Privacy Policy

Privacy Policy

"VRS ART" Ltd.

(Notice regarding the processing of personal data)

Personal data administrator:

1. Name: “VRS ART” Ltd.

2. UIC: 207765236

3. Registered office and address of management: BULGARIA, Troyan, block 2, entrance J, floor 1

4. Telephone: +359876345722

5. Email address: crochetandprint@abv.bg

6. Website: https://twistellestore.com

“VRS ART” EOOD (“the Company” or “the Administrator”) operates in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data (“General Data Protection Regulation” or “the Regulation”). This “Privacy Policy” (“Privacy Policy” or “the Policy”) aims to inform each Client (as defined below) of the Company about the processing of data by which the specific Client is identified or can be identified.

For the purposes of the Policy, "Client" is any natural person party to a contract with the Company for the purchase and sale of goods, as well as an individual who has expressed a will to enter into pre-contractual relations with the Administrator and/or user of the Electronic Store Twistelle Store, accessible on the Internet at the electronic address: https://twistellestore.com, as well as a director, manager, representative, proxy, employee, partner, shareholder, beneficial owner of a legal entity or other legal entity using the Electronic Store.

1. What personal data do we process?

The Company processes, as a personal data administrator, the following groups of personal data of the Clients:

• Physical identity – names, personal identification number, address, telephone number, email address;

• Economic identity - information about a bank account number.

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

2. How we collect personal data

We collect personal data:

• during the registration process on the website of the Online Store and when using the Online Store without registration;

• when conducting correspondence with the Client, which may include communication in written form, including electronic form and oral form;

• through cookies when using or browsing our website.

In some cases, we may also collect information from third parties or public sources.

Our website collects data in log files. This information includes data about your IP address, internet service provider, the browser you are using, your operating system, when you visited our website, the pages you visited.

Our website uses cookies. Cookies are small files of information that a website sends to the visitor's browser. The browser stores this information in a text file on the user's end device. They help us make our website work better for you. You can read more about the use of cookies in our Cookie Policy, published on the website of the E-shop: www.twistellestore.com.

3. Do we process special categories of personal data?

The Company does not process special categories of personal data of Customers.

4. For what purposes do we process personal data?

The Company processes the personal data of the Clients for the following purposes:

• providing information and assistance that you have requested from us;

• individualization and contact with clients and beneficial owners;

• for all activities related to the existence, modification and termination of the relationship between the Company and the Client;

• offering and promoting additional services;

• compliance with regulatory requirements;

• implementing defense in the event of a dispute and cooperating with regulatory authorities to the extent required by law.

If we do not process this personal data, we may not be able to provide you with our services or the assistance you have requested.

5. On what legal basis do we process personal data?

Clients' personal data is collected, processed and used based on several grounds for processing:

• For the performance of a contract or for entering into pre-contractual relations;

• For compliance with a legal obligation applicable to the Company;

• For the purposes of the legitimate interests of the Company or a third party, where the rights and interests of the data subjects do not prevail over them – for the resolution of disputes; for the prevention, detection, investigation of fraud, violations or other unlawful conduct; for the establishment, exercise or defense of legal claims;

• Under the conditions of voluntary consent, when required by applicable law.

6. For how long do we store personal data?

The Company stores personal data for the duration of the contractual relationship and until the contractual claim is settled and during a transitional period (e.g. to comply with obligations relating to archiving and storage of accounting data). If legal or other action is initiated, personal data may be stored until the end of such action, including any possible periods for appeal, and will then be deleted or archived as permitted by applicable law. In particular, the various accounting and tax information carriers containing personal data are stored for a period of 10 years, starting from 1 January of the reporting period following the reporting period to which they relate.

In cases where your personal data is obtained and processed on the basis of your consent, we will process your personal data only to the extent that we have your consent to process your personal data.

7. Who do we share personal data with? Do we provide it to third countries?

The Company may, at its own discretion, transfer part or all personal data to personal data processors for the fulfillment of the processing purposes, subject to the requirements of the Regulation.

The company shares personal data with:

• third parties – service providers engaged by us to perform functions or activities on our behalf;

• third parties: regulatory authorities, tax, financial authorities, judicial, administrative and law enforcement authorities, all in accordance with applicable law.

This list is not exhaustive and there may be other legitimate purposes for storing, disclosing or otherwise processing your personal data.

The Company shall notify the personal data subject in the event of an intention to transfer part or all of his/her personal data to third countries or international organizations.

8. Is personal data protected?

The Company provides and maintains appropriate technical and organizational measures to protect personal data against unauthorized access or unlawful use of personal data and/or against their accidental loss, alteration, disclosure, access and/or damage or copying. These measures are intended to ensure the continued protection and integrity of personal data. The Company reassesses the measures regularly in order to achieve ongoing security of personal data.

9. Do we perform automated decision-making?

The company does not perform automated decision-making with data.

10. What are the Clients' rights regarding the protection of personal data?

Each Client may exercise the rights specified below by written notice to the Company.

• Withdrawal of consent to the processing of personal data

Where the processing of a Client's personal data is based on the Client's consent to the processing of his or her personal data, the Client has the right to withdraw his or her consent at any time. The withdrawal of consent does not affect the lawfulness of the processing based on consent given before its withdrawal.

• Right of access

Each Client has the right to obtain confirmation from the Company whether his/her personal data is being processed by the Company. This includes the right to access the personal data, the right to obtain a copy of the data free of charge (except in cases of excessive and repetitive requests), unless otherwise provided for in the applicable personal data protection rules, as well as the right of the Client to be provided with a description of the basic information related to the processing of his/her personal data.

The Company provides the Client with a copy of his personal data that is being processed free of charge, but reserves the right to impose an administrative fee in case of repetitive or excessive requests.

• Right to rectification

Each Client has the right to correct or request the Company to correct, without undue delay, inaccurate, incomplete or outdated personal data relating to him/her.

• Right to erasure (right to be forgotten)

Each Client has the right to request from the Company the deletion of personal data relating to him without undue delay, where any of the grounds specified below is applicable:

(i) The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

(ii) The Client withdraws his consent on which the processing of his data was based and there is no other legal basis for its processing;

(iii) Customer objects to the processing as set out below;

(iv) The Client's personal data has been processed unlawfully; or

(v) The Customer's personal data must be erased in order to comply with a legal obligation under EU law, the law of a Member State or the law of another country;

(vi) the personal data were collected in connection with the provision of information society services.

The Company may refuse to delete a Client's personal data to the extent that their processing is necessary:

(i) for the exercise of the right to freedom of expression and the right to information;

(ii) for compliance with a legal obligation which requires processing provided for in EU or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in it;

(iii) for reasons of public interest in the field of public health

(iv) for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes;

(v) for the establishment, exercise or defense of legal claims.

• Right to restriction of processing

Each Client has the right to request the Company to restrict the processing of his/her personal data in the following cases:

(i) When contesting the accuracy of the personal data as provided by the Client and processed by the Company (the limitation is for a certain period of time, which allows the Company to verify the accuracy of the personal data);

(ii) Where the processing is unlawful but the Client does not wish the Personal Data to be erased but instead requests the restriction of its use;

(iii) When the Company no longer needs the personal data for the purposes of the processing, but the Client requires them for the establishment, exercise or defense of legal claims;

(iv) Where a Client has objected to the processing and expects the Company to verify whether the Company's legitimate grounds for processing the personal data override the Client's interests.

• Right to object

Each Client has the right at any time, on grounds relating to his or her particular situation, to object to the processing of personal data relating to him or her.

A Client may exercise the right only with respect to the processing of his/her personal data, which is carried out by the Company for the purposes of the Company's legitimate interests.

If the objection is justified, the Company will cease processing the personal data concerning the objecting Client, unless the Company proves that there are compelling legitimate grounds for the processing which override the interests of the Client.

• Right to data portability

This right includes the following possibilities:

(i) to receive the personal data in a structured, commonly used and machine-readable format in order to transmit them to another controller, or

(ii) to obtain a direct transfer of the personal data to another controller, if this is technically feasible.

• Right to appeal

Each Client has the right to file a complaint regarding the processing of his/her personal data by the Company to the Personal Data Protection Commission, which is the competent supervisory authority.

Personal Data Protection Commission

Address: Sofia, p. k. 1592, 2 Prof. Tsvetan Lazarov Street,

tel. (02) 91 53 519, fax: (02) 91 53 525

email: kzld@cpdp.bg

website: www.cpdp.bg

11. What happens in case of change?

In the event of a material change in the manner in which the Company processes Clients' personal data and/or in the types of personal data it processes, and/or in any other aspect of the subject matter of this notice, the Company will notify the Clients of the relevant change immediately by issuing and providing the Clients with an updated version of the notice.