This Personal Data Protection Policy governs the processing of your personal data by SORIKO Ltd., UIC: 119630779, in connection with your visit to our website www.soriko.bg (hereinafter “Website”), your communication with us by email, telephone and social media channels (such as Facebook, Instagram and Google+).
If you would like information on how we process personal data through cookies and social media plug-ins, please see our Privacy Policy
1. GENERAL PROVISIONS
- Your personal data is processed by Soriko Ltd., UIC: 119630779 (hereinafter “we”, “us”, “our”). You can contact us by email at office@soriko.bg.
- Any reference in this Personal Data Protection Policy to particular laws or regulations also includes any amendment, replacement or repeal thereof.
We reserve the right to amend this Personal Data Protection Policy periodically at our discretion. Any such amendment will be announced on the Website. If you do not accept the amendments, you must inform us by sending an email to office@soriko.bg. If we do not receive such an email from you within three (3) working days of the amendments to the Personal Data Protection Policy being announced on the Website, you will be deemed to have accepted all amendments.
2. TYPES OF PERSONAL DATA WE PROCESS
2.1. Whenever you visit or use our Website and social media channels, we collect:
– Technical information relating to the device you use, such as your Internet Protocol (IP) address, browser type, geographical location and operating system;
– Information about your browsing behaviour, such as the duration of your visit, which links you click on, which pages you visit and how many times you visit a given page of the Website.
2.2. When you fill in a contact form, fill in a purchase request or create a user account on our Website, or contact us by email, telephone or social media channels, we collect:
– The basic personal information you provide to us (name, email address, postal address, telephone number);
– The content of your communication or enquiry and the technical data about the communication itself (who you are corresponding with, date, time, etc.);
– Your preferences regarding the means of communication used;
– The publicly available information on your profile in social media channels;
– Any other personal data you choose to provide to us.
2.3. We receive all of the personal data listed directly from you. We may receive additional information about your preferences and your browsing habits from partners such as Google and Meta. If you need more information about the personal data these parties process about you and provide to others, we kindly ask you to consult their personal data protection policies.
3. THE PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
3.1. We process your personal data in order to deliver to you, in a personalised and efficient manner, the information, products and services you request through the Website, by email, telephone or social media channels.
3.2. We process your personal data in order to comply with legal obligations or to fulfil any legitimate request from competent law enforcement authorities or representatives, judicial authorities, government departments or bodies, including the competent personal data protection authorities.
Your personal data may be passed on, on our own initiative, to the police or the judicial authorities as evidence, or where there are reasonable suspicions of an unlawful act or offence committed by you through your use of or registration on the Website, our social media channels or other communication with us.
3.3. We process your personal data in order to carry out statistical analyses so that we can improve our Website, advertising, products and services, or develop new products and services.
3.4. We also process your personal data to protect our legitimate interests or those of our partners or third parties, where your use of your registration on the Website, the social media channels or other communication channels may be considered (a) a breach of the applicable terms of use of the Website or of intellectual property rights or any other right of a third party, (b) a danger or threat to the security or integrity of our Website, the social media channels or other communication channels, or our underlying IT systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (c) in any way malicious, obscene, discriminatory, racist, defamatory, spiteful, harmful or in any other way wrongful or unlawful.
4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
4.1. Where your personal data is processed for the purpose set out in Article 3.1 or in order to take steps prior to entering into a contract with us, we base the processing of your personal data on the necessity of performing that contract or of the process of entering into that contract.
4.2. For the purpose set out in Article 3.2, the processing of your personal data is necessary for compliance with a legal obligation to which we are subject.
4.3. For the purposes set out above in Articles 3.1, 3.3 and 3.4, the processing of your personal data is necessary for the purposes of our legitimate interests, such as:
– Continuous improvement of our Website, social media channels, products and services, in order to provide you with the best possible experience;
– Protecting our Website, social media channels, products and services from abuse and unlawful actions;
– Marketing and promoting our products, services and brand, and the overall commercial success of our products and services.
5. WHO WE SEND YOUR DATA TO
5.1. We rely on third-party processors who process the data you provide on our Website and process your personal data on our behalf in connection with the maintenance and improvement of our Website. These third-party processors are only permitted to process your data on our behalf and on our express written instructions.
We guarantee that all third-party processors are carefully selected and are obliged to observe the safety and integrity of your personal data.
5.2. We do not send your personal data, without your express consent, to any other third party in a manner that allows it to be identified, other than those referred to in Article 5.1.
6. LOCATION AND TRANSFER
6.1. We process your personal data within the European Economic Area (EEA). However, in order to process your personal data for the purposes set out above in Article 3, we may also transfer your personal data to third parties who process data on our behalf outside the EEA. Any organisation outside the EEA that processes your personal data will be required to comply with appropriate security measures regarding the processing of your personal data. These security measures will result from:
– The receiving country having legislation in force that may be considered equivalent to the data protection offered within the EEA; or
– A contractual arrangement between us and that organisation.
6.2. We may transfer anonymous and/or aggregated data to organisations outside the EEA. In the event of such a transfer, we will ensure that security measures are in place to guarantee the safety and integrity of your data and of all rights relating to your personal data that you have under applicable mandatory legislation.
7. QUALITY ASSURANCES
7.1. We make every effort to process only the personal data that is necessary to achieve the purposes set out above in Article 3.
7.2. Your personal data is processed only to the extent necessary to achieve the purposes set out above in Article 3, or until you withdraw your consent to its processing. Withdrawing your consent may mean that you can no longer use our Website in whole or in part. We will erase your personal data when it is no longer necessary for the purposes set out above in Article 3, unless there is:
– An overriding interest on our part in keeping the personal data available in identifiable form;
– A legal or regulatory obligation, or a judicial or administrative order, that prevents us from erasing it.
7.3. You understand that, in essence, our marketing efforts are aimed at making our marketing materials more relevant to you. This means that we may build a profile of you on the basis of the relevant characteristics described in Article 2 of this Personal Data Protection Policy and then use that profile to provide you with messages, promotions, offers, newsletters and other advertising for products and services that may interest you.
7.4. We will take appropriate technical and organisational measures to protect your personal data against unauthorised access or theft, as well as against accidental loss, tampering or destruction. Access by our staff or by our third-party processors will be granted only on a “need to know” basis and will be subject to confidentiality obligations. You are aware, however, that safety and security are a matter of best efforts and can never be guaranteed.
7.5. If you have registered to receive messages, promotions, offers, newsletters and other advertising by email or other personal electronic communication channels, you can change your preferences for receiving such messages, promotions, offers, newsletters and other advertising by following the opt-out link provided in those messages.
8. YOUR RIGHTS
8.1. You have the right to request access to all personal data relating to you that we process. We reserve the right to charge an administrative fee for multiple subsequent access requests submitted with the clear purpose of causing us inconvenience or harm. Each request must specify for which processing activity you wish to exercise your right of access and to which categories of data you wish to have access.
8.2. You have the right to request that any personal data relating to you that is inaccurate be corrected free of charge. If you submit a request for correction, your request must be accompanied by proof of the inaccuracy of the data you want corrected.
8.3. You have the right to withdraw any consent you have previously given to the processing of your personal data.
8.4. You have the right to request that personal data relating to you be erased if that data is no longer required in the context of the purposes set out above in Article 3, or if you withdraw your consent to the processing of the data. However, we will assess the request for erasure against:
– Our overriding interests;
– Legal or regulatory obligations, or administrative or judicial orders, that may conflict with such erasure.
Instead of erasure, you may also request that we restrict the processing of your personal data if (a) you contest the accuracy of the data, (b) the processing is unlawful, or (c) the data is no longer necessary for the purposes set out above in Article 3.
8.5. You have the right to object to the processing of personal data unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. If the intended processing qualifies as direct marketing, you have the right to object to such processing free of charge and without giving reasons.
8.6. You have the right to receive from us, in a structured, commonly used and machine-readable format, all personal data you have provided to us.
8.7. If you wish to submit a request to exercise one or more of the rights listed above, you can send an email to office@soriko.bg. An email requesting the exercise of a right will not be construed as consent to the processing of your personal data beyond what is required to process your request. The request must clearly state which right you wish to exercise and the reasons for doing so, where this is required. It must also be dated and signed, with your full name written in your own hand, and we may ask you for proof of identity. You may also use the contact form on the Website, in which case we may ask you for a signed confirmation and proof of identity.
We will notify you promptly of the receipt of this request. If the request proves to be valid, we will deal with it as soon as possible and at the latest within thirty (30) days of receiving the request.
If you have a complaint about our processing of your personal data, please do not hesitate to contact us by email at office@soriko.bg. If you are not satisfied with our response, you have the right to lodge a complaint with the competent personal data protection authority.