Last updated: 15.06.2023

The website https://born-winner.com is the property of BORN WINER GLOBAL LTD (hereinafter referred to as “we”, “us”), with UIC: 206837533, with seat and registered office in the Republic of Bulgaria, Sofia, postal code 1164, 3 “Popovo” Street, represented by the manager Viktor Atanasov, which company is the Data Controller.

We recommend that you read this document carefully before using the website. If you have any questions regarding this Privacy Policy, please do not hesitate to contact us at info@born-winner.com or +359 879 522 533.
The supervisory authority is the Commission for the Protection of Personal Data with its address in the Republic of Bulgaria, Sofia, postal code 1592, 2 Prof. Cvetal Lazarov Boulevard, telephone 02/915 35 19; e-mail address: kzld@cpdp.bg and website www.cpdp.bg.

Principles that we follow when processing your personal data

1.1 We comply with the following principles when processing your personal data:

– Lawfulness, fairness and transparency by processing your personal data lawfully, fairly and in a transparent manner.

– We only collect your personal data for specific, explicit and legitimate purposes and do not further process it in a manner incompatible with those purposes.
– Data minimisation as the personal data we process is appropriate, relevant and limited to what is necessary in relation to the purposes for which it is processed.
– Accuracy – the personal data we process is accurate.
– Limitation of storage – the personal data we process is stored in a form that permits your identification for no longer than is necessary for the purposes for which that personal data is processed.

– Integrity and confidentiality – the personal data we process is processed in a way that ensures an appropriate level of security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by implementing appropriate technical or organisational measures.

What personal data do we collect and process?

2.1 We do not collect or process special categories of personal data. If you provide us with such data, we will delete it immediately. These include data concerning political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data for the sole purpose of identifying an individual, data concerning health or data concerning sex life or sexual orientation and others.

3.1 Personal data provided to us by third parties

In most cases, we do not process or receive personal data from third parties. However, if we have reasonable grounds to believe that violations have been committed against us, we are entitled to obtain personal data from public registers (Trade Register, etc.) of the suspected person. The legal basis for the processing of this data is for the realisation of our legitimate interests, which consist in bringing an action for infringement. The purpose of processing this data is to bring an action for infringement. 

3.2 Personal data you provide to us

Personal data that you provide when you contact us by telephone

You provide us with the following personal data when you contact us by telephone: name, telephone number, and in some cases e-mail address and address. The legal basis for the processing of this data is for pre-contractual activities undertaken at your request, namely: providing you with more information about the goods we offer in connection with the eventual conclusion of a contract with you. The purpose of processing this personal data is to respond to the request you have sent.

Personal data that you provide us when you contact us by sending a message by e-mail

You provide us with the following personal data when you contact us by sending a message by e-mail: name, e-mail, other information you provide in the message, such as address. The legal basis for the processing of this data is for pre-contractual actions taken at your request, namely: providing you with more information about the goods we offer in connection with the eventual conclusion of a contract with you. The purpose of processing this personal data is to respond to the request you have sent.

Personal data that you provide when you contact us by sending us a message by filling in the contact form

You provide us with the following personal data when you contact us by sending us a message by filling in the contact form located at https://born-winner.com/bg/kontakti/: name, e-mail, other information that you provide in the message, such as address. The legal basis for the processing of this data is for pre-contractual actions taken at your request, namely: providing you with more information about the goods we offer in connection with the eventual conclusion of a contract with you. The purpose of processing this personal data is to respond to the request you have sent.

Personal data you provide us when you subscribe to receive our newsletter 

You only provide us with your e-mail address when you wish to subscribe to receive a newsletter. This data is processed solely for the purpose of sending newsletters containing new products and promotions. The legal basis for the processing of this data is your explicit consent.

Personal data you provide when you contact us by sending a message via Facebook, Instagram, Youtube

You provide us with personal data when you contact us by sending a message via Facebook, Instagram, Youtube, as there are buttons on the website leading to our profiles on these platforms. When you contact us by sending us a message via Facebook, Instagram, Youtube we collect and process your names and also other information that may contain your personal data in the message sent. We process this data for the purpose of communicating with you. The legal basis for the processing of this personal data is for pre-contractual actions taken at your request, namely providing you with more information about the products we offer in connection with the eventual conclusion of a contract with you.

For what purposes do we process the personal data you provide?

4.1 We collect and process the personal data you provide for the following purposes only: to send you the goods you have purchased; to fulfil our legal obligations under a contract to which you are a party; to contact you by e-mail when you have made an e-mail enquiry; to fulfil a legal obligation to issue invoices; for accounting and statistical purposes.

For how long do we keep your personal data?

5.1 When you have contacted us by e-mail, Facebook, Instagram, Youtube we store your personal data for a period of one month in case you have not become our customer and for a period of ten years in case you have become our customer, which period of 10 years is the statutory period for storing invoices. Where you have purchased goods from us we keep your personal data for a period of ten years, which period of 10 years is the statutory period for keeping invoices. Where you have subscribed to receive a newsletter we retain your details until you unsubscribe from receiving the newsletter.

To whom are we entitled to disclose your personal data?

6.1 We do not sell your personal data to third parties. We have the right to disclose your personal data that we process to the following persons: to you, to state authorities (NRA, NSSI, etc.) in case it is provided for in a legal act, to processors (accounting house, hosting service providers, etc.), to courier companies.

Processing of your personal data

7.1 We process your personal data by means of a set of actions which may be carried out by automatic or non-automatic means.

Is it compulsory to provide us with your personal data?

8.1 The personal data that we require you to provide to us is entirely tailored to the services we provide and is therefore mandatory.  Of course, the provision of personal data is entirely voluntary, but you should note that if you refuse to provide us with the required personal data, you will not be able to contact us.

What rights do you have?

9.1 Right of access: You have the right to obtain confirmation from us as to whether personal data relating to you are being processed and, if so, to obtain access to the data, as well as information on: the purposes for which the personal data are being processed; the right to lodge a complaint with the Commission, respectively the Inspectorate, and their contact details; the right to require us to access, rectify, supplement or erase personal data and restrict the processing of personal data relating to you; the legal basis for the processing; the period for which the personal data will be kept and, if this is not possible, the period for which the personal data will be kept; the period for which the personal data will be kept and, if this is not possible, the period for which the personal data will be kept.

9.2 Right to rectification and completion: You have the right to ask us to correct inaccurate personal data relating to you without undue delay.  You have the right to ask us to complete incomplete personal data.

9.3 Right to erasure (“right to be forgotten”): You have the right to ask us to erase personal data concerning you where the processing infringes the provisions of section 45, 49 or 51 of the Data Protection Act or where the personal data must be erased in order to comply with a legal obligation of the controller.

9.4 Right to restrict processing: You have the right to request that we restrict the processing of personal data. We will restrict the processing of personal data without erasing it where: the accuracy of the personal data is contested by you and this cannot be verified, or the personal data must be retained for evidentiary purposes.

9.5 Right to withdraw consent: You have the right to withdraw the consent you have given at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent given prior to its withdrawal. You may withdraw your consent as set out in the “How you can exercise your rights” section of this privacy policy or by selecting the “unsubscribe” option when receiving a newsletter.

9.6 Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format where the processing is based on consent pursuant to or a contractual obligation and the processing is carried out in an automated manner.

9.7 Profiling rights: You have the right not to be subject to a decision based solely on automated processing involving profiling that produces legal effects concerning you or similarly significantly affects you.

9.8 Right to notification of a personal data breach: You have the right to be notified of a personal data breach where the personal data breach is likely to result in a high risk to your rights and freedoms.

9.9 Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with the Supervisory Authority (the Data Protection Commission) if you believe that the processing of personal data relating to you breaches the provisions of data protection legislation. The contacts of the Data Protection Commission are Republic of Bulgaria, Sofia, postal code 1592, 2 Prof. Cvetal Lazarov Boulevard, telephone 02/915 35 19; e-mail address: kzld@cpdp.bg and website www.cpdp.bg.

9.10 Right to an effective judicial remedy against a supervisory authority: You have the right to an effective judicial remedy against a binding decision of a supervisory authority concerning you.

9.11 Right to an effective judicial remedy against a controller or processor: Without prejudice to any available administrative or non-judicial remedies, including the right to lodge a complaint with a supervisory authority, you have the right to an effective judicial remedy where you consider that your rights under the Regulation have been infringed as a result of processing of your personal data which is not in accordance with the Regulation.

9.12 Right to compensation for damages: If you have suffered material or non-material damage as a result of a breach of the Regulation, you have the right to obtain compensation from us or the processor for the damage suffered.

9.13 In the event that we refuse to comply with the obligations laid down in Art. 54 para. 3, Art. 55 para. 3 and 4 and Art. 56 para. 6 and 7 of the Data Protection Act, you are entitled to exercise your rights through the Data Protection Commission.

Right to object

10.1 You have the right, at any time and on grounds relating to your particular situation, to object to processing of personal data concerning you where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us, or processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data, in particular the protection of personal data concerning you. We undertake to cease processing personal data unless we can demonstrate that there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

10.2 Where personal data is processed for direct marketing purposes, you have the right at any time to object to the processing of personal data relating to you for that type of marketing, which includes profiling, insofar as it relates to direct marketing. Where you object to processing for direct marketing purposes, the processing of personal data for those purposes shall cease.

How can you exercise your rights?

11.1 You can exercise your right to object, right to withdraw consent, right of access, right to erasure, right to rectification, right to restriction of processing, right to data portability and profiling rights by submitting a written request to us. You can submit your written request in person by sending an e-mail or by post. In the request you should provide your name, address and other data that identifies you. You must also describe what the request is about and provide an e-mail address, and date and sign the request.

11.2 Once we have received the request, we will record it on the relevant register and verify your identity to minimise the risk of unauthorised access and identity theft before responding to the request.

11.3 We undertake to consider your request which is received by us and will inform you of the action we have taken within two months of receiving the request. If necessary we have the right to extend this period by a further month, depending on the complexity and number of requests that have been received by us. Of course, if such an extension is necessary, we will notify you of this and the reasons for the delay.

11.4 In the event that we do not act on your request, we will be obliged to notify you at the latest within one month of receipt of the request of the reasons for not acting and of the possibility of lodging a complaint with a supervisory authority and seeking judicial redress.

Changes to the Privacy Policy

12.1 This Privacy Policy may be amended at any time in the future. When an update is made, the amended Privacy Policy will be posted with a new “Last Updated” date at the top and will be effective from the date of posting. If you have any questions about this Privacy Policy, you may contact us at info@born-winner.com.