Information about the company processing your data:
- Name: “Gloub Sistem” OOD
- UIC/BULSTAT: 200582199
- Registered office and management address: Sofia, Kap. Dimitar Spisarevski Blvd., bl. 191
- Correspondence address: Sofia, Kap. Dimitar Spisarevski Blvd., bl. 191
- Telephone: +35929463202
- E-mail: info@vodi4ka.com
- Website: https://vodi4ka.com
Information about the competent supervisory authority for personal data protection:
- Name: Commission for Personal Data Protection
- Registered office and management address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
- Correspondence address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
- Telephone: +359 2 91 53 518
- Website: www.cpdp.bg
“Gloub Sistem” OOD (hereinafter referred to for short as the “Controller” or the “Company”) carries out its activities in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. This information is intended to inform you about all aspects of the processing of your personal data by the Company and about the rights you have in relation to such processing.
Grounds for collecting, processing and storing your personal data
Article 1. (1) The Controller collects and processes your personal data in connection with the use of the online store https://vodi4ka.com and the conclusion of contracts with the Company on the basis of Article 6(1) of Regulation (EU) 2016/679 (GDPR), and more specifically on the following grounds:
- your explicit consent as a customer;
- performance of the Controller’s obligations under a contract with you;
- compliance with a legal obligation applicable to the Controller;
- for the purposes of the legitimate interests pursued by the Controller or by a third party.
Purposes and principles in the collection, processing and storage of your personal data
Article 2. (1) We collect and process the personal data that you provide to us in connection with the use of the online store https://vodi4ka.com and the conclusion of a contract with the Company, including for the following purposes:
- creating an account and providing full functionality when using the online store;
- identifying a party to the contract;
- accounting purposes;
- statistical purposes;
- protection of information security;
- ensuring the performance of the contract for provision of the relevant service;
- sending newsletters and emails with special offers where you have expressed a wish to receive them;
- sending replies to inquiries submitted through the contact form on our website;
- processing and delivery of placed orders, including orders made without registration through the “Order as guest” option;
- processing requests related to complaints, withdrawal from a contract, returns and exchanges of goods.
(2) We observe the following principles when processing your personal data:
- lawfulness, fairness and transparency;
- purpose limitation;
- data relevance to the purposes of processing and minimisation of the data collected;
- accuracy and up-to-date status of data;
- storage limitation in view of achieving the purposes;
- integrity and confidentiality of processing and ensuring an appropriate level of personal data security.
(3) When processing and storing personal data, the Controller may process and store personal data for the purpose of protecting the following legitimate interests:
- fulfilment of its obligations to the National Revenue Agency, the Commission for Consumer Protection, the Commission for Personal Data Protection and other state and municipal authorities;
- protection in judicial, administrative and out-of-court disputes;
- prevention of abuse, fraud and attacks against the Company’s information systems.
What types of personal data our Company collects, processes and stores
Article 3. (1) The Company carries out the following operations with the personal data provided by you as customers, for the following purposes:
1. Registration of a customer in the online store and performance of a distance purchase and sale contract - the purpose of this operation is to create an account for using the online store to purchase goods and to provide contact details for delivering purchased goods. Registration and creation of an account for using the online store is not a mandatory step for provision of the service and the service is also available without creating an account through the “Order as guest” option.
2. Sending a newsletter - the purpose of this operation is to administer the process of sending newsletters, emails with special offers, promotions, promo codes, news and new functionalities to customers who have stated that they wish to receive them.
3. Exercising the right of withdrawal or submitting a complaint - the purpose of this operation is to administer the process of exercising the right of withdrawal or complaint by the customer in relation to the goods for which these rights may be exercised.
4. Submitting inquiries through the website contact form - the purpose of this operation is to send a response to an inquiry made by the user.
(2) The Controller does not collect or process personal data that:
- reveals racial or ethnic origin;
- reveals political, religious or philosophical beliefs, or membership of trade unions;
- constitutes genetic and biometric data, data concerning health, or data concerning sex life or sexual orientation.
(3) The personal data have been collected by the Controller from the persons to whom they relate.
(4) The Controller does not carry out automated decision-making with data.
(5) The Company does not collect data about persons under 16 years of age except with the consent of their parent or legal representative where such consent is required.
Article 4. (1) The Controller processes the following categories of personal data and information for the following purposes and on the following grounds:
Your identifying data (email address, first name, surname, telephone, etc.)
Purpose for which the data are collected:
- 1. contacting the user and sending information to them;
- 2. for the purposes of registering a user in the online store;
- 3. sending a newsletter, emails with special offers, promotions, promo codes, news and new functionalities;
- 4. sending a response to an inquiry through our website form.
Grounds for processing your personal data:
By accepting the general terms and conditions and registering in the online store, placing an order without registration, or concluding a written contract, a contractual relationship is created between the Controller and you, on the basis of which we process your personal data - Article 6(1)(b) GDPR. Your data for sending newsletters and emails, as well as for sending a response to an inquiry through our website form, are processed on the basis of your explicit consent - Article 6(1)(a) GDPR.
Delivery data (names, telephone, address, settlement, floor, entrance, access instructions, etc.)
Purpose for which the data are collected:
- 1. performance of the Controller’s obligations under a purchase and sale contract and delivery of the purchased goods;
- 2. contacting you in connection with the delivery.
Grounds for processing your personal data:
By accepting the general terms and conditions and registering in the online store, placing an order without registration, or concluding a written contract, a contractual relationship is created between the Controller and you, on the basis of which we process your personal data - Article 6(1)(b) GDPR.
Data related to placed orders and payments
Purpose for which the data are collected:
- 1. processing the order;
- 2. performing the delivery;
- 3. issuing accounting documents;
- 4. protecting the legal interests of the Company in disputes.
Grounds for processing your personal data:
Processing is necessary for the performance of a contract to which you are a party - Article 6(1)(b) GDPR, as well as for compliance with legal obligations of the Controller - Article 6(1)(c) GDPR.
Technical data (IP address, device data, logs, cookies, website behaviour)
Purpose for which the data are collected:
- 1. ensuring the normal functioning and security of the website;
- 2. statistical and analytical purposes;
- 3. improving the user experience.
Grounds for processing your personal data:
Legitimate interest of the Controller - Article 6(1)(f) GDPR, and where applicable - your consent.
Retention period of your personal data
Article 5. (1) The Controller stores your personal data for a period no longer than the existence of your account in the online store or until completion of an order made “as guest”. After deletion of your account or completion of the order, the Controller takes due care to erase and destroy all your data without undue delay or to anonymise them, except where their retention for a longer period is required under applicable legislation or on the grounds set out below.
(2) The Controller stores your personal data provided in connection with online orders placed for a period of up to 5 years for the purposes of protecting the Controller’s legal interests in judicial or administrative disputes with users of the online store, while accounting documents are stored for the relevant statutory period.
(3) The Controller will notify you if it is necessary to extend the data retention period in view of complying with a statutory obligation or in view of the Controller’s legitimate interests.
(4) The Controller stores personal data that it is required to keep under applicable legislation for the relevant prescribed period, which may exceed the duration of existence of your account in the online store or the completion of the order.
Transfer of your personal data for processing
Article 6. (1) The Controller may, at its discretion, transfer part or all of your personal data to personal data processors for the fulfilment of the processing purposes, in compliance with the requirements of Regulation (EU) 2016/679 (GDPR).
(2) The Controller will notify you in the event of an intention to transfer part or all of your personal data to third countries or international organisations, where applicable.
Your rights in relation to the collection, processing and storage of your personal data
Withdrawal of consent to the processing of your personal data
Article 7. (1) If you do not wish all or part of your personal data to continue to be processed by the Company for a specific purpose or for all processing purposes, you may withdraw your consent to processing at any time by submitting a free-text request to the Controller.
(2) The Controller may request that you verify your identity and your identity as the person to whom the data relate.
(3) If you have placed an order that is being processed, the earliest time at which you may withdraw your consent to processing is after successful completion of the order, where the processing is based on consent.
(4) You may withdraw your consent to the processing of your personal data for direct marketing purposes at any time.
(5) Withdrawal of consent does not affect the lawfulness of personal data processing carried out by the Controller up to that time.
Right of access
Article 8. (1) You have the right to request and obtain from the Controller confirmation as to whether personal data relating to you are being processed.
(2) You have the right to obtain access to the data relating to you, as well as to the information relating to the collection, processing and storage of your personal data.
(3) Upon request, the Controller provides you with a copy of the personal data undergoing processing and relating to you, in electronic or another appropriate form.
(4) Access to the data is provided free of charge, but the Controller reserves the right to impose an administrative fee in the event of repetitive or excessive requests.
Right to rectification or completion
Article 9. You may rectify or complete inaccurate or incomplete personal data relating to you directly through your account on the website, where such functionality is available, or by submitting a request to the Controller.
Right to erasure (“right to be forgotten”)
Article 10. (1) You have the right to request from the Controller the erasure of part or all personal data relating to you, and the Controller is obliged to erase them without undue delay where one of the following grounds applies:
- the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- you withdraw the consent on which the processing is based and there is no other legal ground for the processing;
- you object to the processing of personal data relating to you, including for direct marketing purposes, and there are no overriding legitimate grounds for the processing;
- the personal data have been unlawfully processed;
- the personal data must be erased for compliance with a legal obligation under EU law or the law of a Member State applicable to the Controller;
- the personal data have been collected in relation to the offering of information society services.
(2) The Controller is not obliged to erase the personal data if it stores and processes them:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation requiring processing;
- for reasons of public interest;
- for the establishment, exercise or defence of legal claims.
(3) If you have placed an order that is being processed, the earliest time at which you may request to be “forgotten” is after successful completion of the order, unless the law requires otherwise.
(4) The Controller does not erase data that it has a legal obligation to store, including for defence against legal claims brought against it or for proving its rights.
Right to restriction
Article 11. (1) You have the right to request that the Controller restrict the processing of data relating to you where:
- you contest the accuracy of the personal data for a period enabling the Controller to verify the accuracy of the personal data;
- the processing is unlawful, but you do not wish the personal data to be erased and request instead that their use be restricted;
- the Controller no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or defence of legal claims;
- you have objected to processing pending verification whether the legitimate grounds of the Controller override your interests.
Right to data portability
Article 12. (1) If you have given consent to the processing of your personal data, or the processing is necessary for the performance of the contract with the Controller, or if your data are processed by automated means, you may, after identifying yourself to the Controller:
- request that the Controller provide your personal data to you in a readable format and transfer them to another Controller;
- request that the Controller directly transfer your personal data to a controller designated by you, where technically feasible.
Right to receive information
Article 13. You may request that the Controller inform you about all recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested have been disclosed, unless this proves impossible or involves disproportionate effort.
Right to object
Article 14. You may object at any time to the processing of personal data by the Controller that relate to you, including where they are processed for direct marketing purposes.
Your rights in the event of a personal data security breach
Article 15. (1) If the Controller establishes a breach of the security of your personal data that is likely to result in a high risk to your rights and freedoms, it will notify you of the breach without undue delay, as well as of the measures that have been taken or are to be taken.
(2) The Controller is not obliged to notify you if:
- it has implemented appropriate technical and organisational protection measures in relation to the data affected by the security breach;
- it has subsequently taken measures which ensure that the breach is no longer likely to result in a high risk to your rights;
- notification would involve disproportionate effort.
Persons to whom your personal data are provided
Article 16. For the purposes of processing your personal data and providing the service in its full functionality, and in view of your interests, the Controller may provide your data to the following personal data processors:
- Supplier / courier — Delivery to an address
- Hosting / IT provider — Maintenance of the website, systems and security
- Accounting service — Accounting and tax services
- Legal service — Legal services and protection of legitimate interests
The listed personal data processors comply with all requirements for lawfulness and security in the processing and storage of your personal data.
Cookies and similar technologies
Article 16a. (1) The website https://vodi4ka.com uses cookies and similar technologies for storing information in your browser (browser local storage, pixels, tracking scripts), which serve to ensure the normal functioning of the website, to remember the choices you have made, to measure traffic and - where you have given your consent - for marketing purposes.
(2) Cookies are small text files that are stored on your device when you visit the website and allow it to recognise your browser on a subsequent page load or on a subsequent visit. Similar technologies perform analogous functions through other browser storage mechanisms.
(3) The Controller divides the cookies used into the following categories: strictly necessary, functional, analytics and marketing. Strictly necessary cookies are always set, because without them the service cannot be provided. Analytics and marketing tools, as well as all third-party cookies, are loaded only after your explicit consent given through the cookie banner. Until consent is obtained, the Controller maintains a denied consent state (Google Consent Mode) for analytics, advertising and functionality storage.
(4) Strictly necessary and functional cookies set by the Controller (first party). They are set from the website’s own domain, are not disclosed to third parties, and are stored for the duration of your browser session unless you delete them earlier yourself:
| Name | Purpose | Duration | Category |
|---|
| cookie-consent | Stores your choice regarding cookies (accepted or rejected), so that the banner is not shown to you again and so that tools for which you have not given consent are not loaded. | for the duration of the browser session | strictly necessary |
|---|
| auth | Stores the access token issued upon login, by means of which your session as a registered user is maintained. | for the duration of the browser session | strictly necessary |
|---|
| cart | Stores the contents of your shopping cart so that they are not lost while you navigate between the pages of the website. | for the duration of the browser session | strictly necessary |
|---|
| order-v1 | Stores the data you have entered in the order form (address and delivery details, contact details, selected payment method) so that you do not have to enter them again. | for the duration of the browser session | functional |
|---|
| expressOrderContact | Stores the contact details entered in the express order form. | for the duration of the browser session | functional |
|---|
| favourites | Stores your list of favourite products. | for the duration of the browser session | functional |
|---|
(5) Analytics cookies. They are loaded only after your consent, through the Google Tag Manager container, and serve to compile aggregated statistics on the use of the website:
| Name | Purpose | Duration | Category |
|---|
| _ga | The main Google Analytics identifier, by means of which individual users are distinguished. | typically 2 years | analytics |
|---|
| _ga_<data stream identifier> | Maintains the session state in Google Analytics 4. | typically 2 years | analytics |
|---|
| _gid | Distinguishes users for the purposes of short-term statistics. | typically 24 hours | analytics |
|---|
| other Google Tag Manager and Google Analytics cookies | Their specific names, number and durations are determined by Google and may be changed by the provider without the Controller’s involvement. | determined by Google | analytics |
|---|
(6) Marketing cookies. They are loaded only after your consent and only in so far as the relevant advertising tools are enabled in the Google Tag Manager container:
| Name | Purpose | Duration | Category |
|---|
| _fbp | A Meta (Facebook) Pixel cookie used to measure conversions from advertisements and to build advertising audiences. | typically 90 days | marketing |
|---|
| _fbc | Records the identifier of the advertisement through which you reached the website. Set only where you arrived from a Meta advertisement. | typically 90 days | marketing |
|---|
| Google Ads and remarketing cookies (Google domains, including google.com and doubleclick.net) | Conversion measurement and the display of personalised advertisements. | determined by Google | marketing |
|---|
(7) Third-party functional cookies. Where consent is given, the LiveChat chat application is loaded on the website, which uses cookies and browser local storage in order to maintain the conversation you have started, to recognise returning visitors and to preserve the state of the chat window. The names and durations of these cookies are determined by the service provider.
(8) The exact names, number and durations of third-party cookies are determined unilaterally by the respective provider and may be changed by it without notice. The durations indicated above are those that are customary as at the date of publication of this policy and are indicative. Up-to-date and detailed information can be found in the privacy and cookie policies published by the respective provider.
Third parties processing data through cookies
Article 16b. (1) Where you have given your consent, the following providers may receive data through the cookies and scripts placed on the website:
- Google Ireland Limited, respectively Google LLC — tag management (Google Tag Manager), web analytics (Google Analytics 4) and advertising services (Google Ads, remarketing);
- Meta Platforms Ireland Limited, respectively Meta Platforms, Inc. — conversion measurement and the building of advertising audiences through the Meta (Facebook) Pixel;
- Text, Inc. (LiveChat) — provision of the online customer chat application.
(2) Through the technologies referred to above, these providers process at least your IP address, device and browser identifiers, and information about your behaviour on the website. In respect of part of that processing, the relevant provider acts as an independent controller of personal data and determines the purposes and means of the processing on its own.
(3) Detailed information about the data processed, the retention periods and your rights vis-à-vis these providers is available in the privacy and cookie policies published on the official websites of Google, Meta and LiveChat. We recommend that you review them before giving your consent.
Legal basis for the use of cookies
Article 16c. (1) The Controller processes the data collected through cookies and similar technologies on the following grounds under Article 6(1) of Regulation (EU) 2016/679 (GDPR):
- strictly necessary cookies — the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract - Article 6(1)(b) GDPR, as well as for the purposes of the Controller’s legitimate interest in ensuring the functioning and security of the website - Article 6(1)(f) GDPR; under the applicable electronic communications legislation, consent is not required for these cookies, since without them the service explicitly requested by you cannot be provided;
- functional cookies that are not strictly necessary — your consent - Article 6(1)(a) GDPR;
- analytics cookies — your consent - Article 6(1)(a) GDPR;
- marketing cookies — your consent - Article 6(1)(a) GDPR.
(2) Consent is given freely and a refusal to give it does not restrict your access to the website, to the online store or to the possibility of placing an order.
(3) Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
Transfers to third countries in connection with cookies
Article 16d. (1) Where you have given your consent, the data collected through cookies and similar technologies may be transferred to companies within the groups of the respective providers established outside the European Economic Area, including in the United States of America.
(2) Such transfers are carried out where an adequate level of protection is ensured, namely on the basis of the European Commission’s adequacy decision under the EU-US Data Privacy Framework, where the relevant recipient is certified under it, and/or on the basis of the standard contractual clauses adopted by the European Commission, accompanied where necessary by supplementary technical and organisational measures.
(3) The “Privacy Shield” mechanism has been declared invalid and is not used as a ground for transferring data.
(4) You may request information about the safeguards applicable to transfers to third countries using the Controller’s contact details set out at the beginning of this policy.
Managing, changing and withdrawing your cookie consent
Article 16e. (1) On your first visit to the website you are shown a banner through which you can accept or reject the use of cookies that are not strictly necessary. Until a choice is expressed, such cookies are not set.
(2) You may change or withdraw your choice at any time from the cookie settings section at the bottom of this page, which is also accessible through the link to the cookie settings section. The change takes effect immediately, and after withdrawal of consent the analytics, marketing and optional functional tools are no longer loaded.
(3) You may also manage cookies through your browser settings - by deleting them, blocking their placement, or receiving a notification each time one is set. Please note that blocking strictly necessary cookies may make it impossible for you to use part of the website’s functionalities, including your account and the shopping cart.
(4) Cookies that have already been placed on your device before the withdrawal of consent are not automatically erased by your browser; you may delete them through your browser settings or through the tools provided by the respective provider.
(5) Your rights as a data subject - including the right of access, rectification, erasure, restriction of processing, portability, objection and withdrawal of consent - are described in detail in the sections above (Articles 7 to 15) and apply in full also in respect of the data collected through cookies and similar technologies.
Other provisions
Article 17. The Controller does not transfer your data to third countries except in the cases expressly set out in this policy, including under Article 16d, and where the relevant legal ground exists.
Article 18. In the event of a violation of your rights under the above or under the applicable personal data protection legislation, you have the right to lodge a complaint with the Commission for Personal Data Protection, as follows:
- Name: Commission for Personal Data Protection
- Registered office and management address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
- Correspondence address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
- Telephone: +359 2 91 53 518
- Website: www.cpdp.bg
Article 19. You may exercise all your rights regarding the protection of your personal data by submitting a request to the Controller by email, by post, or through the available functionalities in your account where such functionalities are provided.
Article 20. The Company may amend the Privacy Policy by publishing an updated version on its website.