Confidentiality and protection of Personal Data

NOTICE OF CONFIDENTIALITY AND PROTECTION OF PERSONAL DATA

Thank you for being interested in our work and the protection of Personal Data as a site visitor. This is an important aspect of modern life and we want to inform you as accurately as possible about the Personal Data we process and what rights you have in relation to it.

All our employees are obliged not to distribute the information, including Personal Data, that became known to them during and on the occasion of their work, and they have signed a declaration to this effect.

With this Notice, you receive information in accordance with the General Regulation (EU) 2016/679 on the Protection of Personal Data (abbreviated GDPR, the Regulation or the Regulation on the Protection of Personal Data), as well as the Law on the Protection of Personal Data (abbreviated LPPD), about how AUTOZONABG 2018 Ltd, as well as the site you visited which is owned by AUTOZONABG 2018 Ltd (“we,” “us,” “us,” “the site,” ” AUTOZONABG 2018 Ltd.” for short), use and process information that may contain Personal Data.

We regularly review the content of this Notice and update, change or supplement it as necessary.

First of all, it is good to know that any information through which it is possible to identify you as an independent entity constitutes Personal Data and falls under the protection of the GDPR and the LPPD.

When do we process Personal Data?

І. Contact forms

  • When you make contact with us by sending an email to one of the electronic addresses (emails) specified on our site or another email specified for you personally.
  • When you make contact with us by calling one of the phone numbers indicated on the site or another phone provided to you.
  • When you make contact with us through the contact form on the site, which appears through the “contacts” and “request a quote” menus on the site. In this case, the message sent by you is received by us as an email.

You have the choice to communicate with us via any of these media that you see fit.

In each of these cases, you voluntarily provide, at your discretion, information such as contact details (email and/or phone number), a name that you provide to us, as well as any information that you deem appropriate.

Limitation of the purposes and the processing

We process the information provided by you, including Personal Data, only for the purpose of being able to respond appropriately to your needs.

If we need more information and Personal Data to respond to your inquiry or message, we will ask you to provide it voluntarily.

If we record your phone call, you will be notified before the call begins.

Who has access to your Personal Data?

Your messages and conversations will reach employees of AUTOZONABG 2018 Ltd to whom they are addressed or who are competent to answer you appropriately or provide you with the necessary offer. When it is necessary to provide data to third parties in order to respond to you appropriately, it will be anonymized if possible, depending on the nature of your inquiry. In very rare cases, data will be provided to relevant authorities or institutions that have a legal obligation to receive it.

Purposes and legal basis for the processing of Personal Data

  • Fulfillment of a contractual obligation (Art. 6 para. 1, letter “b” of GDPR)

In this case, the processing of Personal Data is based on the performance of pre-contractual relations that precede contractually regulated relations, as well as on the performance of obligations under a concluded contract. In this case, it will already be necessary for you to provide exact data, as in this case consent to their processing is not required, and accordingly, there is no way to withdraw such consent.

  • Fulfillment of a legal obligation (Art. 6, para. 1, letter “c” of the GDPR)

Sometimes the processing of Personal Data is based on legal obligations, such as inquiries from various Authorities and Institutions within their competences, to which we are obliged to respond. When they do not need Personal Data, it will not be provided to them, only another type of information.

  • Fulfillment of legitimate interests (Art. 6, para. 1, letter “f” of the GDPR)

The legitimate interests in this case are: to be able to respond to you; selection of suitable business partners; the settlement of legal claims; defense against claims.

Data storage period

Personal Data will be stored for 1 year and then deleted. This period is necessary in order to be able to respond to you when you have additional or clarifying questions and inquiries, as well as in the case of legal disputes.

ІІ. Conclusion of contracts and their implementation.

When concluding a contract with us, the subject (the other party) is undertakes provide the necessary information in order to be individualized and to determine when the contract is concluded. Accordingly, a sufficient amount of information is provided about natural persons, including Personal Data such as names, social security number, address, and any other necessary information for the performance of the contract according to its specifics. The public data provided by the Company in the Commercial Register (Commercial Register and Register for Non-Profit Legal Entities) or the BULSTAT register are not protected by the GDPR and the LPPD.

Limitation of purposes and processing

We process the information provided by you, including Personal Data, only for the purpose of concluding the contract and performing it. Personal Data will also be required before the conclusion of the contract, when actions are still being taken to conclude it.

Who has access to your Personal Data?

The AUTOZONABG 2018 Ltd employees who are responsible for the conclusion and execution of the contract. When it is necessary to provide data to parties not participating in the contract (such as external accountants, lawyers, etc.) in order to carry out its conclusion and execution, the Data will be anonymized if possible depending on the nature of the work. Compliance with data protection rules will be ensured through the contract with our subcontractors.

Purposes and legal basis for the processing of Personal Data

  • Fulfillment of a contractual obligation (Art. 6 para. 1, letter “b” of GDPR)

In this case, the processing of Personal Data is based on the performance of pre-contractual relations that precede contractually regulated relations, as well as on the performance of obligations under a concluded contract. In this case, it will already be necessary to provide your exact data, as in this case consent to their processing is not required, and accordingly, there is no way to withdraw the consent.

  • Fulfillment of a legal obligation (Art. 6, para. 1, letter “c” of the GDPR)

Sometimes the processing of Personal Data is based on legal obligations. These obligations include, for example, the fulfillment of storage and identification requirements, e.g. in the context of anti-money laundering requirements, tax control and reporting obligations, and data processing in the context of inquiries from Authorities and Institutions within their legal competences to which we are obliged to respond. When they do not need Personal Data, it will not be provided to them, only another type of information.

  • Fulfillment of legitimate interests (Art. 6, para. 1, letter “f” of the GDPR)

It is necessary for us to process the Personal Data provided by you outside the actual performance of the contract. The legitimate interests here are specifically: accounting; selection of suitable business partners; the settlement of legal claims; defense against claims; the clarification of possible violations of the normative rules, the prevention of crimes and the regulation of damages that have an impact on business relations; possibly collecting data about your ability to pay through credit bureaus to protect our legitimate interests.

Data storage period

Personal Data will be stored for 11 years and then deleted. This period is legally defined in the tax legislation for the storage of primary accounting documents, and this period also includes the possible limitation periods in case of legal disputes. If a legal dispute continues after these 11 years, the data will be stored until its conclusion.

ІІІ. Oriented (targeted or individualized) messages, advertisements and offers

We use platforms such as Facebook, Instagram, Google, YouTube that track your behavior (such as location, time, interests, etc.) when you use them and the data obtained from them helps us to be able to send you individualized or general targeted advertisements and offers . In order to do so, we use platforms and tools such as Google Analytics and Facebook Business Manager through which we exchange information, including Personal Data.

These platforms try to match your profile in their database and decide when and where (the web page you are viewing) is best and optimal to show you our advertisement. We also need all this information to be able to analyze our advertising campaigns and their impact on our business. If you do not wish to be tracked for these purposes, you may also see an advertisement from AUTOZONABG 2018 Ltd, but it will be accidentally seen.

Categories of Personal Data

Identity information

Contact information (if available to us)

Location information

Payment, purchase and transaction data (if available and accessible to us and we need it)

Social media activity and interaction (if available and accessible to us)

Internet browsing information

Mobile device information

Information about behavior and preferences (if available and accessible to us)

Personal opinion

Cookies/tags/pixels may be used: We may collect your Personal Data for this purpose by using technologies such as cookies, pixels and tags to collect information about your device. More information is available under the section “Collection of information about your device on our website and applications using cookies, pixels, tags and similar technologies”.

You can learn more about how our advertising partners and social media platforms help us achieve this goal by visiting their sites:

Google Personalised Advertising: https://support.google.com/adspolicy/answer/143465?hl=en

Google Advertising Policies: https://support.google.com/adspolicy/answer/6020956

Facebook Lookalike Audiences: https://www.facebook.com/business/help/164749007013531

Facebook Custom Audience Terms: https://www.facebook.com/legal/terms/customaudience

Who has access to your Personal Data?

Employees of our team as well as the indicated partner platforms, such as Google and Facebook for the data used.

Legal basis for the processing of Personal Data

  • Consent (Art. 6 para. 1, letter “f” of GDPR)

Data storage period

Until consent is withdrawn.

ІV. Product research and development

We perform analysis to improve our products and services. This includes asking you questions, participating in surveys, asking you for feedback, asking you to leave feedback and opinions after using or trying our services and products, asking other service providers to carry out marketing and product research for us, to test new technologies in our product that may collect Personal Data to stay ahead of the competition. We store this information based on our “legitimate interest”, so by participating in any of these activities, you agree that this is our legitimate interest. Where possible for the particular occasion or if you object to this legitimate interest, we will remove any identity, contact or mobile device information so that the information cannot be used to identify you and will no longer constitute your Personal Data, and is considered “anonymized”.

CATEGORIES OF PERSONAL DATA

Measurements (only if required by the project)

Identity information (only if required by the project)

Contact information (only if required by the project)

Location information (only if required by the project)

Payment, purchase and transaction data (if available and accessible to us and we need it)

Interaction and activity on social media (only if required by the project)

Internet browsing information (only if required by the project)

Information about the mobile device (only if required by the project)

Correspondence (only if required by the project)

Information about behavior and preferences (only if required by the project)

Legal basis for the processing of Personal Data

  • Fulfillment of legitimate interests (Article 6, paragraph 1, letter “f” of the GDPR)

Data storage period

The duration of the project and the legal retention period specified to protect our intellectual property rights

  1. Collection of information about your device on our website using cookies, pixels, tags and similar technologies

By using the so-called “Facebook pixel”, cookies are set on our website with your consent (see cookies with a provider or designation “Facebook” below in our list of cookies used). In addition to us, Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Facebook) is jointly responsible for the processing of the data associated with the pixel in accordance with Article 26 GDPR. The agreement on which the cooperation with Facebook is based can be found here – https://www.facebook.com/legal/controller_addendum. The Pixel collects data about your use of our website and compares it with data from Facebook to show you advertising tailored to you on the Facebook website. Facebook also uses the data for its own advertising purposes as well as for the advertising purposes of third parties in accordance with Facebook’s privacy policy – https://www.facebook.com/policy.php. There you will also find additional information on how you can exercise your rights before Facebook as a data subject with regard to your data processed by Facebook.

We also use the service to provide personalized “Google Remarketing” ads via a “Floodlight tag”. When performing the service, together with us, responsibility for the protection of Personal Data in accordance with Art. 26 GDPR is assumed by Google Ireland Limited (registration number: 368047) with registered office and management address at 1st and 2nd floor, Gordon House, Barrow Street, Dublin 4, Ireland (Google). The agreement on which the cooperation with Google is based can be found here – https://business.safety.google/intl/en_uk/adsservices/. Google Remarketing collects data about your use of our website and compares it with data from the Google search engine in order to show you advertising tailored to your preferences. Google’s privacy policy can be found here – https://policies.google.com/privacy?gl=BG&hl=en. In case you wish to delete your information in Google – https://policies.google.com/privacy?gl=BG&hl=bg#infodelete.

To make your visits to our website as functional as possible, we use cookies. These include data processing in order to technically ensure optimal operation of the website, as well as other tools to achieve convenient settings for you, to create anonymous statistics and personalized (advertising) content. In the “Detailed selection” section, you can allow or deny the use of the tools.

“Cookies” are small text files that sites can use to make the user experience more efficient.

Cookies are small text files that are stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not cause any damage to your end device and do not contain viruses, trojan horses or other malicious software. The information is stored in the cookie, which leads to a connection with the specific device used. However, this does not mean that we immediately understand your identity.

The law states that we can store cookies on your device if they are absolutely necessary for the operation of this site. All other types of cookies require your consent.

This site uses different types of cookies. Some of them are linked to third-party services that appear on our pages.

You can change or withdraw your consent from our website’s Cookie Policy at any time.

Depending on the category of cookie or other technologies for processing consumption data, the use of cookies and other technologies serves the following purposes:

Technically necessary:

Legal basis:

  • Fulfillment of legitimate interests (Art. 6, para. 1, letter “f” of the GDPR)

 

These are cookies and similar methods without which you cannot use our services (e.g. to display our websites/required functions correctly).

User input to save records across multiple sub-pages (e.g. selecting your preferred store in the Lidl store finder);

Security-related events (e.g. Browsing security for visitors by preventing forgery of site requests

Multimedia content playback data (e.g. playback of user-selected (product) videos).

Our site cannot work without this type of cookies, namely:

NameProviderPurposeValidityType
ASP.NET_SessionIdlidl.media01.euStores the visitor’s session state across page requests.SessionHTTP Cookie

Comfort:

Legal basis:

  • Consent (Art. 6 para. 1, letter “e” of GDPR)

 

When using these techniques, we may take into account your actual or perceived preferences for the convenience of using our website. For example, based on your settings, we may display our website in a language suitable for you. We also avoid showing offers that may not be available in your region.

These are user interface settings that are not associated with a permanent identifier (e.g. active language selection or a specific display of search queries or the maps in the store finder).

The cookies used in this category are:

NameProviderPurposeValidityType
CookieConsentBulkSetting-#consentcdn.cookiebot.comEnables cookie consent across multiple websitesPersistentHTML Local Storage

Statistics:

Legal basis:

  • Consent (Art. 6 para. 1, letter “e” of GDPR)

 

These techniques allow us to compile anonymous statistics about the use of our services in order to design them according to needs. This enables us to determine, for example, how to adapt our website even better to user habits.

Pseudonymized user profiles with information about the use of our website. These include in particular:

  • browser type / version,
  • operating system used,
  • referring URL (the page visited before),
  • host name of the access computer (IP address),
  • server request time,
  • individual user number and
  • triggered website events (browsing behavior).

The IP address is regularly anonymized so that it cannot be traced back to you personally.

We combine the user identification number with other data about you (e.g. name, email address, etc.) with your express consent. Based on the user ID itself, we cannot draw any conclusions about you personally.

Statistical cookies help site owners learn how visitors interact with the sites by collecting and reporting anonymous information.

NameProviderPurposeValidityType
_dc_gtm_UA-#lidl.bgUsed by Google Tag Manager to control loading of Google Analytics tag script.1 денHTTP Cookie

 

Marketing:

Legal basis:

  • Consent (Art. 6 para. 1, letter “e” of GDPR)

 

This enables us to show you relevant advertising content based on the analysis of your behavior. Your user behavior may also be tracked across different websites, browsers or end devices using a user identifier (unique identifier).

Pseudonymized user profiles with information about the use of our website. These include in particular:

IP address,

individual user identification number,

potential product interests,

triggered website events (browsing behavior).

IP addresses are regularly anonymized, so linking to your identity is completely impossible.

We combine the user identification number with your other data (e.g. name, email address, etc.) with your express consent. Based on the user ID itself, we cannot draw any conclusions about you personally. We share the customer identification number and related usage profiles with third parties, as necessary, through the ad network providers.

Where cookies are used based on your consent, you may withdraw / amend your consent to all cookies for which consent is required, at any time with effect for the future without affecting the lawfulness of consent-based processing until revocation.

The types of cookies we use:

Marketing cookies are used to track visitors between different sites. Their goal is to display ads that are relevant and attractive to the individual user, making them more valuable to ad publishers and third-party advertisers.

NameProviderPurposeValidityType
ads/ga-audiencesgoogle.comUsed by Google AdWords to re-engage visitors who are likely to become customers based on the visitor’s online behavior on websites.SessionPixel Tracker

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