Information about the company that processes your data:

Name	„Cupffee“ Ltd.
UIC/BULSTAT	203075711
Seat and management address	4002 Plovdiv, “Zapaden” district, 45 “Koprivshtitsa” Blvd.
Correspondence address	4023 Plovdiv, „Trakia” District, 1 “Asenovgradsko shose” Blvd.
Phone	+359 884 931 183
E-mail	office@cupffee.me
Web page	https://www.cupffee.me/

 

Information about the competent data protection authority

Name	Commission for Personal Data Protection
Seat and management address	1592 Sofia, 2 “Proff. Tsvetan Lazarov” Blvd.
Correspondence address	1592 Sofia, 2 “Proff. Tsvetan Lazarov” Blvd.
Phone	+359 02 915 3 518
Web page	www.cpdp.bg

„Cupffee“ Ltd (Hereinafter referred to as “Administrator” or “Company”) operates in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Counci of Europe from 27 April 2016 on the protection of individuals with regard to the processing of personal data and 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 the rights you have in connection with this processing.

 

Grounds for collecting, processing and storing your personal data

 

Art. 1. The administrator collects and processes your personal data in connection with the use of the online store Cupffee.me and concluding contracts with the company on the grounds of art. 6, para. 1, Regulation (EU) 2016/679 (GDPR), and in particular, the following grounds:

1. Your explicit consent as a customer;
2. Fulfillment of the obligations of the Administrator under the contract with you;
3. Compliance with legal obligations that apply to the Administrator;
4. For the purposes of the legitimate interests of the Administrator or a third party;

 

Goals and principles in the collection, processing and storage of your personal data

Art. 2. (1) We collect and process the personal data you provide to us in connection with the use of the online store Cupffee.me and concluding a contract with the company, including the following purposes:

1. creating an account and providing full functionality when using the online store;
2. individualization of a Party, regarding the contract;
3. accounting purposes;
4. statistical purposes;
5. protection of the informational security;
6. ensuring the enactment of the contract for the provision of the respective service;
7. sending newsletters and emails with special offers uppon your explicit request;
8. sending promotional materials and product samples from other companies via „Cupffee“ Ltd. with your explicit request;
9. sending answers to inquiries made through the feedback form on our website.

(2) We adhere to the following principles when processing your personal data:

1. legality, good faith and transparency;
2. restriction of the processing purposes;
3. relevance of the purposes of processing and minimisation of the ammounts of the collected data;
4. accuracy and relevance of the data;
5. limitation of storage, needed to reach the objectives;
6. integrity and confidentiality of the processing and ensuring an appropriate level of security of the personal data.

(3) When processing and storing personal data, the Administrator may process and store personal data in order to protect the following legitimate interests:

1. fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal bodies.

 

What types of personal data our company collects, processes and stores

 

Art. 3. (1) The company performs the following operations with the personal data provided by you as customers, for the following purposes:

1. Registration of a customer in the e-store and fulfillment of a remote sales contract – The purpose of this operation is to create an account for the use of the e-store for the purchase of goods and provide contact information for the delivery of the said purchased goods. Registration and account creation in order to use the online store is not a mandatory step in providing the service and it is available to a large extent without creating an account through the option „Order as guest“ – Conclusion from the impact assessment:Based on the impact assessment carried out, the Data Protection Officer considers that the operation “User registration in the e-store and execution of a remote sales contract” is eligible for execution and provides sufficient guarantees to protect the rights and legitimate interests of data subjects in accordance with the requirements of the GDPR;
2. Sending an informational bulletin (newsletter)– The purpose of this operation is to administer the process of sending newsletters, emails with special offers, promotions, promo codes, news and new features to customers who have stated that they wish to receive ones. Given the limited scope of the personal data collected, the Data Protection Officer considers that an impact assessment is not required.
3. Exercising the right of withdrawal or making a complaint – the purpose of this operation is to administer the process of exercising the right of withdrawal or complaint by the customer for the goods in respect of which these rights may be exercised. Given the limited scope of the personal data collected, the Data Protection Officer considers that an impact assessment is not required.
4. Providing advertising materials and sampling by other companies through „Cupffee“ Ltd.– The purpose of this operation is administration of the process of sending advertising materials and samples of products from other companies through „Cupffee“ Ltd to customers who have stated that they wish to receive them. Given the limited scope of the personal data collected, the Data Protection Officer considers that an impact assessment is not required.
5. Making inquiries through the website feedback form Shop.cupffee.me- the purpose of this operation is to send a response to a request. Given the limited scope of the personal data collected, the Data Protection Officer considers that an impact assessment is not required.

(2) The administrator does not collect or process personal data relating to the following:

1. revealing racial or ethnic origin;
2. revealing political, religious or philosophical beliefs, or union membership;
3. genetic and biometric data, health data or data on sexual life or sexual orientation.

(3) Personal data is collected by the Administrator from the persons to whom it relates.

(4) The administrator does not perform automated decision making about data in his possesion.

(5) The company does not collect data on persons under 16 years of age, except with the express consent of their parent or legal representative.

Art. 4. (1) The Admin processes the following categories of personal data and information for the following purposes and on the following grounds:

1. Your personal data (e-mail, name, etc.)
   • Purpose for which the data is collected:1) Making contact with the user and sending information to them, 2) for the purpose of user registration in the online store, as well as 3) to send newsletters, emails with special offers, promotions, promo codes, news and new features, and 4) sending a response to an inquiry through the form on our website.

1.2. Grounds for processing your personal data – By accepting the general terms and conditions and registering in the e-store or placing an order without registration, or by concluding a written contract, a contractual relationship is created between the Administrator and you on the basis of which we process your personal data – Art. 6, para. 1, p. (b) GDPR. Your data for sending a newsletter and emails, as well as for sending a response to an inquiry through the form on our website, are processed with your explicit consent – Art. 6, para. 1, p. (a) GDPR.

2. Delivery data(name, phone number, address and other.)

2.1. Purpose for which the data is collected: 1) Fulfillment of obligations of the administrator under a contract for sale and delivery of purchased goods and 2) Sending of promotional materials and samples of products from other companies via „Cupffee“ Ltd. to customers who have stated that they wish to receive them.

2.2. Grounds for processing your personal data – By accepting the general terms and conditions and registering in the e-store or placing an order without registration, or by concluding a written contract, a contractual relationship is created between the Administrator and you on the basis of which we process your personal data – Art. 6, para. 1, p. (b) GDPR.
Your data for sending a newsletter and emails, as well as for sending a response to an inquiry through the form on our website, are processed with your explicit consent – Art. 6, para. 1, p. (a) GDPR.

3. Data from your social media accounts (publicly available information from your accounts on Google+, Facebook, etc.)

3.1. Purpose for which the data is collected: 1) Making contact with the user and sending information to him and 2) for the purposes of user registration in the online store.

3.2. Grounds for processing your personal data – With the acceptance of the general conditions and registration in the e-store through a profile in a social network, a contractual relationship is created between the Administrator and you, on the basis of which we process your personal data – Art. 6, para. 1, p. (b) GDPR.

Duration of storage of your personal data

 

Art. 5. (1) The administrator stores your personal data for a period not longer than the existence of your account in the online store or the execution of the order “as a guest”. After deleting your account or completing the order, the Administrator takes the necessary care to delete and destroy all your data without undue delay or to anonymize it (ie to make it in a form that does not reveal your identity).

(2) The Administrator stores your personal data provided in connection with online orders for a period of 5 years for the purposes of protecting the legal interests of the Administrator in case of court or administrative disputes with Users of the online store, as the accounting documents are stored for the respective statutory period.

(3) The Administrator notifies you in case the data retention period needs to be extended in order to fulfill a regulatory obligation or in view of the legitimate interests of the Administrator or otherwise.

(4) The administrator stores the personal data that is necessary to keep in accordance with the applicable legislation for the relevant period, which may exceed the period of existence of your account in the e-shop or until the completion of the order.

Art. 6. (1) The Administrator stores the personal data of the legal representatives of its business partners for the duration of the contract, for compliance with the legitimate interests and legal obligations of the Administrator, and this duration may exceed the duration of the contract.

 

Transfer of your personal data for processing

Art. 7. (1) The Administrator may, at its discretion, transfer some or all of your personal data to personal data processors for the fulfillment of the processing purposes with which you have agreed, subject to the requirements of Regulation (EU) 2016/679 (GDPR).

(2) The administrator notifies you in case of intention to transfer part or all of your personal data to third countries or international organizations.

 

Your rights in the collection, processing and storage of your personal data

 

Withdrawal of consent for the processing of your personal data

Art. 8. (1) If you do not wish all or part of your personal data to continue to be processed by the Company for specific or for all purposes of processing, you can at any time withdraw your consent for processing by filling in the form in your profile or by written request.

(2) The administrator may ask you to verify your identity and the identity of the data subject.

(3) By withdrawing your consent to the processing of personal data, which is mandatory for creating and maintaining an account in the online store, your account will become inactive. Of course, you will be able to browse the online store and the products offered and place orders as a guest or create a new registration.

(4) If there is an order made by you that is in the process of processing, the earliest moment at which you can withdraw your consent for processing is upon successful completion of the order.

(5) You may at any time withdraw your consent to the processing of your personal data for the purposes of direct marketing.

(6) The withdrawal of the consent does not affect the legality of the processing of personal data, which the Administrator has performed so far.

 

Right of access

Art. 9. (1) You have the right to request and receive confirmation from the Administrator whether personal data related to you is processed, and you can at any time see in your account, if you are a registered user, what data we process about you.

(2) You have the right to access the data related to you, as well as the information related to the collection, processing and storage of your personal data.

(3) Upon request, the administrator provides you with a copy of the processed personal data related to you in electronic or other appropriate form.

(4) Providing access to the data is free of charge, but the Administrator reserves the right to impose an administrative fee in case of repetitive or excessive requests.

 

Right of correction or completion

Art. 10. You may correct or complete inaccurate or incomplete personal information relating to you directly through your account on the website or by making a request to the Administrator.

 

Right of deletion (“to be forgotten”)

Art. 11. (1) You have the right to request from the Administrator the deletion of part or all of the personal data related to you, and the Administrator has the obligation to delete them without undue delay when any of the following reasons is present:

1. personal data is no longer needed for the purposes for which is was collected or otherwise processed;
2. You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
3. You object to the processing of personal data relating to you, including for direct marketing purposes, and there are no legal grounds for processing to take precedence.;
4. personal data has been processed illegally;
5. personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State applicable to the Admin;
6. personal data has been collected in connection with the provision of services for the information society.

(2) The administrator is not obliged to delete personal data if it is stores and processed:

1. to exercise the right of freedom of expression and the right of access to information;
2. to comply with a legal obligation requiring processing provided for in EU law or the law of the Member State applicable to the Administrator or for the execution of a task in public interest or in the exercise of official powers conferred to him;
3. for reasons of public interest in the field of public health;
4. for archiving purposes in public interest, for scientific or historical research or for statistical purposes;
5. for the establishment, exercise or defense of legal claims.

(3) In case of exercising your right to be forgotten, the Company will delete all your data, except for the following information:

1. information that is needed to verify that your right to be forgotten has been exercised – e-mail, IP address;
2. technical information about the operation of the online store, which information cannot be connected in any way with your personality;
3. e-mail with which you registered in the online store.

(4) In order to exercise your right to be forgotten, you need to take the following steps:

1. To apply through your profile in the online store or by e-mail;
2. To submit a unique identification code to perform the action, which will be sent to you by email at the address associated with the registration in the online store;
3. To identify yourself as the account holder. Identification is expressed in sending the request through the e-mail which is linked to the user, regarding the data whereof you are exercising the right to be forgotten.

(5) After verifying the identity of the person making the request and the person to whom the data relates in accordance with the above steps, we will delete all data that we process for you, in accordance with para. 3.

(6) If you have an order that is being processed, the earliest time you can request to be “forgotten” is when the order is successfully completed.

(7) By deleting your personal data, your account will become inactive. Of course, you will be able to browse the online store and the products offered and place orders as a guest or make a new registration.

(8) The administrator does not delete the data that they have a legal obligation to store, including for protection in connection with court claims against him or proof of his rights.

 

Right of restriction

Art. 12. You have the right to ask the Administrator to restrict the processing of data related to you when:

1. You challenge the accuracy of personal data for a period that allows the Administrator to verify the accuracy of personal data;
2. Processing is illegal, but you do not want the personal data to be deleted, only the use of it to be restricted;
3. The Admin no longer needs your personal data for the purposes of processing, but you require them to establish, exercise or defend your legal claims.;
4. You have objected to the processing, pending verification of whether the legal grounds of the Administrator take precedence over your interests.

(2) In case of exercising your right of restriction, the Company will suspend the processing of your data, but will not remove the publications you have made in the online store.

 

Right of transferability

Art. 13. (1) If you have given your consent for the processing of your personal data or the processing is necessary for the enactment of the contract with the Administrator, or if your data is processed in an automated manner, you can, after identifying yourself with the Administrator:

1. to ask the Administrator to provide you with your personal data in a readable format and to transfer it to another Administrator;
2. to ask the Administrator to directly transfer your personal data to an administrator designated by you, when this is technically possible.

(2) You may at any time download or receive in machine-readable format the data stored and processed for you in connection with the use of the Administrator’s services, directly through your account via the data export option or by e-mail request.

 

Right to receive information

Art. 14. 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 have been disclosed. The administrator may refuse to provide this information if it is impossible or would require a disproportionate effort.

 

Right to object

Art. 15. You may object at any time to the processing of personal data by the Administrator related to him, including, if they are processed for profiling or direct marketing purposes.

 

 

Your rights in the event of a breach of the security of your personal data

Art. 16. (1) If the Administrator finds a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, they shall notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken.

(2) The administrator is not required to notify you if:

1. they have taken appropriate technical and organizational protection measures with regard to data affected by the security breach;
2. they have subsequently taken steps to ensure that the breach does not pose a high risk to your rights;
3. notifying you would require a disproportionate effort.

 

Persons to whom your personal data is provided

Art. 17. For the purposes of processing your personal data and providing the service in its full functionality and in view of your interests, the Administrator may provide your data to the following processors of personal data:

Person, processing personal data	Purpose of personal data processing
Supplier	Delivery to an address

The specified processors of personal data comply with all requirements for legality and security in the processing and storage of your personal data.

Art. 18. The administrator does not transfer your data to third countries.

Art. 19. In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to send a complaint to the Personal Data Protection Commission on the following coordinates:

Name	Commission for Personal Data Protection
Seat and management address	1592 Sofia, 2 “Proff. Tsvetan Lazarov” Blvd.
Correspondence address	1592 Sofia, 2 “Proff. Tsvetan Lazarov” Blvd.
Phone	+359 02 915 3 518
Web page	www.cpdp.bg

Art. 20. You can exercise all your rights regarding the protection of your personal data through the forms attached to this current information. or through the functionalities in your profile Of course, these forms are optional and you can submit your requests in any form that contains a statement to that effect and identifies you as the data holder.

Art. 21. If the consent relates to a transfer, the Administrator shall describe the possible risks for the transfer of the data to third countries in the absence of a manner with adequate protection and appropriate means of protection.

Art. 22. The Company may amend the Privacy Policy by posting a notice to that effect on its website.

Privacy Policy was last amended on 08.08.2021 г.

Withdrawal form of consent for processing purposes – Annex № 1

Request to be “forgotten” – to delete personal data related to me – Annex № 2

Request for transferability of personal data – Annex № 3

Request for data correction – Annex № 4