Welcome to the policy of protection of personal data https://www.benepura.com/
1. IMPORTANT INFORMATION AND WHO WE ARE
Personal Data Administrator
Full name of the company:Euquality Ltd . , UIC:205062043, Bulgaria, Petrich,Todor Alexandrov N 18. Email: firstname.lastname@example.org You have the right to appeal at any time to the Commission for Personal Data Protection (CPDP), which is the supervisory authority of the Republic of Bulgaria for all data protection issues ( https://www.cpdp.bg/?p=pages&aid=6 ). However, we would like to use the chance to deal with your problems before contacting CPDP, so please contact us first.
CHANGES IN PERSONAL DATA PROTECTION POLICY AND OUR OBLIGATION TO INFORM YOU FOR CHANGES
The last update of this version was published in July 2018. This rule can be changed and updated periodically. Please check regularly.
It is important that the personal data we hold for you is accurate and up to date. Please let us know if your personal information changes during your relationship with us.
Links with third parties
2. DATA WE COLLECT FROM YOU
Personal data or personal information means any information about a person from which that person can be identified. It does not include data in which the identity is removed (anonymous data).
We may collect, use, store and transfer different types of personal data from you that we have categorized:
Identity data – includes name, surname, user ID
Contact details – includes delivery address, phone number and e-mail address for registration, PayPal e-mail address
Financial data – includes bank account details such as IBANs
The technical data include Internet Protocol (IP) address, your login information, browser type and version, timezone settings and location, operating system and platform and other device technologies you use to access this site
Profile data – includes your e-mail address and password, purchases or orders made by you, your interests, preferences and feedback
Marketing and communications data – includes your wish or refusal to receive e-mail notifications for important news, new offers and stores
With the exception of limited circumstances that will be clarified, we do not collect special categories of personal information about you (this includes details of your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political views, trade union membership, information for your health and genetic and biometric data). Nor do we collect information about criminal convictions and crimes. Please keep in mind that we will not consciously collect information from a person under 18 years of age. If you are under 18, you should not use this website or provide us with personal information.
If you have failed to provide personal data
If we need to collect personal data by law or under the terms of a contract we have with you, and you can not provide these data on request, we may not be able to fulfill the contract we have or are trying to conclude with you. In this case, you will not be able to join https://www.benepura.com/ .
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods of collecting data from and about you, including:
Direct interactions. You may provide us with your identity, contact details, transaction or financial data by filling out forms or by communicating with us by mail, e-mail , telephone or otherwise. This includes personal data you provide when:
You create an account on our site
You give us feedback
Technical, Transaction, Identity and Liability Data from the following:
Partner networks based both within and outside the EU; In order to improve the service we provide and the functionality of our site, we may obtain personal data from you from various third parties as outlined below:
Technical data from analytics providers, such as Google, based outside the EU
Contact and technical data when you join our site as a result of our marketing activities involving third parties.
4. HOW WE USE YOUR PERSONAL DATA
We will use your personal data under the respective rules or laws. We will most often use your personal information in the following circumstances:
When we have to fulfill the contract that we will sign or have already signed with you.
When this is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not disregard these interests.
WHY WE USE YOUR PERSONAL DATA
In a table format we’ve outlined below all the ways we plan to use your personal data and the legal bases we rely on. We also identified what our legitimate interests are where appropriate. What is legal interest?
Legal interest means the interest of our business in conducting and managing our business to provide you with the best service and the most secure experience on our Site. We assure you that we review and balance any potential impact on you (positive and negative) and your rights before we process your personal data about our legitimate interests. We do not use your personal data for activities in which our interests are neglected by your influence (unless we have your consent or if the law requires or otherwise allows us).
Implementing the Agreement means processing your data when it is necessary for the performance of a contract to which you are a party. If you do not provide personal information that we require for a contract with you, we can not sign a contract with you for providing our services.
Activity / Purpose Data type Legal basis for processing, including a basis for legitimate interests
Providing our service. This includes but is not limited to:
Manage payments from your https://www.benepura.com/ account , including sending payments through third parties such as PayPal, Transferwise, Piraeus Bank.
Implement the Contract with you
Responding and processing any requests or inquiries you may raise with us, including:
submitting an inquiry to us
escalating and official complaints, including action by the Ombudsman or legal proceedings
It is necessary for our legitimate interests to provide the most effective service to our members and for evidential purposes in the event of a dispute.
Using fraud prevention measures to protect the business from fraudulent activity and the resulting consequences.
Necessary for our legitimate interests to prevent fraud.
Manage our relationship with you, for example:
Notifying you of changes to our terms or privacy policies
Updating your data in our system, validating a payout request
Necessary for our legitimate interests to update the details and preferences of the customer
Promote the features of the Site, such as:
allowing you to participate in lots, contests, promotions
when giving personal examples of use in the media
to explore how users use the products and services of the site; update our records and encourage engagement with the site; and to promote the physical stores of the company .
Necessary for our legitimate interests related to the promotion of the site and our brand on the market in Bulgaria and the European Union .
Conducting marketing campaigns to attract new users. To do this we use different channels for new users
Campaigns to attract new users
If you join our site as a result of redirecting from a third party site, we can pay the referral party a commission. To this end, we share data with affiliate networks and tracking agencies to calculate and pay any commission due.
Pay per click
If you join our site as a result of a click on our web page from a search engine like Google or Bing, it will be tracked by a third party. Your data will be shared between us and the third-party tracking company to calculate how many new users have joined the site and how much commission is due.
Marketing in social media
We love to offer the Site to new or existing members. To ensure that our marketing is appropriate, we find ways to ensure that marketing promotions are targeted at the right people. To do this, we can share our data with large social media pages to ensure that our marketing reaches the target audience.
Necessary for our legitimate interests to engage in marketing activities.
To administer and protect our business and this Site, such as:
reporting and hosting of data
the efficient operation of the Site, the provision of administrative and IT services, network security and in the context of business reorganization or group restructuring.
Necessary for our legitimate security interests on the site
We strive to provide you with a choice of certain personal data especially with regard to marketing and advertising. Within your account, you can view and make certain decisions about the use of your personal data in relation to marketing emails.
PROMOTIONAL OFFERS FROM US
We may use your identity, contact, technical information, usage and account data to determine what we think you may want or need or what you are interested in. This way we can decide which products, services and offers can be important to you (we call this marketing). You will receive marketing messages from us if you signed up for our site and did not opt out of receiving email notifications.
MARKETING OF THIRD PARTIES
We will never sell your personal data to any company. As noted above we may share your contact or identity data with certain third parties, e.g. subprocessors to make it easier for you and social media publishers to make marketing emails to ensure that our marketing is targeted and is suitable for members of https://www.benepura.com/ .
DISCLAIMER FROM EMAIL JOURNALS
You can ask us to stop sending you marketing emails at any time by logging in to your Site account and removing the checkbox for email notifications or by following the links to opt out of any marketing email sent to you or emailing us and letting us know .
CHANGE OF THE GOAL
We will use your personal data only for the purposes for which we have collected it unless we reasonably believe that we should use it for any other reason and this reason is compatible with the original goal. If you want to get an explanation of how the processing for the new goal is compatible with the original one, please contact us at email@example.com. If we have to use your personal data for an unrelated purpose, we will let you know and explain the legal basis that allows us to do so. Please note that we may process your personal data without your knowledge or consent, in accordance with the above rules, when required or permitted by law.
5. DISCLOSURE OF YOUR PERSONAL DATA
We may have to share your personal data with the parties listed below for the purposes listed in the table in paragraph 4 above.
External third parties, as indicated in the glossary
We require all third parties to respect the security of your personal data and treat them in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and to allow them to process your personal data for specific purposes only and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS OF DATA
Some of the external third parties are outside the European Economic Area (EEA), so processing of their personal data will involve transferring data outside the EEA.
Every time we transfer your personal data outside of the EEA, we ensure that it is given a similar level of protection by ensuring that at least one of the following safeguards is applied:
We will transfer your personal data only to countries that are deemed to provide an appropriate level of personal data protection from the European Commission.
When using certain service providers, we can use specific contracts approved by the European Commission that give personal data the same protection that exists in Europe.
When using US-based providers, we may transfer data to them if they are part of the privacy protection that requires them to provide similar protection for personal data shared between Europe and the United States.
7. DATA SECURITY
We have implemented appropriate security measures to prevent accidental loss, use or access to your personal data in an unauthorized way, change or disclosure. In addition, we restrict access to your personal data to those employees, agents, contractors and other third parties on a need-to-know basis. They will process your personal data only per our instructions and are subject to a confidentiality obligation. We have put in place procedures to deal with any alleged violation of personal data and will notify you and any applicable regulator of an infringement when we are legally obliged to do so.
8. DATA STORAGE DURATION
How long will you store my personal data?
We will only retain your personal data for as long as is necessary to meet the objectives for which we have collected it, including for the purposes of complying with statutory, accounting or reporting requirements. In order to determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve these objectives by other means and the applicable legal requirements. Details of the retention periods of different aspects of your personal data are available in our detention policy, which you can request from us by contacting us at firstname.lastname@example.org
In some cases, you can ask us to delete your data. In some circumstances, we may anonymize your personal data (so that they can no longer be associated with you) for research or statistical purposes, in which case we may use this information unlimited without further notice from you.
9. YOUR LEGAL RIGHTS
Under certain circumstances you have rights under the Personal Data Protection Laws.
These rights are:
Request access to your personal data (commonly referred to as a “data access request”). This enables you to obtain a copy of the personal data we hold for you and to verify that we are legally processing it.
Ask for a correction of the personal data we hold for you. This allows you to correct any incomplete or inaccurate data we hold for you, although we may need to verify the accuracy of the new data you provide us with.
Request to delete your personal information. This allows you to ask us to delete or remove your personal data when there is no good reason to continue processing it. In addition, you have the right to ask us to delete or remove your personal data when you have successfully exercised your right to appeal the processing (see below), when we may have processed your information unlawfully or from where we are required to delete your personal data in order to comply with local laws. Note, however, that we may not always be able to execute your request for deletion for specific legal reasons that will be communicated to you, if applicable, at your request.
Object the processing of your personal data when we rely on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you oppose the processing based on this ground because you think it affects your fundamental rights and freedoms. You also have the right to object when we process your personal data for the purposes of direct marketing. In some cases, we can prove that we have convincing legitimate reasons to process your information that goes beyond your rights and freedoms.
Request restrictions for the processing of your personal data. This allows you to ask us to discontinue the processing of your personal data in the following scenarios: (a) if you want us to determine the accuracy of the data; b) when the use of your data is illegal, but you do not want to delete it; c) when you need us to store the data, even if you no longer need it, as you need to identify, exercise or defend legal claims; or (d) You have opposed the use of your data, but we need to check if we have a legitimate ground for using it.
You want to surrender your personal data to a third party. We will provide you or a third party that you have selected your personal data in a structured, often used, machine-readable format. Please note that this right applies only to automated information that you originally provided your consent to use or where we used the information to make a contract with you.
Withdraw the consent at any time when we rely on the consent to process your personal data. However, this will not affect the lawfulness of any processing performed before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case when you withdraw your consent.
You may exercise the above rights by sending us a signed, written request with a date to our email or mailing address, indicating whether you want to send this information to a specific email address or through a correspondence service.
NO FEES ARE REQUIRED
You will not pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your application is clearly unfounded, repetitive or excessive. Another possibility is to refuse to fulfill your request under these circumstances.
WHAT WE MIGHT REQUIRE FROM YOU
We may need to ask you for specific information to help us verify your identity and guarantee your right to access your personal data (or to exercise any of your other rights). This is a security measure that ensures that personal data is not disclosed to any person who is not entitled to receive them. We may also contact you to request additional information about your request to expedite your response.
We try to respond to all legitimate requests within one month. Sometimes it can take us more than a month if your request is particularly complex or you have made several requests. In this case we will inform you.
External third parties
Service providers providing IT and system administration services
Different partner networks that track your purchases through the Site
Regulatory bodies and other bodies based in Bulgaria that may require reporting of processing activities under certain circumstances
Various payment providers available on the Site.
Depending on your marketing preferences, we may engage e-mail providers as an external service
Various tracking agencies through which you have joined our Site as a result of a third party referral
Affiliate Networks means a network that acts as a mediator between our Website that promotes products and services and the stores that sell these products and services.