1. WHO WE ARE. We are Moderato BG LTD, and we process your personal data as controllers. This means that we are responsible for how we process and protect your data.
2. WHAT WE USE YOUR DATA FOR. We will use your data
(collected online or in person), among other purposes, to manage your registration as a user, to manage your purchases of products or services, to respond to your queries, and, if you wish, to send you our customized communications.
3. WHY WE USE YOUR DATA. We have legal standing to process your data for various reasons. The main reason is that we need to process your data to perform the contract that you accept with us when you register and when you make a purchase or enjoy any of our services or functionalities. We also use your data for other reasons, for example, to respond to your queries or to send you newsletters that you have asked to receive from us.
4. WHO WE SHARE YOUR DATA WITH. We share your data with service providers who provide us with assistance or support , third party providers, both inside and outside the European Union. See more.
5. YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In certain cases, you are also entitled to other rights, such as, for example, to object to us using your data, or to transferring your data, as explained in depth below We encourage you to read our full Privacy and Cookies Policy below to understand in depth the manner in which we will use your personal data and your rights over your data.
BEFORE YOU START …
• In this Privacy and Cookies Policy, you will find all relevant information applicable to our use of our users' and clients' personal data, regardless of the channel or means (online or in person) of Moderato BG LTD in Bulgaria that you use to interact with us.
• We are transparent about what we do with your personal data, to help you to understand the implications of the way in which we use your data, and the rights you are entitled to in relation to your data:
o We permanently make available for you all the information included in this Privacy and Cookies Policy, that you can check when you consider appropriate, and in addition,
o you will also find further information on how we use your data as you interact with us.
• These are some terms we regularly use in this Privacy and Cookies Policy:
o When we speak about our Platform, we refer, in general, to any of the channels or means, digital or in person, you may have used to interact with us. The main ones are:
§ Our Website,
§ Our Moderato App, this is, including both the mobile application you installed on your mobile device and others we may use in our stores.
§ In person, in any of our Moderato Store.
1. WHO IS THE CONTROLLER OF YOUR DATA?
Your data controllers are:
§ Moderato BG LTD, company currently operating in Bulgaria the sale of Moderato products
Postal address: Court Yard, village Krumovo 4112,Bulgaria
E-mail: of Data Protection Officer:
2. WHY WE PROCESS YOUR PERSONAL DATA
Depending on the purpose for which we process your data from time to time, as explained above, we need to process one or other data, which will in general be, depending on each case, as follows:
§ your identity data (for example, your name, surname, language and country from which you interact with us, contact data, etc.);
§ economic and transactions information (for example, your payment or card data, information on your purchases, orders, returns, etc.);
§ connection, geolocation and/or browsing data (if you interact with us from your mobile phone, for example);
§ commercial information (for example, if you have subscribed to our newsletter),
§ information about your tastes and preferences.
Remember that, when we ask you to fill in your personal data to give you access to any functionality or service of the Platform, we will mark certain fields as compulsory, since this is information that we need to be able to provide the service or give you access to the functionality in question. Please take into account that, if you decide not to make such data available to us, you may be unable to complete your user registration or may not be able to enjoy those services or functionalities.
Depending on how you interact with our Platform, i.e., depending on the services, products or functionalities that you wish to enjoy, we will process your personal data for the following purposes:
3. HOW WE ARE LEGALLY PERMITTED TO PROCESS YOUR DATA?
The legal terms on which we are permitted to process your personal data also depends on the purpose for which we process them, as explained in the following table:
3. HOW LONG WILL WE KEEP YOUR DATA?
The time for which we will keep your data will depend on the purposes for which we process them, as explained below:
Notwithstanding the fact that we will process your data for the time strictly necessary to achieve the purpose in question, we will subsequently keep them duly stored and protected for the time during which liability may arise for their processing, in compliance with legislation in force from time to time. Once each of the potential actions is time-barred we will proceed to delete the personal data.
3. DO WE SHARE YOUR DATA WITH THIRD PARTIES?
To achieve the purposes mentioned in this Privacy and Cookies Policy, we must give access to your personal data to entities of Moderato BG LTD and to third parties that provide us with support in the services that we offer your, i.e.:
§ financial institutions,
§ anti-fraud detection and prevention entities,
§ technological service providers,
§ logistic, transport and delivery partners and service providers,
§ providers of customer support related services,
§ advertising and marketing related partners and service providers.
For service efficiency purposes, some of these providers are located in territories outside the European Economic Area that do not offer a level of data protection comparable to that of the European Union, as the United States of America. In such cases, we inform you that we will transfer your data with adequate safeguards and always keeping your data safe:
§ Some providers are certified Privacy Shield, which certification you may consult through the following link:
§ With other providers, we have agreed Standard Contractual Clauses approved by the EU Commission, the content of which you may consult through the following link:
6. WHAT YOUR RIGHTS ARE WHEN MAKING YOUR DATA AVAILABLE TO US
We undertake to keep your personal data confidential and to ensure that you may exercise your rights. Bearing that in mind, we agreed that you may exercise your rights free of charge by writing us an e-mail to a single e-mail address (firstname.lastname@example.org), simply informing us of the reason for your request and the right that you wish to exercise. If we consider this necessary to be able to identify you, we may request you to provide a copy of a document evidencing your identity.
In particular, notwithstanding the purpose or legal basis we use to process your data, you have the following rights:
• To request access to your personal data that we hold. We remind you that where you are a Platform registered user you may also consult this information in the relevant section of your online account.
• To request that we rectify the personal data that we hold. Please bear in mind that if you are a registered user on the Platform, you may also access the relevant personal data section of your online account to change or update your personal data. In any case, please take into account that, on actively making your personal data available to us through any procedure, you guarantee that they are true and accurate and you undertake to notify to us any change or modification of your data. You will be liable for any loss or damage caused to the Platform or to the person responsible for the Platform or to any third party by reporting erroneous, inaccurate or incomplete information in the registration forms. Please remember that, as a general rule, you must provide us only with your own data, not with those of third parties, other than to the extent otherwise permitted in this Privacy and Cookies Policy.
• To request that we erase your personal data to the extent that they are no longer necessary for the purpose for which we need to keep processing them, as we have explained above, or when we are no longer legally permitted to process them.
• To request that we cancel or limit the processing of your personal data, which entails that in certain cases you can request us to temporally suspend the processing of the data or that we keep them longer than necessary.
If you have given us your consent to process your data for any purpose, you also have the right to withdraw such consent at any time. Some of the circumstances in which you may withdraw your consent are detailed in section 2 where we explain for which purposes we process your data.
When we are legally permitted to process your data due to your consent or to for the purposes of a contract, as explained in section 3, you will also have the right to request the portability of your personal data. This means that you will have the right to receive the personal data that you made available to us in a structured, commonly used and machine-legible format, to be able to transmit them to another entity directly without impediments on our part.
In addition, where the processing of your data is based on our legitimate interest, you will also have the right to object to the processing of your data.
Finally, we inform you that you have the right to file a claim before the responsible data protection regulatory authority, in particular, before the Spanish Data Protection Agency (Agencia Española de Protección de Datos) (https://www.agpd.es/portalwebAGPD/index-ides-idphp.php).
7. WHAT HAPPENS WHEN YOU PROVIDE US WITH DATA OF THIRD PARTIES?
We offer functionalities or services that require us to process the personal data of a third party that you must provide, such as in the case of activation and sending of the Gift Voucher or the management of the application for the Gift Voucher. If you provide us with personal data of third parties, you confirm that you informed them of the purposes and of the manner in which we need to process their personal data.
We may amend the information contained in this Privacy and Cookies Policy when we consider this appropriate. Should we do so, we will notify you by various procedures through the Platform (for example, through a banner, a pop-up or a push notification), or we may even send you a notice to your e-mail address when the change in question is relevant to your privacy, for you to be able to review the changes, assess them and, as the case may be, object or unsubscribe from ay service or functionality. In any case, we suggest you to review this Privacy and Cookies Policy from time to time in case minor changes are made or we make any interactive improvement, taking the opportunity that you will always find it as a permanent point of information on our Website and our App.