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Foundation Andonovo with UIC 177235161, is the owner of the domain and the website andonovo.com. Andonovo LTD, called also “Andonovo” is partner in the implementation of certain activities on the andonovo.com platform, including not only the trade and personal data protection activities of the website visitors. The performed business is entirely tuned with the non – profit educational sector and aims its support and development.

Information regarding to the Personal data administrator

Title: “Andonovo” LTD

UIC/BULSTAT: 203443750

Headquarters: Sofia 1415, Borovinka 1 str. Bulgaria

Mailing address: Sofia 1202, Tzar Simeon 98 str. Bulgaria

Phone: +359888131754

Е-mаil: contact@andonovo.com

Website: https://andonovo.com

Information about the competent supervisory authority

Title:Commission for Personal Data Protection

Headquarters: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Mailing address: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Phone : +359 2 915 3 518

Website : www.срdр.bg

Reason for combining, processing and archive of  your Personal Data

Art. 1. (1) Andonovo EOOD gathers and processes personal data in order to promote products and services and to deliver services, based on the electronic trading appraisal of Art. 6, para. 1, Regulation (EC) 2016/679, and subsequently, as follows:

Еxplicit consent obtained from you as a client and / or sales partner;

For the accomplishment of, or preparation for, the preparation of such a substance and / or trade;

Initiation of an owed debt, which should be confirmed with Andonovo EOOD;

For the legitimate interest of Andonovo EOOD.


(2) Andonovo Ltd. is the administrator of personal data relating to the data subject, which is used by our customers. In addition to personal data you are further processing, using our services, "Andonovo" Ltd. operates as a personal data processor.

Objectives and Principles for Combined, Processed, and Embedded Personal Data.

Art. 2. (1) "Andonovo" Ltd gathers and processes personal data, which you provide, in reference to use the platform for electronic trades Andonovo and to issue a contract with the company, including for the following objectives.

  • Creation of an electronics store and presentation of a complete finance of our products and services;
  • individualization of the contract parties;
  • accounting purposes;
  • statistical purposes;
  • Information security protection;
  • securing the fulfillment of the contract for the provision of the relevant goods or services;
  • Issuing information bulletins, newsletters, promotions, and updates and etc..
  • improvement and individual services , through individualized offers that are suitable for your companies, also advertisement, campaigns and other products and services, which could be of your interest;

(2) “Andonovo” Ltd. applies the following principles when working with your data :

  • Legality, integrity, clearance;
  • Restrictions of the purpose of processing;
  • Correlation of the object with the aim of processing and minimizing the gathered data;
  • Accuracy and exact information of the data given;
  • Limiting the scope, targeting to achieve the goal;
  • Integrity and confidentiality when processing and guarantee of the appropriate level of security for the personal data.

(3) When processing and storing personal data, “Andonovo” Ltd. can process and store personal data in order to protect the following legitimate interests:

  • fulfillment of  the obligations to the National Revenue Agency, Ministry of internal affairs and other governmental and municipal authorities.

What are the types of personal data which Andonovo Ltd processes and archives?

Art. 3. (1) "Andonovo" Ltd applies the following operations with the personal data in order to:

  • Advantage of consulting with clients through the Head Center - the purpose of this operation is the advancement of the client and / or product of the client. Separate cases for the purpose of the operation can also be protected by the legal implications for the implementation of the action. Impact assessment conclusion: Given the limited scope of personal data collected and the fact that they are collected on the basis of a service contract, the Data Protection Officer considers that the impact assessment of the operation is not necessary
  • Conclusion and execution of a business transaction - The purpose of this operation is to conclude and execute a contract with a trading partner or client and its administration. In some cases, the purpose of the transaction may also be to protect the legitimate interests of the company in the execution of the transaction. Impact assessment conclusion: Given the limited scope of personal data collected and the fact that they are collected on the basis of a service contract, the Data Protection Officer considers that the impact assessment of the operation is not necessary.

(2) Andonovo EOOD processes the following personal data categories and information for the following purposes and the following estimates:

Your individual data (Name and surname, email, phone number, IP address)

- The purpose of collecting the data is for: 1) Identification of an individual; 2) Contacting the customer and sending information to him, including emails for confirmation, inquiries, and others;

- Purpose for collecting your personal data -  processing is necessary to perform a contract to which the data subject is a party or to take steps at the request of the data subject prior to the conclusion of the contract - art. 6, paragraph 1, b. (b) of the GDPR.

- Purpose for which the data is collected:
improving service security and interface localization, statistical and marketing studies
.

- Reason for data processing : the processing is necessary for carrying out preparatory actions for the conclusion and performance of a contract to which the data subject is a party or for taking steps at the request of the data subject prior to the conclusion of the contract - Art. 6, para. 1b (b) of GDPR. Until a user profile is created, the IP address is collected without the ability to identify a specific individual, i.e. the data are collected in an anonymous form, on the basis of observing the legitimate interests of the administrator Art. 6, para. 1b (f) of GDPR.

Your invoice details as an individual - if you wish to receive an issued invoice, you should provide your unique civilian number.

- Purpose for which the data are collected:
issuance of an invoice for completion of payments under a contract for the provision of services for use of the e-commerce platform
.

- Purpose for which the data are collectedby accepting the general terms and conditions and registering on a website, or upon entering into a written contract, a contractual relationship is established between Andonovo EOOD and you on which grounds we process your personal data - Art. 6, para. 1, b. (b) GDРR.

(3) “Andonovo” Ltd.  does not gather and process personal data, which refer to the following:

  • disclose racial or ethnic origin;
  • disclose political, religious or phylosophical beliefs, or memberships of syndical organizations;
  • genetic and biometric data, health status data or sexual orientation or  sexual life data.

(4) Personal data, gathered from "Andonovo" Ltd. from the people they refer to.

(5) The company does not perform automatic data decision making .

Storage period of personal data

Art. 4. (1) After placing an order for any of the products or services on the site, "Andonovo" Ltd. continues to upload your Personal Data for 6 months. After the expiry of this term, “Andonovo" Ltd. takes the necessary care to delete and destroy all your data without undue delay.

(2)Andonovo" Ltd. informs you in the event that the deadline for data collection is necessary to be extended in order to fulfill the goals, fulfill the contract, in view of the legitimate interests of Andonovo EOOD or other.

(3) “Andonovo” Ltd. keeps your personal data, which is necessary to be kept, by the power of the appropriate law, for the relevant stipulated period, which may exceed the duration of your registration.

Transfer of your personal data for processing

Art. 5. (1) “Andonovo” Ltd. may, at its sole discretion, transmit some or all of your data to processing data for the fulfillment of processing objectives in compliance with the requirements of Regulation (ES) 2016/679.

(2) “Andonovo” Ltd notifies you if you intend to share some or all of your information with third countries or international organizations.

Уour rights in the collection, processing and storage of your personal data

Withdrawal of consent to the processing of your personal data

Art. 6. (1) if you do not wish all or part of your personal data to continue to be processed by “Andonovo” Ltd for a specific or all processing purpose, by filling out the consent withdrawal form in Annex № 1 or by requesting it in plain text and send it by email to us.

(2) Once we receive your request, we will send you the email you provided to receive newsletters and advertising messages, a letter detailing your verification as a newsletter recipient and data subject requesting your withdrawal of consent.

(3) With the withdrawal of the consent to the processing of personal data, if you are obliged to create and maintain your registration to use the services, your account will become inactive.

(4) Withdrawal of consent does not affect the lawfulness of the processing of personal data that the controller has carried out so far.

Access rights

Art. 7. (1) You have the right to request and receive from "Andonovo" Ltd. confirmation that any personal data related to you is being processed, by sending a request in plain text via email.

(2) You have the right to receive access to the data, related to it, and to the information, related to the gathering, processing and storage of your personal data.

(3) After we receive your request, we will send to the email, you have used for registration, a letter with detailed instructions for verifying you as the data subject requesting access.

(4) "Andonovo" Ltd. provides you, upon request, with a copy of the personal data processed by you in electronic or other suitable form.

(5) Providing access to the data is free of charge, but "Andonovo" Ltd reserves the right to impose an administrative fee in the event of repetition or excessive requests.

Complete or correction rights

Art. 8. You may correct or complete inaccurate or incomplete personal data related to you directly through your profile in your website or submit to "Andonovo" Ltd.

Rights to be deleted („to be forgotten“)

Art. 9. (1) You have the right to request  deletion of your personal data, and "Andonovo" Ltd. has the obligation to delete it without undue delay when any of the following is true:

  • your personal data is no longer needed for the needs, for which they were gathered or used in another way;
  • 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 legitimate grounds for processing to take precedence;
  • personal data were processed illegally;
  • personal data must be deleted in order to comply with a legal obligation under EU or Member State law that applies to
    "Andonovo" Ltd.
  • Personal data have been collected in connection with the provision of information society serviceso.

(2) "Andonovo" Ltd. is not obliged to delete your personal data, if they are archived or used :

  • to exercise the right to freedom of expression and the right to information;
  • to comply with a legal obligation requiring processing as provided for in EU or Member State law that applies to the controller or for the performance of a public interest task or for the exercise of official powers conferred on him;;
  • for reasons of public interest in the field of public health;
  • for purposes of archiving in the public interest, for scientific or historical research or for historical purposes;
  • for the establishment, exercise or defense of legal claims.

(3) In order to exercise your right to be forgotten, you will need to send by email a request to delete your personal data that "Andonovo" Ltd. is processing by filling in the form in Appendix № 2 or by requesting in free text, after which "Andonovo" Ltd. will send to the email that you are used to sign up, a letter with detailed instructions for verifying you as a store user and the subject of your personal data that was requested to be deleted.

(4) "Andonovo" Ltd.  does not delete the data which it has a legal obligation to preserve, including for the protection of legal claims against it or the proof of its rights.

Restriction rights

Art. 10. (1) You have the right to request "Andonovo" Ltd. to restrict the usage of the connected to you data, when:

  • dispute the accuracy of the data, for a period that allows "Andonovo" Ltd. to verify the accuracy of personal data;
  • the processing is improper, but you do not want your data to be deleted, only to restrict its use;
  • "Andonovo" Ltd. no longer needs personal data for processing purposes, but you do require it to establish, exercise or defend your legal claims;
  • you have objected to the processing pending an examination of whether "Andonovo" Ltd. 's legitimate grounds have priority over your interests.

(2)  Once we have received your request, we will send you an email that you have used to sign up, a letter with detailed instructions for verifying you as a store user, and a data subject requesting a restriction on processing.

Portability rights

Art. 11. (1) You may at any time download the data stored and processed for you in connection with the use of "Andonovo" Ltd's services by email request
.

(2) You may request "Andonovo" Ltd to directly transfer your personal data to the administrator you have specified, where technically possible.

(3) You may exercise the right of portability by sending us an Appendix №3 completed e-mail form or a free text request, and then "Andonovo" Ltd will send to the email you used for registration a letter with detailed instructions for verifying you as a store user and entity of personal data for which portability is requested.

Rights to receive information

Art. 12. You may request "Andonovo" Ltd to inform you of any recipients to whom the personal data for which rectification, deletion or restriction of processing has been requested have been disclosed. "Andonovo" Ltd may refuse to provide this information if this would be impossible or would require a disproportionate effort..

Objection rights

Art. 13. You may object at any time to the processing of personal data from "Andonovo" Ltd that relate to you, including if it is processed for profiling or direct marketing purposes.

Rights if in breach of your personal data security

Art. 14. (1) If "Andonovo" Ltd detects a breach of your personal data security which could pose a high risk to your rights and freedoms, we will notify you without undue delay of the breach, as well as any measures taken or to be takeneти.

(2) "Andonovo" Ltd is under no obligation to notify you if:

has taken appropriate technical and organizational safeguards with respect to data affected by a security breach;

has subsequently taken measures to ensure that the violation does not pose a high risk to your rights;;

notification would require a disproportionate effort.

Individuals who will receive your personal information

Art. 15. The admin does not transmit your data to third party countries.

Other regulations

Art. 16. In the event of a violation of your rights under the aforementioned or applicable data protection legislation, you have the right to file a complaint with the Data Protection Commission as follows:

Title:Commission for Personal Data Protection

Headquarters: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Mailing address: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Phone : +359 2 915 3 518

Website : www.срdр.bg


Art. 17. You can view all of your privacy data by uploading personal data via files that have been applied to this information.These are not obligatory, and you can submit your claims in any form that contains a statement to that effect and identifies you as the data owner.

Art. 18. If the consent concerns a transfer, the controller shall describe the potential risks of transferring the data to third countries in the absence of adequate protection and adequate remedies.

Art. 19. (1) When assigning to "Andonovo" Ltd to process personal data for a taut person for the purpose of using it, then "Andonovo" Ltd operates as a personal data processor.

(2) In the cases of para. 1 "Andonovo" Ltd acts solely on your instruction as a user of the service and only insofar as it may have control over the personal data you process. "Andonovo" Ltd has no control over the content and data that you, as a user of the service, choose to upload to the service (including whether or not that data includes personal data). In this case, "Andonovo" Ltd has no role in the decision-making process as to whether the user is using the personal data processing service, for what purposes and whether it is protected. Accordingly, "Andonovo" Ltd's liability in this case is limited to 1) compliance with the instructions of the service user under the contract and the general terms and conditions, and 2) the provision of information about the service and functionalities through its interface.

Appendix № 1

Consent withdrawal form for processing purposes

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

Your contact data (е-mаil)*: ..........

To

Title: “Andonovo” LTD

UIC/BULSTAT: 203443750

Headquarters: Sofia 1415, Borovinka 1 str. Bulgaria

Mailing address: Sofia 1202, Tzar Simeon 98 str. Bulgaria

Phone: +359888131754

Е-mаil: contact@andonovo.com

Website: https://andonovo.com


I withdraw my consent to the collection, processing and storage of the following personal information provided by me:

All personal information provided by me.

Only for this data: .......... for the following purposes: ..........

The following purposes: ..........

All purposes.

I declare, that I am aware of the terms and conditions of the company for the provision of the service after withdrawal of the consent.

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

Title:Commission for Personal Data Protection

Headquarters: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Mailing address: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Phone : +359 2 915 3 518

Website : www.срdр.bg


Appendix № 2

Request to be Forgotten - to delete personal information related to me

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

Your contact data (е-mаil)*: ..........

To

Title: “Andonovo” LTD

UIC/BULSTAT: 203443750

Headquarters: Sofia 1415, Borovinka 1 str. Bulgaria

Mailing address: Sofia 1202, Tzar Simeon 98 str. Bulgaria

Phone: +359888131754

Е-mаil: contact@andonovo.com

Website: https://andonovo.com


Please delete any data that you collect, process and store, provided by me or by third parties who are associated with me, according to the identified identification, from your database.

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

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

Title:Commission for Personal Data Protection

Headquarters: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Mailing address: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Phone : +359 2 915 3 518

Website : www.срdр.bg


Appendix № 3

Request for personal data portability

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

Your contact data (е-mаil)*: ..........

To

Title: “Andonovo” LTD

UIC/BULSTAT: 203443750

Headquarters: Sofia 1415, Borovinka 1 str. Bulgaria

Mailing address: Sofia 1202, Tzar Simeon 98 str. Bulgaria

Phone: +359888131754

Е-mаil: contact@andonovo.com

Website: https://andonovo.com


please all related personal data that is collected, processed and stored in your databases to be sent in .html format to:

е-mаil: ..........

Accepting data Administrator:

Title:..........

UIC/BULSTAT/ registr. Number in CPSU:..........

Е-mаil: ..........

АРI interface: ..........

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

Title:Commission for Personal Data Protection

Headquarters: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Mailing address: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Phone : +359 2 915 3 518

Website : www.срdр.bg


Appendix № 4

Request for data correction entry

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

Your contact data (е-mаil)*: ..........

To


Title: “Andonovo” LTD

UIC/BULSTAT: 203443750

Headquarters: Sofia 1415, Borovinka 1 str. Bulgaria

Mailing address: Sofia 1202, Tzar Simeon 98 str. Bulgaria

Phone: +359888131754

Е-mаil: contact@andonovo.com

Website: https://andonovo.com


Please have the following personal data that you collect, process and store, provided by me or by third parties associated with me as follows:

Data to be corrected:

..........

Please correct them as follows:

...........

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

Title:Commission for Personal Data Protection

Headquarters: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Mailing address: Sofia 1592, „Prof. Tsvetan Lazarov” 2 Blvd.

Phone : +359 2 915 3 518

Website : www.срdр.bg

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