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Privacy Policy

Privacy Policy

REGARDING THE PROCESSING OF PERSONAL DATA

1. GENERAL PROVISIONS

This document concerns the privacy policy regarding the processing of personal data within the system of the website www.protestaudio.com (hereinafter referred to as the "website"). The administrator of the website is "CABLE SYSTEMS TECHNOLOGY" AD - a commercial company with its headquarters and management address at 9A Ilievska St., 5300 Gabrovo, Bulgaria, UIC: 205285690 (hereinafter referred to as the "administrator" or "CST" AD).

The administrator will invest and use the necessary resources and efforts to process your data in accordance with Regulation (EU) 2016/679 ("General Data Protection Regulation" or "GDPR") and any other applicable legislation. Since transparency is a fundamental principle of this legal framework, the administrator – through this document – aims to inform you about how personal data of the users of the website are collected, used, transmitted, and protected against infringement when interacting with the website in relation to products and services offered through the website, or otherwise.

The administrator reserves the right to periodically update and amend this privacy policy to reflect changes in how your personal data is processed or changes in the legal framework. In case of such changes, the administrator will publish the updated version of the privacy policy on the website, replacing the old version. In this regard, website users should periodically check the document's content.

2. HOW TO CONTACT THE WEBSITE ADMINISTRATOR?

In addition to the address provided in point 1, you can contact the website administrator using the contact details provided in point 3.2.3 of the website’s terms of use or on the "Contact" page.

In relation to the legislation on personal data protection, "CST" AD is the administrator for the processing of personal data of the website’s users.

The administrator values the opinion of website users and is prepared to provide additional information that may be necessary regarding the processing of personal data. We recommend that users of the website – whenever they find it appropriate – contact the Data Protection Officer of "CST" AD at the email address protest@protestaudio.com.

The Administrator determines the purposes and means of processing the personal data of its clients and informs data subjects that NAP Ready participates in the processing as a third-party data processor, in compliance with the requirements of the General Data Protection Regulation (GDPR).

3. WHAT CATEGORIES OF PERSONAL DATA DO WE PROCESS?

The administrator of the website collects your personal data directly from you, so you decide which information to provide. Below are examples of the information that the website administrator receives from users:

  • When creating a profile on the website, you provide the following information: your email address, first and last name, phone number;
  • When the system allows, you can add additional information to your profile, such as: photo, gender, additional phone number, date of birth, delivery address, additional email address, etc.;
  • When making an order, you provide the following information: first and last name of the recipient, delivery address, billing details, phone number, etc.;

We may offer you to register on the website through your Google profile. If you choose this option, you will be redirected to the "Google LLC" pages, where you will be informed about the transfer of your data to the website administrator. You can review Google's privacy policies by following these links (in English): https://policies.google.com/privacy ("Google")

Additionally, the administrator of the website may collect and subsequently process certain information regarding your browsing behavior on the website to personalize your experience with the website. This is done through the use of "cookies" and/or similar technologies. You can learn more in this regard on the page regarding the cookie and similar technologies policy.

The administrator of the website does not collect or process sensitive data included in the special categories of personal data under the GDPR. Furthermore, the administrator does not intend, aim, or seek to collect or process data of minors (persons under 18 years old).

4. WHAT ARE THE PURPOSES AND LEGAL BASES FOR THE PROCESSING?

The administrator of the website will use your personal data for the following purposes:

  • Providing goods and services offered by "CST" AD for your benefit.

To achieve this general goal, the website administrator may, when necessary, perform the following actions:

  • Create and manage your profile on the website platform;
  • Process orders, including accepting, validating, dispatching, and invoicing them;
  • Resolve issues related to canceled orders or any other actions related to orders and sales of goods or services;
  • Return products in accordance with applicable regulations;
  • Refund the value of products in accordance with applicable regulations;
  • Provide support, including answering customer inquiries related to orders and sales of goods and services through the website.

The processing of your data for these purposes is usually necessary for the conclusion and execution of a sales contract between "CST" AD and you. Additionally, for the fulfillment of these purposes, processing is required under applicable legislation, including tax and accounting laws.

In relation to the above, when using the website, when placing an order for the delivery of a specific product, and when entering into a distance sales contract, when these actions require providing personal data of the website user ("customer", "customer-user" according to the website's terms of use), the user declares that they voluntarily provide their personal data and give consent for them to be processed by the website administrator ("merchant", "seller", "CST" AD according to the website's terms of use) for the stated purposes. The personal data of the website user will be processed by the administrator on three legal bases provided in Article 6, paragraph 1 of the GDPR, namely: (1) performance of contractual relations, (2) performance of the administrator’s legal obligations, and (3) legitimate interests. The personal data of the website user will be processed for the following purposes: (1) in connection with the performance of obligations arising from a distance sales contract, including for sending notifications; (2) in relation to the potential collection of amounts owed by the website user under the sales contract; (3) in connection with the realization of the legitimate rights and interests of "CST" AD; (4) in relation to the fulfillment of legally established obligations of "CST" AD (e.g., tax obligations or obligations to notify administrative authorities).

The administrator of the website will process the personal data of the website user to the extent necessary: full name, date of birth, permanent and/or current address, phone number, email address, any data regarding the user’s obligations under the distance sales contract, including data on individuals connected to the website user in any way (e.g., persons authorized by them in connection with the execution of the contract).

To achieve the stated purposes, the administrator will provide, in accordance with applicable legislation, the personal data of the website user to the following categories of recipients: (1) competent state authorities and institutions in cases provided by law; (2) judicial authorities; (3) companies providing postal and courier services. The decision to provide the personal data of the website user to third parties will be made on a case-by-case basis, depending on the need for its provision. Apart from the above-mentioned purposes, the administrator may use and provide the personal data of the website user for purposes related to statistics, marketing, or advertising.

5. IMPROVING OUR SERVICES

The goal of the administrator is to offer a complete and high-quality service when shopping online. To this end, the website administrator may use certain information regarding your behavior as a buyer, encourage you to fill out satisfaction surveys after completing an order, or conduct market research and studies directly or with the help of partners.

These activities are based on the legitimate interests of "CST" AD in carrying out business activities, while taking measures to protect the fundamental rights and freedoms of users of the website.

6. MARKETING

The website administrator aims to keep users informed about product/service offers that they may be interested in. In this regard, it is possible to send all kinds of messages via electronic communication channels (email, SMS, etc.), containing general and thematic information, information about similar products or products complementary to those purchased by users, information about offers and promotions, information about products added to the sections "Profile/My Cart" or "Profile/Favorites." If users have shown interest in purchasing such goods and/or services, the website administrator may also use other forms of business communication, such as market research and consumer opinion surveys, and provide personalized recommendations through the website.

To provide you with relevant information, the administrator may use certain data regarding your buying behavior (such as viewed or purchased products or items added to your wish list) to create a profile. Such data processing will always be done in compliance with the rights and freedoms of users of the website. Decisions made based on this data will not have any legal consequences for you.

The website administrator will require your prior consent to send marketing messages. You can change your decision at any time regarding this, as well as withdraw your consent to receive such messages by:

  • Changing the settings in your customer profile in the "My Subscriptions" section, when this option is available;
  • Using the "Unsubscribe" link in the messages you receive;
  • Contacting the website administrator using the contact details above.

In certain situations, "CST" AD may base its marketing activities on its legitimate interest in promoting and developing its commercial activity. In any case, when using your data based on these legitimate interests, the website administrator will take the necessary measures to ensure that your fundamental rights and freedoms are not affected. You can always, using the above-mentioned methods, terminate the processing of your personal data for marketing and advertising purposes.

7. PROTECTION OF PUBLIC INTEREST AND THE LEGAL RIGHTS AND INTERESTS OF THE ADMINISTRATOR

In some cases, the processing of personal data by the website administrator is based on legal provisions. There may also be cases where the administrator uses or transmits information to protect the public interest or their own legitimate rights and business activity. These may include:

  • Measures to protect the website and its users from cyberattacks;
  • Measures to detect and prevent fraud attempts, including transmitting information to competent state authorities;
  • Measures to detect and prevent money laundering and terrorist financing;
  • Measures to manage various other risks.

The main reason for such processing is the public interest and the legitimate interests of "CST" AD, related to the protection of its commercial activity. All measures taken in this regard will ensure a balance between the public interest, the interests of "CST" AD, and your fundamental rights and freedoms.

8. HOW LONG WILL YOUR PERSONAL DATA BE KEPT?

As a general rule, your personal data is kept as long as you have a profile on the website. If a sale and/or delivery has been made via the website and an invoice has been issued, the personal data related to its issuance will be kept in accordance with legal requirements for the storage of accounting and business records. You can always request that the website administrator delete certain information or close your profile, and they will respond to this request, but may keep certain information even after the closure of the profile when applicable legislation or their legitimate interests require it.

9. WHO WILL RECEIVE YOUR PERSONAL DATA?

Depending on the case, the website administrator may transmit or provide access to some of your personal data to the following categories of recipients:

  • Companies within the group to which "CST" AD belongs;
  • Courier service providers;
  • Payment and/or banking service providers;
  • Marketing and/or telemarketing service providers;
  • Market research service providers;
  • Insurance companies;
  • IT service providers;
  • Other companies with which "CST" AD may develop joint sales programs for the market of the goods and services offered by "CST" AD;
  • State authorities, when required by law or if necessary to protect our legitimate interests.

Access to your personal data by third parties – private entities will be conducted in accordance with the legal provisions in the field of personal data protection and information confidentiality, as well as based on contracts signed with these entities.

10. TO WHICH COUNTRIES WILL YOUR PERSONAL DATA BE TRANSMITTED?

Currently, the website administrator stores and processes your personal data on the territory of the Republic of Bulgaria. However, it is possible that some of your personal data will be transmitted to entities located in the European Union or outside of it, including countries for which the European Commission has not recognized an adequate level of protection of personal data.

The website administrator takes measures to ensure that any international transfer of personal data is carefully managed to protect your rights and interests. Data transmission to service providers and other third parties will always be protected by contractual obligations and, where appropriate, by other guarantees such as standard contractual clauses issued by the European Commission or certification schemes such as the EU-US Privacy Shield.

You can contact the website administrator at any time using the contact details above to learn which countries your data will be transmitted to and what protective measures the website administrator applies regarding this data transfer.

11. HOW DO WE PROTECT THE SECURITY OF YOUR PERSONAL DATA?

The website administrator is committed to ensuring the security of personal data by implementing appropriate technical and organizational measures in compliance with applicable standards. Your personal data is stored on secure servers, with up-to-date encryption algorithms used, and backup storage is ensured. The site uses SSL technology.

Despite the protection measures for personal data, transmitting information over the internet or through other public networks is not completely secure. There is a risk that the data may be viewed and used by unauthorized third parties. In this sense, the administrator cannot take responsibility for vulnerabilities in systems other than the website’s system.

12. WHAT ARE YOUR RIGHTS?

GDPR recognizes several rights regarding your personal data. You have the right to request access to your data, correction of errors in our records, as well as to raise objections to the processing of your personal data. You also have the right to file a complaint with the competent supervisory authority or in court. Depending on the case, you also have the right to request the deletion of your personal data, the restriction of the processing of your data, and the right to data portability. These rights can be exercised by submitting a written request to the website administrator, including electronically, to the provided email address, in compliance with the provisions of the applicable regulations on personal data. More information about each of the rights can be found in the table below.

Regarding the exercise of your rights, you can contact the website administrator using the contact details above and on the "Contact Us" page. If you wish to exercise these rights, please consider the following:

12.1. Identity of the person contacting the website administrator

All records containing personal data have a certain degree of confidentiality. For this reason, you should send any requests related to these records through the email address associated with your account on the website. Otherwise, the website administrator reserves the right to verify your identity by requesting additional information to confirm it.

12.2. Fees

The website administrator will not charge fees for exercising any rights regarding your personal data unless your request for access to information is unfounded, submitted repeatedly, or is excessive, in which case the website administrator has the right to charge you a reasonable fee. The website administrator will inform you of any applicable fees before processing your request.

12.3. Response time

The website administrator plans to respond to all valid requests within one month, unless the request is particularly complex or if you have made multiple requests, in which case a response will be provided within two months. The website administrator will inform you if it will take longer than one month. You may be asked to clarify what you wish to achieve or the reason for your request. This will help speed up the process and shorten the response time.

12.4. Third-party rights

The website administrator will not respond to requests that unlawfully affect the rights and freedoms of other data subjects.

Corresponding Rights

Description and access

You may request the website administrator to:

  • Confirm whether they are processing your personal data;
  • Provide a copy of your personal data;
  • Provide information regarding your personal data, such as what data is held, how it is used, to whom it is disclosed, whether it is transferred abroad, how it is protected, how long it is retained, what rights you have regarding it, how you can file a complaint, where your data was obtained from (as far as this information was not already provided through this document).

Correction

You may request the website administrator to correct or supplement any inaccurate or incomplete personal data. The website administrator may attempt to verify the accuracy of the data before making corrections.

Deletion

You may request the website administrator to delete your personal data when (alternatively):

  • It is no longer necessary for the purposes for which it was collected;
  • You have withdrawn your consent (if processing is based on consent);
  • You exercise your legal right to object;
  • The data has been processed unlawfully;
  • There is a legal obligation in this regard.

The website administrator is not required to honor your request for deletion if the processing is necessary (alternatively):

  • To fulfill a legal obligation;
  • To establish, exercise, or defend a legal claim.

There may also be other circumstances where the website administrator is not obliged to comply with your request for deletion. Additionally, before exercising your right to request the deletion of personal data, you should download from your account on the website and keep all documents related to orders made through the website, whether the invoicing was done to you or to another natural or legal person (such documents may include invoices, warranty certificates, etc.). If you do not do this, you will lose access to these documents, and it is possible that the website administrator will not be able to provide them to you as the data deletion process and account deletion are irreversible.

Restriction of Data Processing

You may request the website administrator to restrict the processing of your personal data when (alternatively):

  • The accuracy of the data is disputed (see above regarding the right to request correction), to allow for verification of its accuracy;
  • The processing is unlawful, but you do not wish for the data to be deleted;
  • The data is no longer necessary for the purposes for which it was collected, but the website administrator still needs it to establish, exercise, or defend a legal claim;
  • You have already exercised the right to object and are verifying whether our interests still dominate.

The website administrator may continue to use your personal data if restricted (alternatively):

  • If we have your consent;
  • To establish, exercise, or defend a legal claim;
  • To protect the rights of "CST" AD or another natural or legal person.

Data Portability

You may request the website administrator to provide your personal data in a structured, commonly used, and machine-readable format or request that it be directly transferred to another data controller when (alternatively):

  • The processing is based on your consent or a contract with you;
  • The processing is carried out by automated means.

Right to Object

You may object at any time and for reasons related to your specific situation, against the processing of your personal data based on the legitimate interests of the website administrator when you believe that your fundamental rights and freedoms outweigh these interests.

Additionally, you may object at any time to the processing of your data for direct marketing purposes (including profiling) without providing any reason, in which case processing will be stopped as soon as possible.

Automated Decisions

You may request the website administrator not to be subject to a decision based solely on automated processing if that decision (alternatively):

  • Produces legal effects concerning you;
  • Affects you significantly and similarly.

This right does not apply if the decision resulting from automated processing (alternatively):

  • Is necessary for the website administrator to enter into or perform a contract with you;
  • Is authorized by law and there are adequate safeguards for your rights and freedoms;
  • Is based on your explicit consent.

Complaints

You have the right to lodge a complaint with the national supervisory authority regarding the processing of your personal data. In the Republic of Bulgaria, the contact details for the supervisory authority are as follows:

Personal Data Protection Commission

Sofia 1592, Prof. Cvetan Lazarov Blvd. No. 2

Phone: +359 2 91 53 519 or +359 2 91 53 555

Email: kzld@cpdp.bg

Website: https://www.cpdp.bg/

Without prejudice to your right to contact the supervisory authority at any time, you have the option to contact the website administrator in advance, and we will make every effort to resolve any issues by mutual agreement.

We remind you that you can contact the Data Protection Officer of "CST" AD at any time by sending your request or inquiry to the following email address: protest@protestaudio.com