy. Bittel Ltd is a personal data controller in accordance with the Personal Data Protection Act (PDPA) - identification number 242004 in the "Register of the personal data controllers and the registers kept by them".
You can contact us at any of the following coordinates:
- Headquarters and management address: Plovdiv, Trakia - Industrial Zone, 13 Nestor Abadjiev Str.
- Business activity address: Plovdiv, Trakia - Industrial Zone, 13, Nestor Abadjiev Str.
- Correspondence address: Plovdiv, Trakia - Industrial Zone, 13, Nestor Abadjiev Str.
- E-mail: firstname.lastname@example.org
- Phone number: 032 270 027
Legal grounds for collecting, processing and storing your personal data
Bittel Ltd. collects, processes and stores your personal data on the following legal grounds:
- Your explicit consent;
- Implementing a contract between you and Bittel Ltd, as well as taking steps to enter into a contract;
- Compliance with the legal obligations of Bittel Ltd. (obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities);
- Protecting the legitimate interests of Bittel Ltd.
For what purpose do we collect, process and store your personal data?
Bittel Ltd. collects, processes and stores your personal data for the purposes of:
- User profile resigtration and maintenance on any of our sites: www.bittel.bg, www.carmen.bg, www.klimaticite.bg, www.nippon.bg и www.farfisa.bg;
- Technical assistance to create a profile on one of our sites and to recover a forgotten access password;
- Managing and administering our sites;
- Identification and verifition of legal age for online shopping;
- Personalizing / identifying you as a party of a contract with Bittel Ltd and providing the required security for the performance of the contract;
- Placing an order or purchasing an item or service on any of the sites of Bittel Ltd;
- Providing an explanation/clarification or additional information about the items and services Bittel Ltd offers;
- Managing and responding to customer complaints, inquiries, returns and complaints; refunds; replacement of goods, etc .;
- Warranty and service;
- Participant registration in questionnaire surveys, gift games, events and promotional campaigns organized by Bittel Ltd;
- Accounting purposes;
- Statistical purposes;
- Marketing purposes including direct marketing;
- Evaluating the efficiency of the marketing channels used;
- Analysis of purchase history data, customer preference and customer behaviour;
- Protection of information security;
- Sending informational messages in case of unfinished orders (items forgotten in your shopping cart);
- Sending informational messages to confirm placement of order, specifying the delivery time and method, the available quantities of the requested products, etc.
- Sending informational messages about changes in the platforms we use, recommendations for improving their use, changes in our General terms and conditions, Peronal Data Protection Policy, etc.;
- Sending a newsletter about Bittel's new products or current promotional offers (only in case you give specific unambiguous consent to receive our newsletter, by filling in our registration form). Your consent to receive our newsletter can be withdrawn at any time.
What kind of personal data does Bittel Ltd collect, process and store?
When you register a user profile on one of our sites, place an order for goods or services online, apply for a consumer loan, participate in our advertising campaigns and events, etc., different types of personal data can be collected, including, but not limited to:
1. Personalized personal data - name, surname, address, telephone number and e-mail address. These personal data can be collected when:
- registering a profile on our websites www.bittel.bg, www.carmen.bg, www.klimaticite.bg, www.nippon.bg and www.farfisa.bg;
- purchasing goods or services on our websites www.bittel.bg, www.carmen.bg, www.klimaticite.bg, www.nippon.bg and www.farfisa.bg;
- subscribing to a newsletter and advertising messages;
2. Personal number (EGN)- Your Personal Number can only be requested when:
- you clearly express interest to receive an invoice as a natural person;
- you buy goods and services in instalments.
3. Financial data and information (bank account, etc)
4. Data collected in the process of providing our services:
- Data about the IP address you use - your IP address can be used for interface localization, statistical and marketing research, etc.;
- Data about your preferred goods and services ("Favorite products" list/wishlist);
- Data collected in the communication between you and Bittel Ltd - information collected when completing the contact forms on our websites, using the chats on our websites, leaving comments and feedback about the products you purchased, etc .;
- Information about the visits and use of our websites;
- Information about your orders - etc. order history (only if you have a registered user profile on one of our websites);
- Video recordings from our offices and showrooms in the country;
- Video recordings or photos taken in accordance with the previously announced conditions for participation in gift games and / or other promotional campaigns organized by Bittel Ltd.
Bittel Ltd does NOT collect, process or store personal data revealing:
- racial or ethnic origin;
- political, religous or philosophical beliefs;
- trade union membership;
- genetic data, biometric data and data concerning health;
- data about your sexual life or sexual orientation.
How long can personal data be stored?
Bittel Ltd. will store and process the personal data provided by you for whatever time is necessary for the fulfillment of the purposes for which they have been originally collected, after which your personal data will be erased or pseudonymized / anonymized unless a legal act requires their being stored for a longer period.
If you have a registered user profile on one of our sites, Bittel Ltd. will store your personal data for a period no longer than the existence of your account on the website.
To whom we may disclose your personal data?
In relation to the fulfillment of our contractual obligations under a contract we enter into with you and in relation to meeting our legal obligations, we may disclose some of your personal data to:
- A transportation or courier company to deliver the goods you purchased to the address you specify;
- A service or installation company to perform the installation, mounting and / or initial setup of the equipment you have purchased;
- Financial, banking and credit institutions - to make the necessary payments when purchasing a good or service, including when applying for a consumer loan (buying by installments);
- External accountants/ office, assisting the accounting of Bittel Ltd.;
- Organizations, companies and individuals providing consultancy services in different fields - lawyers, marketing agencies, IT companies, etc .;
- Authorities, institutions and individuals to which we are required to disclose your personal data under the applicable laws - the National Revenue Agency, the National Social Security Institute, the Ministry of Interior, judicial authorities, supervisory authorities, etc.
- Security companies holding a license to perform private security activities processing video recordings from the facilities/offices of Bittel Ltd. and/or keeping other registers in the process of providing access to the same facilities.
Rights of natural persons
As a data subject you have the following rights:
- Right of access to your personal data;
- Right to rectify and/or add to incomplete/inaccurate data;
- Right to erasure ( right 'to be forgotten');
- Right to restrict processing;
- Right of personal data portability;
- Right to object to processing and storing your personal data;
- Right to NOT be evaluated on the basis of automated processing, including profiling;
- Right to be notified about a personal data breach;
- Right to file a complaint with a competent data protection supervisory authority.
You are entitled to check if your personal information is accurate, complete and up-to-date, as well as rectify it by signing into your profile if you have one.
If you would like to have access to your personal data collected, to claim for rectification, or request their erasure, object to their processing or withdraw your consent, you need to send a request to Bittel Ltd. at: email@example.com.
In order to avoid misuse, requests with the above content will only be considered:
- if sent from the e-mail address you used for your user profile registration on our websites and
- if they contain sufficient information (name, surname and telephone number used when registering) so as to identify you as the owner of the personal data.
Bittel Ltd. reserves the right to request additional information in order to identify you as the owner of these personal data.
Bittel Ltd makes a commitment to provide the requested information without undue delay and in any case within one month of receiving the request. If necessary, this period might be extended by a further two months, taking into account the complexity and the number of requests. Bittel Ltd. will inform you of any such extension within one month of receiving the request, indicating the reasons for the delay.
Bittel Ltd. has the right to refuse to provide the requested information, and in any case will indicate the reasons for its refusal.
In any case, you also have the right to file a complaint with the Commission for Personal Data Protection, which is the competent authority for personal data protection on the territory of the Republic of Bulgaria.
Right of access to your personal data
You have the right to require that Bittel Ltd confirm if your personal data are being processed and if so, to have access to them, as well as to information about:
- categories of personal data which are processed;
- the purposes of processing;
- recipients or categories of recipients to whom your personal data are or will be disclosed;
- whenever it is possible, the length of time during which your personal date will be processed and stored.
Right to rectify and/or add to inaccurate or incomplete data
You have the right to rectify and / or add to the personal data you have provided us with at any time. You can do this using your user profile on our websites www.bittel.bg, www.carmen.bg, www.klimaticite.bg, www.nippon.bg and www.farfisa.bg or by sending a request to Bittel Ltd. at e-mail address: firstname.lastname@example.org
Right to erasure (right 'to be forgotten')
You have the right to request from Bittel Ltd to erase the personal data related to you and Bittel Ltd. has the obligation to erase them without undue delay when there are no legal grounds for their storage and there is one of the following reasons:
- your personal data are no longer necessary for the purposes they were originally collected for or they are processed in a different way;
- processing your personal data is based on your previous consent which you are now withdrawing;
- there are no legal grounds for continuing the processing;
- your personal data have been processed unlawfully;
- the personal data have to be erased in order to comply with a legal obligation of Bittel Ltd arising from EU law or the national law of the relevant Member State;
- the personal data have been collected for the purpose of offering information society services to a child.
"The right to be forgotten" is not an absolute right. There are situations in which Bittel Ltd has the possibility to refuse to erase the data, namely when the processing of specific data is necessary for any of the following purposes:
- to comply with a legal obligation of Bittel Ltd, deriving from EU law or the national law of the relevant EU Member State;
- to establish, exercise or defend legal claims;
Right to restrict processing
You have the right to require that Bittel Ltd restrict the processing of your personal data when:
- you contest the accuracy of the data (for a period of time that allows Bittel Ltd to verify the accuracy of the data);
- the processing of your personal data is unlawful, however, you do not wish to erase them but to limit their being used;
- Bittel Ltd. no longer needs your personal data for processing purposes, but you require them to establish, exercise or defend your legal claims;
- you have objected to the processing in anticipation of a verification that the legal grounds of Bittel Ltd override your interests.
Right of data portability
In order to further strengthen the control of your personal data, you have the right to require that Bittel Ltd. provide you with your personal data at any time in a structured, widely used, machine-readable and interoperable format. You can make use of this right only when:
- Your personal data are collected based on your own consent, or
- their processing is necessary due to a contractual obligation.
Right to object to processing and storing of personal data
You have the right to object to the processing of your personal data by Bittel Ltd at any time, including if such personal data are processed for the purposes of direct marketing or profiling.
Right to not be evaluated on the basis of automated processing, including profiling
You have the right not to be the subject to a decision based solely on automated processing of personal data, including profiling. This right is inapplicable when the decision:
- is necessary to enter or perform a contract between you and Bittel Ltd;
- is permitted by EU law or the national law of the relevant EU Member State;
- is based on your explicit consent.
Right to be notified about a personal data breach
If Bittel Ltd finds out a personal data breach that may result in a high risk for your rights and freedoms, Bittel Ltd. will notify you without undue delay about the breach as well as about the measures taken or to be taken.
Bittel Ltd is not required to notify you if:
- it has subsequently taken measures to make sure that the breach of security will not lead to a high risk for your rights;
- it has taken the appropriate technical and organizational measures to protect your personal data and these measures have been applied prior to the breach of security;
- the notification would require disproportionate efforts. In this case, Bittel Ltd. will make a public statement or take another similar measure so that all affected natural persons are equally and effectively informed.
Right to file a complaint with a competent data protection supervisory authority
In the Republic of Bulgaria, the competent data protection supervisory authority is the Commission for Personal Data Protection. In case of violation of your rights, you have the right to file a complaint with the Commission for Personal Data Protection as follows:
- Headquarters and management address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd
- Correspondence address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd
- Phone number: 02 91 53 518
- E-mail: email@example.com
- Website: www.cpdp.bg
How do we protect your personal data?
Bittel Ltd has taken all necessary
- technical and
measures to protect your personal data from loss, theft and misuse, as well as unauthorized access, disclosure, alteration or destruction.
To ensure maximum protection and security for your personal data, we use additional protection mechanisms such as encryption, pseudonymization, anonymization, etc.
The security measures we apply are subject to constant improvement and adaptation to the ultimate technologies.