– VISITORS OF OUR WEBSITE WWW.ENEADA.EU;
– EVERY INDIVIDUAL WHO BUYS A SERVICE THROUGH OUR WEBSITE WWW.ENEADA.EU;
– EVERY INDIVIDUAL WHO USES A SERVICE PAID THROUGH OUR WEBSITE WWW.ENEADA.EU;
– EVERY INDIVIDUAL WHO USES A SERVICE SPECIFIED ON OUR WEBSITE WWW.ENEADA.EU;
– EVERY INDIVIDUAL WHO CONTACTS US THROUGH THE CONTACT FORM OF OUR WEBSITE WWW.ENEADA.EU;
– EVERY INDIVIDUAL WHO HAS SUBSCRIBED FOR OUR NEWSLETTER.
- Who are we?
We are “ENEADA BG” ЕООD, entered in the Register of Companies with UIN 175418840, with its seat and address of management in Sofia, region Lozenets, 2 Plana planina Street, entrance B.
We collect and process your personal data lawfully, in good faith and in a transparent manner.
You can contact us through the mobile telephone number 088 426 5217, as well as you can write to us at the email address firstname.lastname@example.org.
- Personal data that is processed
“ENEADA BG” ЕООD processes personal data individually or along with other administrators. Depending on the specific objectives and grounds “ENEADA BG” ЕООD processes the data specified below separately or in a combination.
4.1. DATA THAT WE PROCESS WHEN YOU VISIT OUR WEBSITE WWW.ENEADA.EU
When you visit our website www.eneada.eu, irrespective of whether you decide to buy one of the services that we offer, it is possible that we collect data for your use of the website through the so called “cookies”.
WHAT ARE COOKIES?
Cookies are small pieces of information sent from the pages of a website to your browser and stored on your device.
There are two types of cookies – persistent cookies and session cookies. Persistent cookies are stored as a file on your device for an unlimited period of time. Session cookies are placed temporarily on your device when you visit our website www.eneada.eu but they disappear when you close a page. This means that they are not stored permanently on your device.
WHAT TYPES OF COOKIES DO WE USE?
We use three types of cookies:
These cookies are necessary in order our website www.eneada.eu to perform its functions. We use these cookies to provide our services and maintain the security of our services. These cookies are stored for an unlimited period of time on your device.
Functionality cookies allow us to store your preferences as well as other personal settings of yours. Functionality cookies are stored temporarily on your device.
These are cookies used for web advertising..
SOCIAL NETWORK COOKIES
When you use the button for the social network Facebook, this activity of yours will be stored by this social network.
THIRD PARTY COOKIES
We use third party cookies which help us to perform our activity, to research the market and to improve the functionality of our website www.eneada.eu. The third party cookies, which we use, are listed below. Some of these cookies can be disabled through the general settings of your browser. Regarding other cookies you have to visit the respective websites and to follow the instructions which are provided.
– We use Google Analytics to generate statistics about the traffic of our website www.eneada.eu and the sources of traffic, as well as about conversion of measures and sales. See here regarding cancellation: https://support.google.com/analytics/answer/181881.
HOW CAN COOKIES BE DELETED?
You can choose yourself to accept cookies or not to accept cookies. If you want to know when your device receives a cookie/cookies, you can set your browser to inform you about it. Thus you are able to accept or decline a given cookie. Your device can be set to decline all cookies. If you want to know how to do that, visit www.aboutcookies.org. Please consider that the changes in your browser through which the cookie function is disabled shall prevent а part/parts of our website www.eneada.eu to function properly.
All personal data that we collect through using cookies are stored up to the moment at which you change your cookie preferences and stop (forbid) the use of the relevant category of cookies that collects personal data.
4.2. DATA WE PROCESS AT CONCLUSION AND EXECUTION OF A SERVICE AGREEMENT
When you buy any service on our website www.eneada.eu, you conclude an agreement with us for the provision of this service.
When buying any service on our website www.eneada.eu, we collect from you and process the following categories of personal data:
– YOUR NAME;
– YOUR EMAIL ADDRESS;
– YOUR PHONE NUMBER;
– YOUR GENDER;
– YOUR DATE OF BIRTH, MONTH OF BIRTH AND YEAR OF BIRTH;
– YOUR EXACT TIME OF BIRTH;
– THE COUNTRY IN WHICH YOU LIVE;
– THE CITY/THE VILLAGE WHERE YOU LIVE;
– TWO RECENT PHOTOS OF YOU;
– YOUR EDUCATION;
– YOUR FIELD OF WORK;
– YOUR MARITAL STATUS;
– WHO DO YOU LIVE WITH;
– WHETHER YOU HAVE ANY CHILDREN;
– WHETHER YOU WOULD LIKE TO HAVE CHILDREN;
– HOW TALL ARE YOU;
– WHAT IS YOUR WEIGHT (IN KILOGRAMS);
– WHAT IS THE COLOUR OF YOUR EYES;
– WHAT IS THE COLOUR OF YOUR HAIR;
– WHETHER YOU SMOKE;
– WHETHER YOU USE ALCOHOL;
– WHETHER YOU DO SOME SPORTS;
– WHETHER IT IS IMPORTANT FOR YOU TO SHARE VERY PERSONAL MATTERS WITH YOUR PARTNER;
– WHETHER IT IS IMPORTANT FOR YOU TO SPEND AS MUCH TIME AS IT IS POSSIBLE WITH YOUR PARTNER;
– WHETHER YOU STILL NEED YOUR SPACE EVEN IF YOU ARE IN A CLOSE RELATIONSHIP;
– WHETHER YOU LIKE TO CARRY ON INTENSE INTELLECTUAL CONVERSATIONS WITH YOUR PARTNER;
– WHAT YOU LIKE DOING ON SATURDAY NIGHT;
– WHETHER YOU THINK THAT THE UNPREDICTABLE SITUATIONS ARE EXHILARATING;
– WHETHER YOU DO THINGS ON THE SPUR OF THE MOMENT;
– WHETHER YOU ALWAYS LOOK FOR NEW EXPERIENCES;
– WHETHER YOU CONSIDER (AND RECONSIDER) THOUROUGHLY EVERY OPTION BEFORE MAKING A PLAN;
– WHETHER YOU THINK THAT PEOPLE SHOULD BEHAVE ACCORDING TO ESTABLISHED STANDARDS OF PROPER CONDUCT;
– WHETHER YOU THINK THAT THE ESTABLISHED CUSTOMS NEED TO BE RESPECTED AND PRESERVED;
– WHETHER YOU LIKE TO WORK IN A STRAIGHTFORWARD PATH TOWARD COMPLETING A TASK;
– WHETHER WHEN READING YOU ENJOY IT WHEN THE WRITER TAKES A SIDETRACK TO SAY SOMETHING BEAUTIFUL OR MEANINGFUL;
– WHETHER YOU ARE SENSITIVE TO PEOPLE’S FEELINGS AND NEEDS;
– WHETHER AFTER WATCHING AN EMOTIONAL FILM YOU STILL FEEL MOVED BY IT SEVERAL HOURS LATER;
– WHETHER REGARDLESS OF WHAT IS LOGICAL YOU GENERALLY LISTEN TO YOUR HEART WHEN MAKING IMPORTANT DECISIONS;
– WHAT IS YOUR PREFERRED DISTANCE OF RESIDENCE OF A MATCH TOWARD YOURS (IN KILOMETERS);
– WHAT IS YOUR PREFERRED HEIGHT RANGE OF A MATCH (IN CENTIMETERS);
– WHAT IS YOUR PREFERRED AGE RANGE OF A MATCH;
– WHAT IS YOUR PREFERRED WEIGHT OF A MATCH (IN KILOGRAMS);
– WHAT IS YOUR PREFERRED STAR SIGN OF A MATCH;
– WHETHER YOU MIND IF THE PARTNER HAS CHILDREN;
– WHETHER YOU MIND IF THE PARTNER WANTS TO HAVE CHILDREN IN THE FUTURE;
– WHETHER YOU MIND IF THE PARTNER SMOKES;
– WHAT LEVEL OF EDUCATION OF YOUR PARTNER YOU ARE WILLING TO CONSIDER;
– WHAT INTEREST OR ACTIVITIES YOU WOULD LIKE TO SHARE WITH YOUR FUTURE PARTNER;
– THE ANSWERS OF THE CURRENT TEST THAT YOU FILL IN ON THE PAGE “CURRENT TEST”OF OUR WEBSITE WWW.ENEADA.EU;
– CONVENIENT FOR YOU DATE AND TIME FOR A CONSULTATION.
4.3. OTHER PERSONAL DATA OF YOURS THAT WE PROCESS DURING THE PROCESS OF PROVISION OF OUR SERVICE/SERVICES:
– DATA COLLECTED DURING PAYMENT ON YOUR BEHALF;
– PAYMENT INFORMATION COLLECTED DURING PROCESSING OF A PAYMENT REQUESTED BY YOU;
– DATA PROVIDED DURING PARTICIPATION IN GAMES, LOTTERIES AND/OR OTHER SEASONAL OR PROMOTIONAL CAMPAIGNS THAT ARE ORGANIZED BY “ENEADA BG” EOOD AND ADDRESSED TO THE PUBLIC, INCLUDING THROUGH ANY SOCIAL NETWORK;
– PERSONAL IDENTITY NUMBER OR FOREIGNER IDENTITY NUMBER;
– YOUR PERMANENT ADDRESS ACCORDING TO YOUR IDENTITY DOCUMENT;
– YOUR CITIZENSHIP ACCORDING TO YOUR IDENTITY DOCUMENT;
– THE NUMBER OF YOUR IDENTITY DOCUMENT;
– THE DATE OF ISSUING OF YOUR IDENTITY DOCUMENT;
– THE ISSUER OF YOUR IDENTITY DOCUMENT;
– THE VALIDITY OF YOUR IDENTITY DOCUMENT;
– WHEN THE PAID SERVICE INCLUDES VIDEO RECORDING OF THE EXPERIENCE AND A USER WANTS TO BE VIDEO RECORDED, THE PERSONAL DATA THAT WE PROCESS INCLUDES THIS VIDEO RECORDING;
– WHEN THE PAID SERVICE INCLUDES PHOTO RECORDING OF THE EXPERIENCE AND A USER WANTS TO BE PHOTO RECORDED, THE PERSONAL DATA THAT WE PROCESS INCLUDE THIS PHOTO RECORDING;
The legal grounds for processing the categories of personal data specified above is concluding and executing of a service agreement.
4.4. DATA THAT WE PROCESS FOR THE PURPOSES OF OUR NEWSLETTER
Through our website www.eneada.eu we offer at your disposal an option to send to you current our service offers and information when you subscribe for our newsletter. For this purpose it is necessary to provide only your email address (including when we have already have it and we process it for whatever purpose specified above). We process this category of personal data on the grounds of our legitimate interest to inform our customers and potential customers about current products, offers and promotions that we offer. We process this data on the grounds of your consent to receive newsletters that you have confirmed by typing your email address and clicking on the virtual button “I’m joining!”.
- Purposes and legal basis for processing personal data
5.1. “ENEADA BG” EOOD processes your data for the following purposes:
5.1.1. In order to execute contractual obligations and services, as well as regarding customer relationship management in reference to services provided by “ENEADA BG” EOOD:
– updating your personal data provided during registration/concluding an agreement for use of the services of “ENEADA BG” EOOD;
– checking the type of services that are registered and used regarding your request/ complaint/argument or with the purpose of protecting customers and “ENEADA BG” EOOD from fraud and abuse caused by third parties;
– providing information for services used;
– treating received warnings, objections, complaints, performing checks, giving feedback;
– technical support for access to the website www.eneada.eu;
– resolving disputes at the competent authority (court, arbitration, conciliation commission, administrative authorities etc.) in reference to the activity of “ENEADA BG” EOOD;
– management of anti-fraud activities; “ENEADA BG” EOOD processes personal data during execution of activities regarding prevention, detection, investigation and management of fraud.
5.1.2. During fulfilling legal obligations “ENEADA BG” EOOD processes your data for the following purposes:
– providing information about a customer and about services used by him regarding an inquiry/request/inspection by a competent authority;
– issuing invoices if it is applicable for a specific service.
5.1.3 “ENEADA BG” EOOD processes the relevant data provided with the consent of a customer regarding its processing, for the following purposes:
– for receiving email messages (regarding the services used by you) at an email specified by you;
– for including your name, photos, video and other forms of your consent in advertising and media publications of “ENEADA BG” EOOD (or of its partners) as a result of your participation in lotteries and games or in social networks.
5.1.4. “ENEADA BG” EOOD processes your data also for the purposes of the following legitimate interests:
– preparation and storing statistical information and check up in aggregated form – “ENEADA BG” EOOD makes the specified analysis for the purpose of developing and refining the services offered and to improve customer service;
– when data is provided to third parties: during execution of legal or contractual obligations of “ENEADA BG” EOOD or other valid legal grounds.
- Categories of third parties that receive personal data
According to the requirements of Regulation ЕС 2016/679, “ENEADA BG” EOOD has the right to reveal personal data that it processes to the following categories of receivers:
– to the individuals to which the data refers;
– to third parties, individuals, legal entities, public authorities, institutions and establishments during execution of legal or contractual obligations of “ENEADA BG” EOOD or other valid legal grounds, for example detection, prevention or performing other activities regarding fraud, technical problems or the ones related to security;
– to banks, providers of payment services and/or system operators specified in Law on Payment Services and Payment Systems that are payment processors of the payments made by you;
– to individuals and/or legal entities that after assignment by “ENEADA BG” EOOD support equipment and software used for processing your personal data;
– to individuals and/or legal entities that provide services regarding organizing, storing, indexing and destructing archives on a hard copy and/or electronic media;
– to subcontractors of “ENEADA BG” EOOD that are processors of personal data.
The processors of personal data perform processing according to an agreement/other legal act that is concluded with “ENEADA BG” EOOD and according to the instructions of “ENEADA BG” EOOD. The subcontractors of “ENEADA BG” EOOD provide enough guarantees for applying appropriate technical and organizational measures for observing Regulation 2016/679.
- Do we export your data out of the European Union?
The Rocket Science Group LLC, the organization that owns the platform for management of email campaigns that we use is in the USA. That means that your personal data that we collect and process for the purposes of sending newsletters is stored and processed on the servers of the platform for management of email campaigns that are on the territory of the USA. Pursuant to Article 1 of the RESOLUTION FOR EXECUTION (ЕС) 2016/1250 OF THE COMMISSION dated 12 July 2016, the USA is a country that guarantees adequate level of protection of personal data that is submitted to organizations in the USA included in the list to the EU-U.S. Privacy Shield that is powered and provided for public access by the Department of Commerce of the USA. The Rocket Science Group LLC is included in this list and that provides protection of your personal data in the USA in accordance with all applicable requirements of the European legislation.
- А term for storing your personal data
The term for storing your personal data depends on the purposes of processing for which it is collected:
– the personal data, that is processed for the purpose of providing the services specified on our website www.eneada.eu , is stored for a period of one year as of the date of concluding the service agreement;
– the personal data, that is processed for the purpose of issuing accounting/financial documents, is stored for at least five years after the expiry of the limitation period for the repayment of a public debt unless a longer term is envisaged in the applicable legislation;
– “ENEADA BG” EOOD may store some of your personal data for a longer period up to the expiry of the relevant limitation period, with the purpose of protection in case of possible claims of customers in reference to execution of services/cancellation of registration/a service agreement etc. as well as for a longer period in case of litigation that is already filed in reference to the above mentioned up to its resolution through a final court decision entered into force;
– personal data for which there is not explicit legal obligation for storing shall be deleted after achieving the purposes for which personal data is collected and processed;
– any record of a phone call is stored up to one month as of the date of the made phone call.
- Security measures of “ENEADA BG” EOOD for protection of personal data
Protection of information and data of the customers is a main priority of “ENEADA BG” EOOD. The company constantly applies and updates technical and organizational measures for providing protection of the data of customers. Regular inspections on all procedures and rules for collecting, storing and processing data are performed.
10. Your rights in reference to processing your personal data
As a subject of your personal data you have a number of rights. The description of these rights and the order for their exercising is specified below in this section.
You can exercise all rights specified below through a written notification sent to “ENEADA BG” EOOD in a free text form. This written notification is submitted by you in person or by an individual who is explicitly authorized by you.
You can send the relevant notification to our email address email@example.com. When the notification is sent electronically, it has to be signed through an electronic signature. We shall respond to your notification as soon as it is possible as this period shall not be longer than 20 (twenty) working days as of the date of receiving your notification.
Please have in mind that we shall not process a request in a notification sent by you if we cannot be sure that this notification is actually submitted by you. That is why in certain cases it is possible for us to ask you to submit your notification in our office so that we can identify you.
10.1. RIGHT OF ACCESS TO YOUR PERSONAL DATA
You have the right to receive information from us regarding our processing of your personal data. If we process your personal data, you have the right to get access to the data itself as well as information about:
– THE CATEGORIES OF PERSONAL DATA THAT IS PROCESSED;
– THE PURPOSES OF PROCESSING;
– THE RECEIVERS OR THE CATEGORIES OF RECEIVERS BEFORE WHICH THE PERSONAL DATA IS REVEALED OR SHALL BE REVEALED, ESPECIALLY THOSE ONES IN THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS;
– WHEN IT IS POSSIBLE, THE ENVISAGED TERM DURING WHICH THE PERSONAL DATA SHALL BE STORED, AND IF IT IS NOT POSSIBLE THE CRITERIA USED FOR DEFINING THIS TERM;
– THE EXISTENTENCE OF A RIGHT TO REQUIRE FROM US CORRECTION OR DELETION OF PERSONAL DATA OR LIMITATION OF PROCESSING THE PERSONAL DATA RELATED TO YOU OR THE EXISTENCE OF A RIGHT TO REQUIRE INFORMATION FROM US SO THAT YOU CAN OBJECT TO SUCH PROCESSING;
– YOUR RIGHT FOR COMPLAINGT TO SUPERVISORY AUTHORITY;
– WHEN PERSONAL DATA IS NOT COLLECTED BY YOU, ALL AVAILABLE INFORMATION FOR ITS SOURCE;
– THE EXISTENCE OF AUTOMATED MAKING OF A DECISION INCLUDING PROFILING AS WELL AS ADDITIONAL INFORMATION ABOUT IT IN CASES ENVISAGED BY LAW.
We shall provide a free copy of your personal data that we process as well as the information specified above. If you want any additional copies of data, it is possible that we specify a reasonable fee for each additional copy on the grounds of any administrative expenses for its creation.
10.2. RIGHT OF CORRECTION
If you think that the personal data that we process is not correct, you have the right to request from us its correction without any unnecessary delay. When the processed personal data is not complete, you have the right to request its completion as the purposes of processing has to be noted.
10.3. RIGHT OF WITHDRAWAL OF CONSENT
When we process your personal data on the grounds of a consent provided by you, you can withdraw the consent provided at any time. After the withdrawal of the consent, we shall stop the activities regarding processing of your personal data on the grounds of your consent. In this case the withdrawal of the consent shall not affect the legality of processing on the grounds of your consent before the consent is withdrawn.
Nevertheless, it is possible that we continue to process the same personal data as far as another grounds (different from consent) is available for processing the data.
10.4. RIGHT FOR OBJECTION TO THE PROCESSING
You have the right to object to the processing of your personal data in the cases in which we process it on the grounds of public interest or on the grounds of our legitimate interests when you think that in your specific case this processing is not compatible with the protection of your interests, rights and freedom. In such cases if we cannot prove that there are legitimate grounds for processing that have priority over your interests, rights and freedom or that the processing is necessary for establishment, exercising or protection of legal claims, we shall stop the processing of this personal data.
When we process your personal data for the purposes of direct marketing, you can object to this data processing. After your written objection, we shall immediately stop the processing of your personal data. Other than through written objection, you can inform us about your wish for us to stop the processing for the purposes of sending newsletters through unsubscribing from the subscription for receiving newsletters through the link for unsubscribing that is a part of every email by which we send newsletters to you.
10.5. RIGHT OF DELETION OF PERSONAL DATA
You have the right to want from us deletion of your personal data without unnecessary delay, and we are obliged to delete your personal data without unnecessary delay, when any of the grounds specified below is applicable:
– THE PERSONAL DATA IS NO MORE NECESSARY FOR THE PURPOSES FOR WHICH IT IS COLLECTED AND/OR PROCESSED IN OTHER WAY;
– YOU WITHDRAW YOUR CONSENT FOR PROCESSING THE DATA WHEN THE DATA IS PROCESSED ON THE GROUNDS OF YOUR CONSENT AND THERE IS NO OTHER LEGAL GROUNDS FOR THE PROCESSING;
– THE PERSONAL DATA IS PROCESSED UNLAWFULLY;
– THE PERSONAL DATA HAS TO BE DELETED WITH THE PURPOSE OF KEEPING OUR LEGAL OBLIGATION.
Exceptions from the rule
Your right to require deletion of your personal data is not applied (which means we do not have an obligation for deletion of the data) if the processing of personal data is necessary:
– FOR EXERCISING THE RIGHT OF FREEDOM OF EXPRESSION AND THE RIGHT OF INFORMATION;
– FOR KEEPING OUR LEGAL OBLIGATION THAT REQUIRES PROCESSING OR FOR EXECUTION OF A TASK REGARDING PUBLIC INTEREST OR WHEN EXERCISING OFFICIAL AUTHORITIES THAT ARE GIVEN TO “ENEADA BG” EOOD;
– BECAUSE OF REASONS OF PUBLIC INTEREST IN THE AREA OF PUBLIC HEALTH PURSUANT TO ARTICLE 9, PARAGRAPH 2, LETERS G) AND H), AS WELL AS ARTICLE 9, PARAGRAPH 3 OF THE GENERAL DATA PROTECTION REGULATION;
– FOR THE PURPOSES OF ARCHIVING FOR PUBLIC INTEREST, FOR SCIENTIFIC AND HISTORICAL RESEARCH OR FOR STATISTICAL PURPOSES ACCORDING TO ARTICLE 89, PARAGRAPH 1 OF THE GENERAL DATA PROTECTION REGULATION AS FAR AS THERE IS POSSIBILITY FOR THE DATA DELETION TO RESULT IN IMPOSSIBLE OR DIFFICULT ACHIEVEMENT OF THE PURPOSES FOR THIS PROCESSING;
– FOR ESTABLISHING, EXERCISING AND PROTECTION OF LEGAL CLAIMS;
10.6. RIGHT OF LIMITATION OF THE PROCESSING
In the cases specified below you have the right to request from us to stop temporarily any other processing of your personal data excluding its storing:
– WHEN YOU CONTEST THE ACCURACY OF YOUR PERSONAL DATA – FOR A TERM THAT ALLOWS US TO CHECK THE ACCURACY OF THE PERSONAL DATA;
– WHEN THE PROCESSING IS ILLEGAL BUT YOU DO NOT WANT YOUR PERSONAL DATA TO BE DELETED, AND YOU WANT TO LIMIT ITS USE INSTEAD;
– WHEN WE DO NOT NEED ANY MORE YOUR PERSONAL DATA FOR THE PURPOSES OF THE PROCESSING BUT IT IS REQUIRED BY YOU FOR ESTABLISHING, EXERCISING OR PROTECTION OF LEGAL CLAIMS;
In the cases specified above we can process the relevant personal data, other than its storing, only with your consent or for establishing, exercising or protection of legal claims or for protection of the rights of other individual or because of important grounds of public interest for the Republic of Bulgaria or the European Union.
10.7. RIGHT OF DATA PORTABILITY
You have the right of receiving your personal data that you have provided to us in a structured widely used format that is suitable for machine reading, and you have the right of transferring this data to another administrator without any hindering on our behalf, when:
WE PROCESS THE DATA ON THE GROUNDS OF YOUR CONSENT OR WHEN THE DATA PROCESSING IS NECESSARY FOR THE EXECUTION OF AN OBLIGATION UNDER AN AGREMEENT BETWEEN YOU AND “ENEADA BG” EOOD
THE PROCESSING IS DONE IN AN AUTOMATED MANNER
For the purposes of exercising your right of data portability, you have the right to get direct transfer of your personal data from “ENEADA BG” EOOD to other administrator only as far as it is technically feasible.
10.8. RIGHT OF A CLAIM TO A SUPERVISORY AUTHORITY
If you think that we process your personal data in breach of the provisions of the applicable legislation, including but not limited to the General Data Protection Regulation and the Consumer Protection Act, you have the right of submitting a complaint to the supervisory authority in the Member State of the European Union at your permanent place of residence, place of work or place of the alleged infringement.
In the Republic of Bulgaria the competent supervisory authority is
COMMISSION FOR PERSONAL DATA PROTECTION
Address: Sofia 1592, 2 Prof.Tsvetan Lazarov Blvd.
Telephone number: 02 915 3 518
Email address: firstname.lastname@example.org