In its capacity as a personal data administrator, "PHOTOENERGY - ML" EOOD (CHILL) 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 in relation to the processing of personal data and regarding the free movement of such data by collecting data only necessary for the provision of the offered services, and keeps them responsible and lawful.
1. General information
1. Information about the Personal Data Administrator
"PHOTOENERGY - ML EOOD"is a commercial company registered under the Commercial Law of Republic of Bulgaria with EIC: 200689889
Headquarters and address of management: Strumyani village, Vrabche village, 2
Address for exercising the activity: Strumyan village, Vrabche village, 2
- E-mail: hello@chill.bg
- Contact phone: +359883323677
- Website: https://chill.bg/
2. Information about the competent supervisory authority
- Personal Data Protection Commission
- Headquarters and management address: Sofia 1592, "Prof. Tsvetan Lazarov" Blvd. No. 2
- Correspondence details: Sofia 1592, "Prof Tsvetan Lazarov" Blvd. No. 2
- Phone: 02 915 3 518
- E-mail: kzld@government.bg, kzld@cpdp.bg
- Website: www.cpdp.bg
2. Basis for collection, processing and storage of personal data
1. "PHOTOENERGY - ML" EOOD collects and processes your personal data in connection with:
- - the use of the website: https://chill.bg/
- - the registration of a user profile on the blog
- - download, install and use CHILL mobile applications
- - the goods and services offered and their delivery
- - concluding contracts with CHILL
- - administration of the CHILL fan page on Facebook - Chill Dog Friendly and c Instagram - chill.dogfriendly
- - Admin account on Google Play and Apple App Store
2. Personal data are processed on the basis of Art. 6, para. 1, Regulation (EU) 2016/679, i specifically:
- - express consent obtained from the client and user
- - performance of the obligations of"PHOTOENERGY - ML" EOOD under the contract
- - fulfillment of the legal obligations of "PHOTOENERGY - ML" EOOD
- - for the purposes of the legitimate interest of "PHOTOENERGY - ML" EOOD
3. Purposes for the collection, processing and storage of personal data CHILL collects and processes the personal data that you provide in connection with the services used by it to conclude the contracts, including for the following purposes:
- 1. Create a user profile on the site and blog
- 2. Ensuring the full functionalities of the offered services and products
- 3. Individualization of a party to the contract
- 4. Accounting purposes
- 5. Statistical purposes
- 6. Protection of information security
- 7. Ensuring the performance of a contract for the provision of a relevant service or product
- 8. Sending informational messages, notifications of service changes, recommendations to improve the use of the site, blog, mobile applications, etc.
- 9. Improving and individualizing the services by offering suitable offers for products and services that may be of interest to users and customers
- 10. Provision of Technical Support
- 11. Management of blog and mobile applications
- 12. Administration of the CHILL fan page on Facebook and Instagram
4. "PHOTOENERGY - ML" EOOD observes the following principles when processing personal data:
- 1. Lawfulness, good faith and transparency
- 2. Limitation of processing purposes
- 3. Relevance to the purposes of the processing and minimization of the data collected
- 4. Accuracy and Timeliness of Data
- 5. Limitation of storage in order to achieve the objectives
- 6. Integrity and confidentiality of processing and ensuring an appropriate level of security of personal data
- 7.When processing and storing personal data, "PHOTOENERGY - ML" EOOD OOD may processes and stores personal data in order to protect the following legitimate interests - fulfillment of obligations to the National Revenue Agency, National insurance institute, Ministry of Internal Affairs, judicial authorities, control bodies, local self-government bodies and other state and municipal bodies.
5. "PHOTOENERGY - ML" EOOD carries out the following operations with personal data for the following purposes:
- 1. User registration on Site/Blog
- 2. Conclusion and execution of a commercial transaction
- 3. Sending Informational Messages
- 4. Sending an information bulletin (newsletter)
- 5. Mobile Application Management
- 6. Processing of anonymous statistical information
The purpose of this operation is to create a profile on the site/blog that enables the user to leave comments under the articles and use the functions of the site.
The purpose of this operation is to conclude and execute a contract with a user, trading partner or client and its administration.
The purpose of this activity is to administer the process of sending messages to customers, users and counterparties that relate to improvements or changes to the services.
The purpose of this operation is to administer the process of sending newsletters to customers and users who have indicated that they wish to receive.
The purpose of this operation is for the user who downloaded and installed the application to benefit from the full functionality of the mobile application of his choice.
The aim of this operation is "PHOTOENERGY - ML" EOOD to improve its activity, through the anonymous statistical information provided to it by Facebook and Instagram in connection with visits to her fan pages, both from Google Play and the Apple Store via her admin profile.
6. "PHOTOENERGY - ML" EOOD processes and stores the following categories of personal data and information about the following purposes and on the following grounds:
- 1. Individualizing data: username, e-mail
Purpose for which collect the data: Registration of a user profile on the Blog/Site and the Mobile Application
Making contact with the user and sending information to him, including expressed express desire - to send a newsletter and advertising messages.Ground for preparation of personal data: With the acceptance of the general conditions, the registration in the Blog/Site and The mobile application between "PHOTOENERGY - ML" EOOD and the User is contractually created relation which constitutes grounds for processing personal data - art. 6, para. 1, b "b" from Regulation (EU) 2016/679.
- 2. Additional data provided at the request of the user. If the user wishes to complete his profile, he can also fill in additional data.
- 3. . Data that "PHOTOENERGY - ML" EOOD processes when visiting the site
When visiting the website www.https://chill.bg/, "PHOTOENERGY - ML" EOOD collects data about
the IP address used; for the type of device used during the visit – desktop or
mobile; the type of operating system used by the user; for the time of
the user session; for language used, for location - country and city.
Purpose for which the data is collected: Improving the security of the service and localization of the interface, statistical and marketing research.
Grounds for data processing: Processing is necessary for the performance of a contract, to which the data subject is a party - art. 6, para. 1, b. "b" of Regulation (EU) 2016/679. Until the creation of a user profile, the IP address is collected on the basis of implementation of the legitimate interests of the administrator - art. 6, para. 1, b. "e" of Regulation (EU) 2016/679.
- 4. Data that "PHOTOENERGY - ML" EOOD processes when using a mobile
application
When using a mobile application, CHILL collects data about the type of mobile
device; for the type and version of the operating system; country and city information,
which are filled in during registration in the phone's operating system; IP address of
the mobile device.
Purpose for which the data is collected: Improving services, reporting bugs and errors, collection of statistical data, marketing research, maintenance of certain functionalities, facilitating software updates and improvements, analysis of the use of the application.
Grounds for data processing: Processing is necessary for the performance of a contract, to which the data subject is a party - art. 6, para. 1, b. "b" of Regulation (EU) 2016/679.
- 5.Authorization to access from a mobile application
A CHILL mobile application may ask you to allow access to the application
to your phone or its sensors, such as camera, Wi-Fi, geo-location, Bluetooth, calendar or
to other information, such as photos, albums, etc., located on your mobile device.
"PHOTOENERGY - ML" EOOD does not have access to this data. The access may be refused
be done through the operating system settings of your mobile device.
Purpose for which the data is collected: ensuring the correct functioning of the mobile application and the services provided through it, maintaining certain functionalities.
Grounds for data processing: Processing is necessary for the performance of a contract, to which the data subject is a party and is carried out only after giving his consent.
- 6. Processing of anonymous statistical data prepared and provided by Facebook and
Instagram, in connection with a visit by users to the CHILL fan page
"PHOTOENERGY - ML" EOOD receives statistical data prepared by Facebook and Instagram
based on visits to the fan page by a user, regardless of whether the same has
profile in the relevant social network, in the form of demographic information percentage
data on target audience, on age and gender trends, on
target audience interests, information about purchases and online behavior
shopping of visitors to its page, the categories of products or services from which
visitors are most interested. Audience statistics compiled by
Facebook and Instagram are provided to "PHOTOENERGY - ML" EOOD in an anonymous form.
Purpose for which the data is collected: management of the advertising of the activity carried out, offering more relevant content to users, developing functional possibilities, management and improvement of fan pages, organization of promotional campaigns.
Grounds for data processing: Implementation of the legitimate interests of the administrator - art. 6, para. 1, b. "e" of Regulation (EU) 2016/679.
- 7. Processing of statistical data prepared and provided by Google Play and Apple
Store
"PHOTOENERGY - ML" EOOD receives statistics prepared by Google Play and Apple Store
data in the form of percentage demographic information about target
audience, on age and gender trends, on mobile used
devices and operating system versions, information about purchases, behavior
when purchasing a mobile application and subsequently uninstalling it. The statistical ones
data prepared by Google Play and Apple Store are provided to "PHOTOENERGY - ML" EOOD
Ltd
in anonymous form.
Purpose for which the data is collected: developing and improving functional capabilities, management and improvement of the offered services, elimination of bugs and errors.
Grounds for data processing: Implementation of the legitimate interests of the administrator - art. 6, para. 1, b. "e" of Regulation (EU) 2016/679.
- 8. "PHOTOENERGY - ML" EOOD does not collect or process personal data that:
- reveal racial or ethnic origin
- reveal political, religious or philosophical beliefs, or membership in trade union organizations
- genetic and biometric data, health data or data about sex life or sexual orientation.
- 9. Personal data of persons under the age of 16
- 10. The personal data were collected by "PHOTOENERGY - ML" EOOD from the persons for whom relate
- 11. "PHOTOENERGY - ML" EOOD does not perform automated decision-making with data.
Purpose for which the data is collected: Supplementing information about the user in his user profile profile.
Grounds for data processing: With the acceptance of the general conditions and registration of user profile, created contractually between "PHOTOENERGY - ML" EOOD and the User a relationship that constitutes grounds for processing personal data - art. 6, para. 1, b "b" of Regulation (EU) 2016/679.
"PHOTOENERGY - ML" EOOD does not provide goods and services to persons under 16 years of age. If the data subject is a person under the age of 16, the processing is lawful only if consent is given by the custodial parent or guardian. If a parent or guardian learns or suspects that a child under the age of 16 has provided personal data of "PHOTOENERGY - ML" EOOD, it should be contacted by email hello@chill.bg
In the event that a person under the age of 16 is found to have provided personal data, it will be deleted immediately.
7. Period of storage of personal data
- 1. "PHOTOENERGY - ML" EOOD stores personal data of users for a period not longer than the existence of the registered accounts. After the expiry of this period, "PHOTOENERGY - ML" EOOD takes the necessary care to delete and destroy all your data, without unnecessary delay
- 2. "PHOTOENERGY - ML" EOOD stores the personal data that it is required to keep under the law of the applicable legislation for the relevant stipulated period, which may exceed the term of existence of the user's registration.
- 3. "PHOTOENERGY - ML" EOOD stores the personal data provided in connection with arising contractual relations, for the period of service provision and until the expiration of the statutory period for filing claims, which may exceed the period of existence of user registration.
8. Rights of natural persons in the collection, processing and storage of personal data:
- 1. Withdrawal of consent to the processing of personal data
If your personal data is processed based on your consent, you can withdraw it at any time by a free text request sent to hello@chill.bg via the email you used to register your account.
"PHOTOENERGY - ML" EOOD may ask the user to additionally certify his identity and identity with the data subject.
The withdrawal of consent does not affect the lawfulness of the processing carried out until withdrawal of consent.
In case of withdrawal of consent, "PHOTOENERGY - ML" EOOD will assess whether there are still grounds for the processing of personal data. The further processing of the data in this case will be possible to defend against claims and only to the extent necessary to do so purpose, as well as for the fulfillment of legally defined obligations
- 2. Right of access
Every person and user has the right to request and receive from "PHOTOENERGY - ML" EOOD confirmation whether personal data related to him is being processed.
Users have the right to access the data related to them, as well as to the information related to the collection, processing and storage of personal data.
"PHOTOENERGY - ML" EOOD provides, upon request, a copy of the processed personal data, related to the user, in electronic or other suitable form
Providing access to the data is free, but "PHOTOENERGY - ML" EOOD reserves the right to impose an administrative fee, in case of repetition or excessiveness of the requests
- 3. Right to correction or completion
The user can correct or complete inaccurate or incomplete personal data, through your profile and/or by sending a request to "PHOTOENERGY - ML" EOOD by email hello@chill.bg through the email he used to register his profile
- 4. Right to erasure - right "to be forgotten"
The user has the right to request from "PHOTOENERGY - ML" EOOD deletion of the related his personal data, and "PHOTOENERGY - ML" EOOD has the obligation to delete them without unnecessary delay when any of the following grounds exist:
- the personal data are no longer necessary for the purposes for which they were collected or processed
- the user has withdrawn his consent on which the processing of the data is based and there is no other legal basis for the processing
- the user has objected to the processing of personal data related to him, including for the purposes of direct marketing and there are no legitimate grounds for the processing that they have advantage
- personal data were processed unlawfully
- personal data must be deleted in order to comply with a legal obligation under the law of the EU or the law of a member state that applies to "PHOTOENERGY - ML" EOOD
- the personal data were collected in connection with the provision of information services society.
"PHOTOENERGY - ML" EOOD is not obliged to delete the personal data if it stores them and handles:
- to exercise the right to freedom of expression and the right to information
- to comply with a legal obligation that requires processing provided for in EU law or the law of the member state that applies to "PHOTOENERGY - ML" EOOD or to the performance of a task of public interest or in the exercise of official duties powers
- for reasons of public interest in the field of public health
- for the purposes of archiving in the public interest, for scientific or historical research or for statistical purposes
- for the establishment, exercise or defense of legal claims.
To exercise your right to be "forgotten", you must submit a written request to "PHOTOENERGY - ML" EOOD to email hello@chill.bg from the email address you used registered your profile to verify identity with the person they refer to the data.
In the email you must specify your username and which account you wish to delete. The deletion request is in free text, which should clearly show your desire to be forgotten
"PHOTOENERGY - ML" EOOD reserves the right to ask you for additional information about identification purposes before deleting your profile.
"PHOTOENERGY - ML" EOOD does not delete the data that it has a legal obligation to store, including for defense on the occasion of legal claims made against it or proving of own rights.
- 5. Right to Limit
You have the right to demand from "PHOTOENERGY - ML" EOOD to limit the processing of the data related to you when:
- dispute the accuracy of personal data, for a period that allows "PHOTOENERGY - ML" EOOD Ltd to verify the accuracy of personal data
- the processing is illegal, but you do not want your personal data to be deleted, but only that their use be limited
- "PHOTOENERGY - ML" EOOD no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or protection of your legal rights claims
- you have objected to the processing pending verification of whether the legal grounds of "PHOTOENERGY - ML" EOOD have priority over your interests.
- 6. Right of portability
You can at any time download the data that is stored and processed for you in connection with using the services of "PHOTOENERGY - ML" EOOD, by making a request to email hello@chill.bg via the email you used to register your account.
You may request "PHOTOENERGY - ML" EOOD to directly transfer your personal data to an administrator specified by you, when this is technically feasible.
- 7. Right to receive information
You can ask "PHOTOENERGY - ML" EOOD to inform you about all recipients whose personal data is requested to be corrected, deleted or restriction of processing have been disclosed. "PHOTOENERGY - ML" EOOD can refuse to provide this information if it would be impossible or disproportionately demanding great effort.
- 8. Right to object
You can object at any time to the processing of personal data by "PHOTOENERGY - ML" EOOD, which relate to you, including if they are processed for the purposes of profiling or direct marketing.
9. Direct Marketing
- 1. By checking the "I want to subscribe to the newsletter" box and/or by providing on email address and selecting the "Subscribe" button, the User agrees to receive marketing messages from "PHOTOENERGY - ML" EOOD in connection with promotional offers, current information, advertising campaigns, marketing and market research, pricing politics; sending advertising offers and materials, product information to "PHOTOENERGY - ML" EOOD and third parties, offers and news, newsletter and other such information, for direct marketing and any other commercial communications.
- 2. By checking the "I want to subscribe to the newsletter" box and/or by providing on email address and selecting the "Subscribe" button, the User gives his consent to the personal his data to be stored and processed for marketing purposes, including for analysis of site preferences and actions, for the purposes of sending the aforementioned emails.
- 3. The user has the opportunity to object to the processing of personal data for the purposes of direct marketing, and may at any time withdraw the given consent and refuse to receive information about products, campaigns, promotions, etc. of "PHOTOENERGY - ML" EOOD or third parties, as well as from receiving other advertising and information materials and offers by clicking on the "unsubscribe" or "terminate your subscription" field at receiving an e-mail containing any of the listed messages, or by sending message to email hello@chill.bg
- 4. Withdrawal of consent does not invalidate the legality of data processing actions to the moment of refusal.
10. Your rights in the event of a breach of the security of your personal data
If "PHOTOENERGY - ML" EOOD detects a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, notifies you unnecessarily delay for the violation, as well as for the measures that have been taken or are to be taken undertaken.
"PHOTOENERGY - ML" EOOD is not obliged to notify you if:
- has taken appropriate technical and organizational protection measures in relation to the data affected by the security breach
- has subsequently taken measures to ensure that the breach does not result in a high risk to your rights
- notification would require a disproportionate effort.
11. Right of appeal
In the event of a violation of your rights as set forth above or as applicable legislation for the protection of personal data, you have the right to file a complaint with the Commission for protection of personal data.
12. Security measures
The security of personal data is a priority for "PHOTOENERGY - ML" EOOD. The data that "PHOTOENERGY - ML" EOOD is collected, stored and processed on secure servers, as only a limited circle of authorized persons have access to them, encryption measures have been taken data and security is provided by an SSL certificate. Administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
This Privacy Policy enters into force on 12.10.2022