POLICY FOR THE PROTECTION OF INDIVIDUALS IN THE PROCESSING OF PERSONAL DATA

Information about the company that processes your data:
Name: "EM Studio Advertising and Creative" Ltd
EIK: 103943377
Headquarters and management address: city of Varna 9010, Primorski district, TRAKATA district, 4th Street No. 11
Correspondence address: Varna, 1 Akademik Igor Kurchatov St
Phone: 052 501 106
Email: admin@blagodae.com
Website: https://www.blagodae.com/
Personal data protection officer: Filip Ivanov, phone: 052 919 086

Information about the competent supervisory authority for the protection of personal data

Commission for the Protection of Personal Data
Headquarters and management address: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2
Address for correspondence: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2
Phone: 02 915 3 518
Web page: www.cpdp.bg

According to the provisions of the current European and Bulgarian legislation, "eM Studio Advertising and Creative" Ltd. is the administrator of personal data. These policies comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. on the protection of natural persons in connection with the processing of personal data and on the free movement of such data, the Law on the Protection of Personal Data, as well as all other legal acts relating to the protection of natural persons in the processing of their personal data. The purpose of this information is to inform you about all aspects of the processing of your personal data by "eM Studio Advertising and Creative" OOD and your rights arising from this processing in relation to the General Regulation for the protection of personal data.
"eM Studio Advertising and Creative" Ltd. is committed to maintaining high standards in the implementation of protection in the processing of your personal data that you provide on the website www.blagodae.com in order to guarantee your basic rights according to Regulation (EU) 2016/679 and in particular the right to protection of personal data.
What is personal data - it is any information related to an identified natural person or a natural person who can be identified directly or indirectly (data subject).
Processing of personal data is any action or set of actions that may be performed in relation to personal data by automatic or other means.
"EM Studio Advertising and Creative" Ltd. is the controller of personal data, as only defines the purposes and means of processing your personal data.

1. Why we collect, process and store your personal data

www.blagodae.com, owned by "eM Studio Advertising and Creative" Ltd., collects, processes and stores personal data in connection with using the functionalities of the electronic store for the sale of goods at a distance, organizing the delivery of the purchased goods, creating an account, subscription and receive e-mail with notifications about current promotions and new products. To create an account on our site, we need your name, email, address and phone number. In the event that you no longer wish to be registered on the site, please inform us so that we can take the necessary steps to delete your account. The notice can be sent by e-mail using the request in Appendix No. 1 or by a free text request by e-mail.

2. Grounds for collection, processing and storage of personal data

2.1. Express consent received from you as a customer;
2.2. Fulfillment of the Administrator's obligations under a contract with you;
2.3. Compliance with a legal obligation that applies to the Administrator;
2.4. For the purposes of the legitimate interests of the Administrator or a third party
When processing and storing personal data, the Administrator may process and store personal data in order to protect the following legitimate interests - fulfillment of obligations to the National Revenue Agency, the Ministry of Internal Affairs and other state and municipal bodies.

3. Purposes of processing your personal data

"eM Studio Advertising and Creative" Ltd. collects, processes and stores the personal data that you provide to us in connection with the use of the electronic store and the conclusion of a contract with the company, including for the following purposes:
3.1. Creating a profile and providing full functionality when using the online store;
3.2. Conclusion and performance of a contract at a distance;
3.3. Individualization of a party to the contract;
3.4. Accounting purposes;
3.5. Statistical purposes;
3.6. Ensuring the performance of the contract for the provision of the relevant service;
3.7. Sending a newsletter upon your request

4. Principles for the processing of your personal data:

legality, good faith and transparency – we process your personal data lawfully, in good faith and in a transparent manner for you.
limitation of processing purposes - the collection of personal data is for specific and legitimate purposes and processing in a manner incompatible with these purposes is not allowed.
minimizing the data collected - "eM Studio Advertising and Creative" Ltd. processes only personal data that is appropriate, limited to what is necessary and related to the purposes for which it is processed.
accuracy and timeliness of data - "eM Studio Advertising and Creative" Ltd. takes reasonable measures to ensure timely correction or removal of inaccurate personal data.
storage limit - "eM Studio Advertising and Creative" Ltd. stores personal data in a form that allows identification of the data subject for a period not longer than necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods, insofar as they will be processed solely for statistical purposes, and the company ensures the application of appropriate technical and organizational measures in order to guarantee the rights and freedoms of the data subject. You can request from the electronic store of "eM Studio Advertising and Creative" OOD to delete your account and the personal data available in it.
integrity and confidentiality of processing - "eM Studio Advertising and Creative" Ltd. processes your personal data in a way that guarantees an appropriate level of security, including protection against unauthorized or illegal processing and against accidental loss, destruction or damage by applying appropriate technical and organizational measures.
responsibility and accountability of the administrator - "eM Studio Advertising and Creative" Ltd. is responsible for compliance with the above-mentioned principles and is able to prove their compliance.

5. Why and which personal data is processed by EM Studio Advertising and Creative Ltd., managing www.blagodae.com

5.1. Registration in the e-store and execution of a remote purchase and sale contract - the purpose is to create a profile for using the e-store to purchase goods and provide data for their delivery. Registration and creation of an account for using the online store is not a mandatory step of providing the service and it is also available without creating your own account.
Conclusion of the impact assessment: Based on the impact assessment carried out, the operation "Registration in the e-shop and execution of a contract of purchase and sale at a distance" is permissible to carry out and provides sufficient guarantees to protect the rights and legitimate interests of the data subjects in accordance with the requirements of the Regulation.
5.2. Newsletter sending - the purpose is to administer the process of sending newsletters to customers who have indicated that they wish to receive one. Given the limited scope of personal data collected, it is not necessary to carry out an impact assessment of the operation.
5.3. Exercising the right to refuse an order or making a complaint - the purpose is to administer the process of exercising the right of refusal or complaint by the customer. Given the limited scope of personal data collected, it is not necessary to carry out an impact assessment of the operation.
5.4. Conclusion and execution of a commercial transaction with a customer or partner - the purpose of this operation is the conclusion and execution of a contract with a commercial partner or customer and its administration. Given the limited scope of the collected personal data and the fact that some of them are collected from publicly available sources, conducting an impact assessment is not necessary to conduct an impact assessment of the operation.

Your individualizing data when creating an account in our online store are:

• in the "Personal information" sector - first name, last name, telephone, e-mail. They are needed by "eM Studio Advertising and Creative" OOD for individualizing you as our customer with your own account in the electronic store and receiving an electronic newsletter by e-mail with prior consent.
• "Payment and delivery information" sector - the mandatory personal data marked with an asterisk are: address, city, postal code and country. They are necessary for "eM Studio Advertising and Creative" Ltd. for the fulfillment of its obligations under the contract for purchase and sale and delivery of the purchased goods.
• To place an order in the e-shop without prior registration and creating an account, the following personal data are required: first name, last name, telephone, e-mail, address, city, postal code and country, in order to fulfill the order placed by you.

In connection with the above activities, the company also collects an IP address.
"eM Studio Advertising and Creative" Ltd. collects the minimum necessary personal data for the fulfillment of its contractual obligations to you. The company does not collect additional data, and in the event of a change in the mandatory data, you can update the information in your account yourself.
The Company does not collect or process personal data that reveal racial or ethnic origin, political views, religious or philosophical beliefs, or membership in trade union organizations, genetic and biometric data, data on the state of health or data on the sex life or sexual orientation of natural persons .
EM Studio Advertising and Creative Ltd. accepts that it collects personal data from the natural persons to whom it relates.
The company does not transfer your data to third countries, automated processing, including profiling. Profiling is any form of automated processing of personal data to assess certain personal aspects related to the natural person, to predict aspects related to the natural person's professional duties, his economic situation, health, personal preferences, interests, reliability, behavior , location or movement.
"eM Studio Advertising and Creative" Ltd. uses the personal data collected by you, name and e-mail, for the purposes of direct marketing, after receiving express consent for this.
In the event that we collect personal data from you in your capacity as a legal representative or proxy of a legal entity - business partner, it is for the purpose of concluding and executing a commercial transaction. For the conclusion and execution of a commercial transaction with a commercial company, we process only the three names of the legal representative or the person authorized by the company.
The online store www.blagodae.com can use the so-called "cookies" for the purposes of providing full functionality of the website, improving the user experience, statistical purposes, ease of access, etc., to which you agree by using our website. You can control and/or delete cookies at any time through the settings of your browser. "Cookies" do not constitute personal data and are not used to identify visitors and users of the e-shop. You can find more about cookies here

6. Period of storage of personal data

In connection with the creation of an account in our online store, we process your personal data for a period not longer than the existence of your account in the online store. After deleting your account, the Administrator takes the necessary care to delete and destroy all your data without undue delay or to anonymize them, i.e. to bring them into a form that does not reveal your identity, unless there is another legal basis to continue processing the data.
"eM Studio Advertising and Creative" Ltd. processes the personal data you provided when placing an order without registering in the electronic store. The term of processing your personal data in the primary accounting documents created in connection with your order is in accordance with the statutory five-year terms under the Accounting Act. In case of consent to receive our e-mail newsletter, your name and e-mail are processed until you file an opt-out.
We store your personal data provided in connection with online orders for a period of 5 years for the purpose of protecting the legal interests of "EM Studio Advertising and Creative" OOD in legal or administrative disputes with users of the online store, as well as in connection with the requirements of the Accounting Act. By virtue of the applicable legislation, it is possible that your personal data may need to be stored for a period that may exceed the period of existence of your profile in the e-shop or after the execution of an order without a created profile. After the expiration of the statutory storage period, the company undertakes to notify you in the event that it is necessary to extend the data storage period in order to fulfill a legal obligation or in view of the legitimate interests of the company or otherwise.
"eM Studio Advertising and Creative" Ltd. stores the personal data of natural persons acting in their capacity as legal representatives or proxies of legal entities, our commercial partners for the period of performance of the contract or for the period of existence of the created account, in order to comply with legitimate interests and legal obligations of the Administrator, the term of which may exceed the term of existence of the account.

7. Transmission of personal data for processing

"eM Studio Advertising and Creative" Ltd., as a personal data administrator, may, at its own discretion, transfer part or all of your personal data to personal data processors - its employees and/or contractual partners for the fulfillment of the purposes of processing, subject to compliance with the requirements of Regulation (EU) 2016/679 (GDPR). Personal data processors comply with all legality and security requirements when processing and storing your personal data.
"eM Studio Advertising and Creative" Ltd. does not transfer your data to third countries. The Company will notify you if it intends to transfer part or all of your personal data to third countries or international organizations.

8. Your rights in the processing of personal data

8.1. Withdrawal of consent for personal data processing
If you do not wish the personal data provided by you to be processed for marketing purposes and receiving our newsletter, you can withdraw your consent to processing at any time in one of the following ways:

• By unsubscribing via the "please unsubscribe here" link at the bottom of each message;
• By free text request sent to office@blagodae.com

Upon receipt of your request, we will, without undue delay, delete your personal data from our newsletter receipt lists.
The withdrawal of consent does not affect the lawfulness of the processing of personal data, which "eM Studio Advertising and Creative" LLC has carried out up to this point.

8.2. Right of access
You have the right to request and receive from "EM Studio Advertising and Creative" OOD, the owner of www.blagodae.com, a confirmation as to whether personal data related to you is being processed by sending a request for this information using the request in Appendix #1 or in free text by e-mail. You have the right to access the data related to you, as well as the following information: purposes of the processing, categories of personal data, recipients or categories of recipients to whom the personal data is or will be disclosed, the storage period or the criteria for determining the period of storage of personal data.
After receiving your request, we will provide you with information about the processed personal data related to you in electronic form as soon as possible. Providing access to the data is free of charge, but "eM Studio Advertising and Creative" Ltd. reserves the right to impose an administrative fee in case of repetitive or excessive requests.

8.3. Right to object
You can object at any time to the processing of your personal data by the Administrator, including if it is processed for the purposes of profiling or direct marketing. You can make an objection using the request in Appendix #1 or in free text by e-mail.

8.4. Right to rectification
You may at any time correct inaccurate or incomplete personal data relating to you directly through your profile on the website in the "My Account" section; by making a request to the Administrator by e-mail using the request in Appendix No. 1 or by a free-text request by e-mail.

8.5. Right to erasure - right to be forgotten
You have the right to ask eM Studio Advertising and Creative Ltd. to delete part or all of your personal data, and the company has the obligation to delete them without undue delay, when any of the following grounds are present:

• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
• You have objected to the processing of your personal data, including for direct marketing purposes, and there are no overriding legal grounds for the processing;
• the personal data were processed unlawfully;
• the personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the Administrator;
• personal data were collected in connection with the provision of information society services.

"EM Studio Advertising and Creative" Ltd. does not apply the above when personal data is stored and processed for:

• exercising the right to freedom of expression and the right to information;
• compliance with a legal obligation that requires processing provided for in EU law or Member State law that applies to the Administrator or for the performance of a task in the public interest or in the exercise of official powers conferred on him;
• for reasons of public interest in the field of public health;
• the purposes of archiving in the public interest, for scientific or historical research or for statistical purposes;
• the establishment, exercise or defense of legal claims.

In order to exercise your right to be forgotten, it is necessary to send by e-mail a request to delete your personal data, which the Administrator processes, by completing the request in Appendix No. 1 or by a free text request by e-mail.

8.6. Right to limitation
You have the right to demand from eM Studio Advertising and Creative Ltd., the personal data controller, to limit the processing of the data related to you by sending the request according to Appendix No. 1 or in free text by e-mail, when:

• dispute the accuracy of the personal data, for a period that allows the administrator to verify the accuracy of the personal data;
• the processing is illegal, but you do not want the personal data to be deleted, but only to have its use restricted;
• the administrator no longer needs the personal data for the purposes of processing, but you require them to establish, exercise or defend your legal claims;
• you have objected to the processing pending verification of whether the controller's legitimate grounds prevail over your interests.

8.7. Right of portability
If you have consented to the processing of your personal data or the processing is necessary for the performance of the contract with the Administrator, you have the right to receive from the Administrator, in a structured, widely used and machine-readable format, your personal data, as well as to receive the direct their transfer to another Administrator. You can exercise your right to transfer personal data from one administrator to another only in cases where this is technically feasible.
You can exercise the right of portability by emailing us the request in Appendix No. 1 or a free text request.

8.8. Right to receive information
You can ask the Administrator to inform you about all recipients to whom the personal data for which correction, deletion or restriction of processing has been requested has been disclosed. The administrator may refuse to provide this information if it would be impossible or would require a disproportionate effort.

8.9. Right of appeal
You have the right to file a complaint against the processing of your personal data before the competent supervisory authority (in Bulgaria – the Commission for the Protection of Personal Data or the court) if you believe that your rights to the protection of personal data have been violated.

You can exercise all your rights regarding the protection of your personal data through the annex to this policy. This application is optional and you can make your requests in any form that contains a statement to that effect and identifies you as the data owner.

9. Security of personal data

Taking into account the achievements and technical progress, the costs of implementation and the nature, scope, context and purposes of processing, the risks to the rights and freedoms of natural persons, "eM Studio Advertising and Creative" OOD, as well as its employees processing personal data, apply appropriate technical and organizational measures to ensure the required level of security.
In the event that "eM Studio Advertising and Creative" Ltd. detects a breach of the security of your personal data, which may create a high risk for your rights and freedoms, it will notify you without undue delay of the breach and of the measures taken or to be taken to be undertaken.
"EM Studio Advertising and Creative" Ltd. is not obliged to notify you of a breach of personal data security if any of the following conditions are met:

• The Company has taken appropriate technical and organizational measures to protect the personal data affected by the security breach;
• The administrator has subsequently taken measures to ensure that the breach will not result in a high risk to your rights;
• Notification would result in a disproportionate effort.

10. Provision of your personal data for processing

EM Studio Advertising and Creative Ltd. does not share, sell, rent, trade personal data collected from its customers.
With a view to processing your personal data, implementing the service in its full functionality and with a view to your interests, "eM Studio Advertising and Creative" Ltd., at its own discretion, may provide part or all of your personal data to personal data processors - its employees and/or contractual partners for the fulfillment of processing purposes, in compliance with the requirements of Regulation (EU) 2016/679 (GDPR). If there is a legal basis, your personal data may be provided to service providers /e.g. courier, accounting services/ to help us process the data that is collected voluntarily by you, as well as in fulfillment of our contractual obligations, which we conclude. The personal data collected by you may be passed on only to our trusted partners, with whom we jointly realize the services and products we offer. Service providers use the data according to our instructions and may not store it for longer than is necessary to perform the specified service and to comply with the law. In the case of providing data, "eM Studio Advertising and Creative" OOD obliges third parties - customers, employees and partners, to maintain confidentiality of information and undertake that your personal data are used only for the agreed purposes and are never used beyond the purposes for which they were provided. In addition, they must process personal data in accordance with and in compliance with the policy for the protection of natural persons in the processing of personal data of "EM Studio Advertising and Creative" OOD, as well as with the applicable data protection laws, taking into account all requirements for legality and security in the processing of your personal data.

In the event of a breach of your rights under applicable data protection legislation, you have the right to lodge a complaint with the Commission for Personal Data Protection as follows:
Name: Personal Data Protection Commission.
Headquarters and management address: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2
Address for correspondence: Sofia 1592, "Prof. Tsvetan Lazarov" No. 2
Phone: 02 915 3 518
Web page: www.cpdp.bg