Privacy Policy
Privacy policy in relation to the processing of personal data
We consider the guarantee of the right to personal data protection to be the main commitment of ELTRADE Ltd., therefore we will use and invest all necessary means and efforts to process your data in full compliance with Regulation (EU) 2016/679 (“the EU General Data Protection Regulation” or “GDPR”) and any other applicable Bulgarian legislation. As one of the main principles of this legal framework is transparency, we have prepared this document through which we want to inform you about how we collect, use, transfer and protect your personal data when you interact with us in connection with products and services, including through our website or mobile applications.
We reserve the right to periodically update and amend this Privacy Policy to reflect any changes to how we process your personal data or changes to your legal requirements. In the event of such changes, we publish the amended version of the Privacy Policy on our website and therefore kindly ask you to periodically check its contents.
Who we are and how to contact us
ELTRADE Ltd. is the trade name of the company for cash registers, commercial hardware and software “Eltrade” (hereinafter referred to as “ELTRADE Ltd” or “we”). For the purposes of data protection legislation, we are the controller in the processing of your personal data.
As your opinion is important to us and we are always ready to provide you with additional information that you may need in connection with the processing of your data, we encourage you to contact the Data Protection Officer by e-mail at eltrade@eltrade.cim, or by regular mail or courier to 1404, PK 63 blvd. “Gotse Delchev”, bl. 102 – by writing the following text: to the attention of the Personal Data Protection Officer of ELTRADE Ltd.
Which categories of personal data we process
In general, we collect your personal data directly from you, so you decide what kind of information you provide to us. For example, the information we receive from you is as follows:
When you create an account on the website www.eltrade.com of ELTRADE Ltd., you send us your e-mail address, first and last name. You can also add additional information to your personal page (My Account) from the platform of ELTRADE Ltd. such as: mobile phone number, landline phone number, address, company, etc.
When you place an order, you provide us with the following information: your desired product, first and last name, delivery address, billing details, payment method, phone number, etc.
In addition, we offer you to register on the platform of ELTRADE Ltd. through your Facebook or Google profile. If you choose one of these options, you will be directed to the Facebook Admin / Google LLC page, where you will be notified of the transfer of your data to ELTRADE Ltd. You can view the privacy policies of Facebook and Google by following the following links: https://www.facebook.com/about/privacy; https://policies.google.com/privacy
In addition, we may collect and subsequently process certain information regarding your browsing behaviour on our website or using a mobile application in order to personalise your online experience and make suggestions that are tailored to your profile. We invite you to learn more in this regard by reading the section on processing below.
On our website and mobile application, we may store and collect information through cookies and similar technologies in accordance with the Cookie Policy.
We do not collect or otherwise process sensitive data included in special categories of personal data in the General Data Protection Regulation. In addition, we do not wish to collect or process data of minors under the age of 16.
What are the purposes and grounds of processing
We will use your personal data for the following purposes:
- Provision of services to ELTRADE Ltd. in your favor
- That general objective may include, where appropriate, the following:
– Creating and managing an account on the platform of ELTRADE Ltd.;
– Processing of orders, including acceptance, validation, shipping and invoicing of the same;
– resolving problems related to order cancellations or any other problems related to orders, purchased goods or services;
– return of products in accordance with legal regulations;
– reimbursement of the value of products in accordance with legal provisions;
– Assisting, including answering your questions in relation to your orders or the goods and services of ELTRADE Ltd. or the sellers on the online platform of ELTRADE Ltd.;
– The processing of your data for these purposes is in most cases necessary for the conclusion and performance of a contract between ELTRADE Ltd. and you. In addition, the fulfilment of these purposes requires processing in accordance with applicable law, including tax and accounting laws.
- Improving our services
We would always like to offer you the best online shopping experience. For this purpose, we may use certain information about your buying behavior, invite you to complete surveys about your satisfaction after completing an order, or conduct market research and research, directly or with the help of partners.
We base these activities on our legitimate interests in conducting business activities, always ensuring that your fundamental rights and freedoms are unaffected.
- Marketing
We would like you to always be aware of the best offers for the products/services you are interested in. In this regard, we can send you all kinds of messages through electronic communication channels (e-mail / SMS / mobile push / webpush, etc.), which contain general and thematic information, information about similar products or products supplementing the products you have purchased, information about offers and promotions, information about products added in the “Account/My Cart” sections, or if you are interested in purchasing them, and other business communications such as market research and consumer opinion surveys, and we may present personalized recommendations on the website and mobile app. In order to provide you with information of interest to you, we may use certain data regarding your buyer behaviour (e.g. products viewed/ products added to the wishlist/purchased products) to create an account. We always ensure that such processing is carried out in compliance with your rights and freedoms, and that decisions taken in connection with them do not give rise to any legal effects for you and do not affect you in a similar way to a material extent.
In most cases, we require your prior consent in order to send you marketing communications. You can change your mind and withdraw your consent at any time by:
– Change the settings in the customer profile in the “Profile” section;
– use the “Unsubscribe” link in communications you receive from us;
– by contacting ELTRADE Ltd. using the contact details above.
In certain situations, we may base our marketing activities on our legitimate interest in promoting and developing our commercial activities. In any case, when we use your information for our legitimate interests, we take care and take the necessary measures to ensure that your fundamental rights and freedoms are not affected. However, you may at any time, using the means described above, terminate the processing of your personal data for marketing purposes and we will respond to your request.
Eltrade Ltd. has the right to display in its products and applications information, promotional and advertising messages related to its products, services, functionalities or offers of its commercial partners. These messages form part of the user interface of the products and applications and the use of the products and applications implies their acceptance.
Protection of our legitimate interests
There may be instances in which we use or transmit information to protect our rights and business. These may include:
– Measures to protect the website and users of the platform of ELTRADE Ltd. against cyberattacks;
– measures to prevent and detect fraud attempts, including the transmission of information to competent public authorities;
– measures to manage various other risks.
The main reason for these types of processing is our legitimate interests related to the protection of our commercial activity, and it is stipulated that we ensure that all measures taken by us guarantee a balance between our interests and your fundamental rights and freedoms.
In addition, in some cases, our processing is based on legal provisions such as the obligation to protect goods and values provided for by the applicable legislation in this regard.
How long we keep your personal data
As a rule, we store your personal data as long as you have an account with ELTRADE Ltd. You can always ask us to delete certain information or close your account, and we will respond to this request by retaining certain information, even after closing the account, when applicable law or legitimate interests require it.
Who we send your personal data to
Depending on the case, we may transfer or give access to some of your personal data to the following categories of recipients:
– partners in the market platform of ELTRADE Ltd.;
– Courier service providers;
– Payment/banking service providers;
– Providers of marketing/telemarketing services;
– Providers of market research services;
– IT service providers;
– other companies with which we may develop joint programs for the sale of our goods and services on the market.
If we are required by law, or if this is necessary to protect our legitimate interests, we may also disclose certain personal data to public authorities.
We guarantee that access to your data by third-party private parties is carried out in accordance with the legal provisions in the field of data protection and confidentiality, on the basis of contracts concluded with them.
How we protect the security of your personal data
We are committed to ensuring the security of personal data by applying appropriate technical and organizational measures in compliance with industry standards.
We store your data on secure servers, using the latest encryption algorithms and ensuring that backups are stored.
We use the ePay payment processing service to make the payments. All payment information is encrypted using SSL technology.
Despite the measures we put in place to protect your personal data, we are aware that, in principle, the transmission of information over the Internet or other public networks is not completely safe, and there is a risk that the data may be viewed and used by unauthorized third parties. We cannot take responsibility for these vulnerabilities of systems that are not under our control.
What are your rights
The General Data Protection Regulation recognises a number of rights in relation to your personal data. You can request access to your data, the correction of errors in our files, and/or raise objections to the processing of your personal data. You can also exercise your right to lodge a complaint with the competent supervisory authority or with the court. Depending on the case, you may also have the right to request the erasure of your personal data, the right to restrict the processing of your data and the right to data portability.
To exercise your rights, you can contact us using the contact details provided above. Please take into account the following if you wish to exercise these rights:
– Identity. We take seriously the confidentiality of all records containing personal data. For this reason, we ask you to send us your requests regarding these records using your e-mail address provided in your account with ELTRADE Ltd. Otherwise, we reserve the right to verify your identity by requesting additional information to verify it.
– Taxi. We will not charge a fee for exercising any rights in relation to your personal data, except where your request for access to information is unfounded, repeatedly or unnecessarily repeated, in which case we will charge a reasonable amount. We will inform you of any applicable fees before we consider your request.
– Deadline for reply. We plan to respond to all valid requests within one month, except when the request is particularly complex, or if you have made more requests, in which case we will respond within a maximum of two months. We will let you know if we will need more than one month. We may ask you to tell us exactly what you want to receive or what you are worried about. This will help us act faster and shorten the time it takes to respond to your request.
– Rights of third parties. We will not need to respond to a request if it negatively affects the rights and freedoms of other data subjects.
You can ask us:
– to confirm that we are processing your personal data;
– provide a copy of this data;
– to provide you with information about your personal data, such as the data we hold, how we use it, to whom we disclose it, whether we transfer it abroad and how we protect it, how long we keep it, what rights you have, how you can lodge a complaint, where we acquired your data, to the extent that the information has not already been provided to you through this notice.
– to ask us to correct or supplement your inaccurate or incomplete personal data. We may try to verify the inaccuracy of the data before correcting it.
– ask us to delete your personal data, but only if it is no longer necessary for the purposes for which it was collected; or you have withdrawn your consent (if the processing of the data is based on consent); or you exercise a legal right to object; or they have been illegally processed; or there is a legal obligation in this regard.
We have no obligation to comply with your request for the deletion of your personal data if their processing is required:
– in order to fulfill a legal obligation; or
– to establish, exercise or defend a legal claim;
There are certain other circumstances in which we are not obliged to comply with your request for data deletion, although these are also the most likely circumstances in which we may refuse your request.
Please note that before exercising this right, you must withdraw from your account with ELTRADE Ltd. and keep all documents related to the orders placed by ELTRADE Ltd., regardless of whether the billing was made to you or to another natural or legal person (such as invoices, warranty certificates). If you do not do so before exercising your right to erasure, you will lose all these documents and ELTRADE Ltd. will not be able to provide them to you, as the case may be, as the process of deleting data and deleting the ELTRADE Ltd. account with all data and documents related to it is an irreversible process.
Restriction of data processing
You can ask us to restrict the processing of your personal data, but only if:
– their accuracy is disputed (see the section on data correction) so that we can verify their accuracy;
– the processing is unlawful, but you do not want the data to be deleted;
– they are no longer necessary for the purposes for which they were collected, but we still need to establish, exercise or defend a legal claim;
– You have already exercised the right to object and check whether the dominance of our rights still exists.
We may continue to use your personal data as a result of a restriction request:
– if we have your consent;
– to establish, exercise or defend a legal claim;
– to protect the rights of ELTRADE Ltd. or any other natural or legal person.
Data portability
You can ask us to provide your personal data in a structured, commonly used and machine-readable format, or you can request that it be directly “ported” to another data controller, but only if:
– the processing is based on your consent or on the conclusion of a contract with you;
– Processing is carried out by an automatic means.
Right to object
You can object at any time, for reasons related to your specific situation, to the processing of your personal data based on our legitimate interests if you consider that your fundamental rights and freedoms override those interests.
In addition, you can object at any time to the processing of your data for direct marketing purposes (including the creation of accounts) without giving any reason, in which case the processing will cease as soon as possible.
Making automatic decisions
You can ask us not to be subject to a decision based solely on automatic processing, but only when that decision:
– gives rise to legal consequences for you;
– or affects you in a similar way and to a significant extent.
This right shall not apply if the decision taken after the adoption of an automatic decision:
– we need it in order to enter into or perform a contract with you;
– is permitted by law and adequate guarantees for your rights and freedoms are in place;
– or is based on your explicit consent.
Complaints
You have the right to lodge a complaint with your local supervisory authority regarding the processing of your personal data.
Without prejudice to your right to contact the supervisory authority at any time, please contact us in advance and we promise you that we will make our best efforts to resolve your concerns amicably.
We remind you that you can contact the Personal Data Protection Officer of ELTRADE Ltd. at any time by sending your request to him in one of the following ways:
– by e-mail to: eltrade@eltrade.com
– by regular mail or courier to the address: 1404 Sofia, PK 63 blvd. “Gotse Delchev”, bl. 102, by writing the text for the attention of the Personal Data Protection Officer of ELTRADE Ltd.