Effective May 25, 2018 and is an integral part of the Site Terms and Conditions
BENECROMA Ltd. Is the owner of this website. According to the Personal Data Protection Act and Regulation 2016/679 of the EU on the protection of personal data, BENECROMA Ltd. is a personal data controller. We collect, store and use this data from your registrations in the site. By virtue of the above acts, you, as a physical person, are subject of personal data, and we are the controller of your personal data that we process.
Administrator contact details you may use:
(Identifying Code) 130464491
registered office and address for correspondence: city of Sofia 1202, Oborishte district, 52 Tsar Simeon Str.,
Tel. +359 2 9156100
To contact the administrator, use the contact form on the site.
Our data protection officer can be contacted at e-mail: : email@example.com
PERSONAL DATA WE COLLECT
When registering on the site or by phone, when participating in games organized by us, or when asking questions, we may receive from you or may ask you to provide us certain information about yourself.
This information may include:
• Your names – in order to know who you are;
• email address – in order we can send you a message about your winnings from our games, in order for you to ask questions or file a complaint, etc. You can request not to receive e-mail messages from us any longer by clicking on the Unsubscribe link at the bottom of the e-mail message we have sent you or by sending us your e-mail for this purpose.
• contact address – in order we can send your prize won from our games;
• mobile or fixed phone number – to call you in connection with the prize;
• if you have registered an account with us (e.g. via the site registration webpage: additional data such as your date of birth, your password and certain preferences, history of your participation in our games. If you link this account of yours to your Facebook profile or other social media: additional information about your contacts, friends, likes and dislikes, if you choose to share such information with us through your social media account settings.
• information that you “like” or “dislike” us and information from your posts that you make on our pages in social networks;
• technical information about your device with which you open our web pages, IP address when visiting our pages – in order to be able to provide you the best possible service through our web pages;
• “cookies” – like most websites you visit, we also use “cookies”; more information about this can be obtained from our cookies policy here;
• Your voice data – when you call our phones and the call is recorded;
• any other information voluntarily provided by you.
We use the information about your personal data so that we can supply you quality services. When we process your personal data for the delivery of your prizes from the games, to ensure the security of our sites, as well as to fulfill our statutory obligations, this processing is mandatory for the fulfillment of these purposes. Without this data we would not be able to provide the relevant services. For example, if you do not provide us your names and address, we would not be able to make a home delivery of your prizes. If we collect your data for other purposes, we will necessarily ask for your additional consent.
ADVERTISING COOKIES FROM GOOGLE
• Google uses “cookies” to display ads on the websites of its partners, such as websites displaying Google ads or participating in Google-certified ad networks. When an end user visits a Google partner website, a “cookie” may be placed on their browser.
• Third-party vendors, including Google, use “cookies” to display advertisements based on the given user’s previous visits to your or other websites.
• The use of advertising cookies allows Google and its partners to display advertisements to your users based on their visits to your and/or other sites on the Internet.
• Users can opt out of personalized ads by visiting Ads Settings
WAYS WE COLLECT AND USE YOUR PERSONAL DATA
Legal grounds for collection and processing::
• in connection with and for the performance of a contract we enter into with you (including in oral form regarding the purchase of our products);
• to fulfill our obligations that follow from a regulatory act, for example in connection with obligations provided for in the Accounting Act and the Tax and Insurance Procedural Code, etc.;
• our legitimate interest, except when your interests or your fundamental rights and freedoms take precedence over it. An example of our legitimate interest is improving security in our facilities (via video surveillance), improving the quality of service (by recording conversations with customers), fulfilling correspondence with customers and third parties in connection with their inquiries or in order to offer them our products;
• Your explicit informed consent in some cases, for example by registering on our websites, or agreeing to keep your data that you have provided to us over the phone (for example when ordering home deliveries of our products), or regarding the use of “cookies” ; Your consent may be withdrawn at any time, in which case we will cease to further process your data subject to the withdrawn consent.
Purposes for which we use your personal data:
• to deliver to you products that we offer and that you have requested or won;
• to provide you with information regarding the products we offer, including marketing messages, through the communication channels you have chosen (phone, SMS, email);
• to contact you when you have asked us a question or requested a quote for our product or inquired about an additional service, or to notify you of important changes to our terms of service or internal policies, or of breaches in data security;
• to carry out our activities in accordance with the applicable accounting, tax and other laws, professional norms and rules, including by responding to the requests of competent state authorities;
• to improve the services we provide to you, including for internal purposes such as audits, analytics and surveys to help us improve our operations (or to monitor and analyze trends and usage of our services) and to improve the design and content of our websites and so that they correspond most optimally to your preferences and the devices you use;
• in relation to legal claims, as set out in the How long we keep your personal data section and for purposes set out elsewhere in this Notice.
We will periodically update the above example list in response to the development of our business and changing legal requirements. We will notify you in the event that we would like or need to use your personal data for purposes and in a manner significantly different from what we have informed you about and, if necessary, we will seek your consent.
SHARING OF YOUR PERSONAL INFORMATION
In carrying out our activity, we may need to share your personal data with:
• our professional consultants and auditors;
• persons who, by virtue of a legal act, have the authority to request the provision of information, including personal data, such as – courts, prosecutor’s office, various regulatory bodies such as the Consumer Protection Commission, the Personal Data Protection Commission, bodies with powers on the protection of national security and public order;
• our suppliers or business partners with the help of which we provide you with our services (including companies that, by assignment, maintain our websites, hardware and software, advertising agencies, postal operators);
Also, please note that our web pages may contain links to other similar pages that are not owned and operated by us. We cannot control and are not responsible for the personal data processing practices or the content of these other pages. We strongly recommend that you familiarize yourself with the privacy policies and information of any website that collects personal data. This Policy applies only to the personal information that BOROLA collects about you through its web pages or otherwise. In all cases, we enter into written contracts with the companies we work with, requiring them to take the necessary measures to ensure the protection of your personal information. We will transfer to these our contractors only the information they need to provide us with the agreed services, without allowing them to use your information for their own purposes. We will not provide your personal data to third parties to send you unsolicited marketing messages, unless you have given the necessary consent for this. If you receive unsolicited commercial messages from the companies we work with, please let us know via the contact form on the site.
TRANSFER OF YOUR PERSONAL DATA OUTSIDE BULGARIA
We may transfer and store your personal data in other member states of the European Economic Area. On the territory of these countries, an adequate level of personal data protection is ensured, according to the standards of the Regulation.
STORAGE PERIOD OF YOUR PERSONAL DATA
We have an internal policy that determines how long we keep your personal data. It is based primarily on the type of information we collect and the purposes for which we collect it. In principle, we store your personal data for as long as necessary for the processing purposes for which the data were collected and for any other permissible and related purpose or until the expiration of a legally defined period (for example for the storage and processing of accounting data and for tax control – 6 years). It is our legitimate interest to retain certain of your personal information until the expiry of the limitation period for making claims (5 years). We will not delete or anonymize your personal data if it is necessary for pending judicial or administrative proceedings or proceedings for consideration of your complaint before us.
PROTECTION OF YOUR PERSONAL DATA
BOROLA uses physical, electronic and organizational measures, appropriate in view of the sensitivity of the information we maintain to protect the personal data you provide to us from unauthorized access, use or disclosure. For example, we encrypt communications using SSL, encrypt information at storage, have firewalls, access control tools, segregation of duties, and more. All server-client connections are made only through an encrypted connection using the https protocol. You can get more information about the SSL certificate at www.momo.bg at any time by clicking in the URL field of your web browser. We have adopted policies and procedures and appointed a Data Protection Officer. We require our suppliers and partners who have access to your personal data to use appropriate measures to ensure the protection and confidentiality of your personal data. However, you are also responsible for safeguarding your password and username with which you access our websites. Unfortunately the transmission of information over the Internet or by telephone may not be completely secure, despite the measures we take. Therefore, please note that the transmission of your personal information via the Internet or by telephone is done at your own risk.
RIGHTS RELATING TO YOUR PERSONAL DATA
In relation to your personal data, you have certain rights vis-à-vis us which are granted to you by the Regulation and other applicable legislation. Sometimes certain rights may arise and be exercised only on certain grounds for processing your personal data; your other rights are subject to certain limitations and exclusions by law. If you do not understand how we process your personal data or have any questions, please contact our Data Protection Officer whose contact details are listed at the end of this Notice in the How to Contact Us section.
You have the following rights:
• Right of access to personal data relating to you
• Right to object to the processing of your personal data
• The right to request rectification of inaccurate personal data relating to you
• The right to request the erasure of personal data relating to you (“the right to be forgotten”)
• Right to request restriction of processing of personal data relating to you
• The right to receive the personal data you have provided to us and which concerns you and to reuse it by transferring it to another controller (“right to portability”)
• The right to lodge a complaint with the competent supervisory authority or the court in case your rights have been violated or you have suffered from unlawful processing of your personal data.
Where the processing is based on your consent, you have the right to withdraw your consent to the processing of your personal data at any time without affecting the lawfulness of the processing based on your consent before it is withdrawn.
ACCESS TO YOUR PERSONAL DATA
You have the right to request:
• information on whether data concerning you is processed, information on the purposes of this processing, on the categories of data and on the recipients or categories of recipients to whom the data is disclosed.
• a message in an understandable form containing your personal data being processed, as well as any available information about its source.
If you wish, we will provide you with access to the personal data that is being processed, in the form of a copy of it. The copy will be free for you. For additional copies, we may charge you a reasonable fee to cover our administrative costs of making them. If you submitted the request by electronic means, we will, where possible, provide you with the information in a widely used electronic form, unless you have asked us otherwise.
We perform automated decision-making for our customers as a result of automated processing of their personal data. If we do not process your personal data, we will notify you. If we refuse your request for a copy of the data, we will let you know our reasons for doing so.
The exercise of your right of access should not adversely affect the rights or freedoms of others, including trade secrets or intellectual property, and in particular copyright protection of software. In case we consider that there is a reason to expect such a negative impact, we can motivatedly limit some of the information we will provide to you so that it does not occur.
RIGHT TO OBJECT TO THE USE AND STORAGE OF YOUR PERSONAL DATA
You have the right to:
• to object to the processing of your personal data if there is a legal basis for this; when the objection is justified, we will stop processing your data.
• to object to the processing of your personal data for direct marketing purposes (i.e. when we make offers to you by telephone, email and post on our own initiative).
If you have objected to the processing of your personal data based on our legitimate interest or the legitimate interest of a third party (or profiling, if we start to do so and which we will notify you of), we may continue processing despite your objection if we can prove that there are legal grounds for the processing that take precedence over your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
In the event that data relating to you is used for the purposes of direct marketing, you have the right to object free of charge and at any time to its processing for this type of marketing (which could also include profiling, insofar as it is related to direct marketing) and we will stop processing them.
If you do not wish to receive information and offers from us regarding our products, please notify us in writing at firstname.lastname@example.org or at the address indicated above, specifying your names and address/or email address. Alternatively, you can opt out of receiving unsolicited commercial communications by clicking the Unsubscribe link at the bottom of each email.
RIGHT TO CORRECT AND UPDATE YOUR PERSONAL DATA
In the event that we process incomplete or wrong/wrong data, you have the right, at any time, to request:
• to delete, correct or block your personal data, the processing of which does not meet the requirements of the law.
• to notify the third parties to whom your personal data has been disclosed of any deletion, correction or blocking, except in cases where this is impossible or involves excessive efforts.
We rely on the accuracy of your personal information that you provide to us. If this information changes, please notify us of your updated personal details on the contact form on the site.
RIGHT TO DELETE YOUR PERSONAL DATA
You may request that your personal data be deleted if:
• the data are no longer necessary for the purposes for which we collected them;
• withdraw your consent for us to process your personal data (and there is no other legal basis for us to continue processing them);
• you object to us processing your data on the basis of our legitimate interest and we fail to substantiate our more substantial legitimate reasons for the processing;
• we process your personal data in violation of the Regulation and applicable legislation;
• if we are obliged to delete your data according to Bulgarian legislation or the law of the European Union.
We may refuse to delete your data if we need it in connection with a legal claim, to comply with our legal obligations, as well as in other cases provided for in the Regulation.
LIMITING THE PROCESSING OF YOUR PERSONAL DATA
You can request restriction of the processing of your personal data if:
• you dispute the accuracy of the data for the period in which we have to verify its accuracy;
• the processing of the data is without legal basis but instead of deleting them, you want their limited processing;
• You object to us processing your data on the basis of our legitimate interest while we assert our right;
• we no longer need this data (for the specified purpose) but you need it to establish, exercise or defend your legal claims.
Where the processing of your personal data has been restricted, we may still continue processing with your express consent either to establish, exercise or defend legal claims or to protect the rights of another natural person or for important grounds of public interest for the European Union or its member state.
RIGHT TO DATA PORTABILITY
You can request from us to provide your personal data, in an organized, orderly, structured, generally accepted electronic format, only when the following two conditions are met:
• the processing of your personal data is carried out in an automated way (ie, this right does not apply to the processing of data on paper);
• the processing is carried out on the basis of your consent or a contract to which you are a party, or to take steps at your request before entering into a contract.
You should be aware that when you exercise the right to portability this does not result in your data being deleted from our systems. You will be able to continue using our services even after the data portability operation. Data portability also does not affect the initial retention period that applies to transmitted data. You can exercise your remaining rights which are set out in the legislation and which we have listed here, while we continue to process the data.
RIGHT OF APPEAL
If you believe that we are in violation of applicable law, please contact us for clarification. Of course, you also have the right to immediately file a complaint with a supervisory authority in the European Union where you live, work, or where the alleged violation of your rights took place. The supervisory authority for the protection of personal data in Bulgaria is the Commission for the Protection of Personal Data, with address 2 Tsvetan Lazarov Blvd., Sofia, p. code 1592. You can also seek protection of your rights in court.
TO EXERCISE YOUR RIGHTS YOU NEED TO KNOW:
How to claim your rights
To exercise your rights according to the Regulation, you can write to us through the contact form on the site or send us your inquiry by mail or bring it to us at the following address: Sofia-1202 Oborishte district Tsar Simeon St. No. 52.
Applications in connection with the exercise of your rights are generally submitted in person or by a person expressly authorized by you. An application can also be submitted electronically, in accordance with the Law on Electronic Documents and Electronic Signatures.
In what form will we answer you? In the form in which you sent your inquiry to us – in writing on paper or in electronic form. Where you have submitted a request by electronic means, where possible, the information will be provided to you in a widely used electronic form, unless you have requested otherwise. How soon will you receive a response? Within one month of receiving your request we will provide you with information about the actions we have taken on it. If necessary, this period can be extended by another two months taking into account the complexity and number of requests. If such an extension is necessary, we will notify you within one month of submitting your request, explaining the reasons for this extension.
Doubts about your identity. Where we have reasonable concerns regarding the identity of the natural person making the request to us, we may request the provision of additional information necessary to confirm the identity of the data subject. If we do not receive such information and are unable to identify the data subject, we may decline to act on a request made to us to exercise any of the rights set forth in this Notice.
PERSONAL INFORMATION OF CHILDREN
Protecting children’s privacy is essential. We do not collect personal data of children under the age of 14 and strictly comply with the requirements of the law. If you are under the specified age, you are only allowed access to web pages with the consent of your parents or guardians. We urge parents to regularly monitor and control their children’s Internet activity. If you are a parent and have concerns about the collection or use of personal information about your child, please contact us at the above addresses.
FOR CHANGES TO THIS POLICY
You will be notified of material changes to this document on our web page and, where possible, by other appropriate means, so that you are always informed of changes to what personal data we collect about you, how we use it and under what circumstances we share it with others persons. You may be asked to read and accept these changes before continuing to access our websites. If we would like to use your personal information for a significantly different purpose and manner than what we have told you, we will also send you a notice at the email address you have provided. So you will have a choice as to whether or not you accept the changes in the use of your personal information.