Mandatory Information on the Rights of Individuals Regarding Personal Data Protection (Privacy Notice)

Information about the Company Processing Your Data:

Name: Safrono Ltd.

Company Registration Number (UIC): 206688071

Registered Address: Blagoevgrad, Elenovo residential complex, 72A, Floor 5

Telephone: +359 898 495 141

E-mail office@saffrono.com

Website: https://www.saffrono.com

Information about the Competent Supervisory Authority for Personal Data Protection:

Commission for Personal Data Protection

Address: Sofia 1592, “Prof. Cvetan Lazarov” Blvd. No. 2

Tel.: (02) 915 3 518

Fax: (02) 940 36 40

Email: kzld@government.bg, kzld@cpdp.bg

Website: www.cpdp.bg

Legal Grounds for Collecting, Processing, and Storing Your Personal Data

Article 1. Saffrono collects and processes your personal data in connection with the use of the online store www.saffrono.com and the conclusion of contracts with the company based on Article 6, Paragraph 1 of Regulation (EU) 2016/679 (GDPR) and, more specifically, on the following grounds:

  • Explicit consent provided by you as a client;
  • Fulfillment of SAFRONO’s obligations under a contract with you;
  • Compliance with a legal obligation directly applicable to SAFRONO;
  • For the purposes of the legitimate interests of SAFRONO or a third party.

Purposes and Principles for Collecting, Processing, and Storing Your Personal Data

Article 2. (1) We collect and process the personal data you provide in connection with the use of the online store www.saffrono.com and the conclusion of contracts with the company, including for the following purposes:

  • Creating a profile and providing full functionality when using the online store;
  • Identifying the party to the contract;
  • Fulfilling orders and deliveries under the contract;
  • Accounting purposes;
  • Statistical purposes;
  • Ensuring information security;
  • Ensuring the fulfillment of the contract for providing the respective service;
  • Sending newsletters and electronic messages at your expressed desire.


(2) We adhere to the following principles when processing your personal data:

  • Lawfulness, fairness, and transparency;
  • Limitation of processing purposes;
  • Relevance to the purposes of processing and minimization of the collected data;
  • Accuracy and up-to-dateness of the data;
  • Limitation of storage in view of achieving the purposes;
  • Integrity and confidentiality of processing, ensuring an appropriate level of personal data security.


(3) When processing and storing personal data, SAFRONO may process and store personal data to protect the following legitimate interests:

  • Fulfilling its obligations to the National Revenue Agency, the Ministry of Interior, and other state and municipal authorities.


Types of Personal Data Collected, Processed, and Stored by Our Company

Article 3. (1) The Company performs the following operations with the personal data provided by you as clients, for the following purposes:

  • Client registration in the online store and fulfillment of a distance sales contract – The purpose of this operation is to create a profile for using the online store to purchase goods and to provide contact details for the delivery of purchased goods. Registration and profile creation for using the online store is not a mandatory step for accessing the service, as it is significantly available without creating a profile by placing an order without registration.
  • Sending newsletters – The purpose of this operation is to manage the process of sending newsletters, emails with special offers, promotions, promo codes, news, and new functionalities to clients who have expressed their desire to receive such information.
  • Exercising the right of withdrawal or filing complaints – The purpose of this operation is to manage the process of exercising the right of withdrawal or filing complaints regarding goods for which such rights may be exercised.
  • Sending gifts, promotional packages, promo codes, etc. – The purpose of this operation is to send gifts for birthdays or campaigns organized by the Company to our clients who have consented to their data being processed for this purpose.


(2) The Administrator does not collect or process personal data related to the following:

  • Disclosing racial or ethnic origin;
  • Disclosing political, religious, or philosophical beliefs, or membership in trade unions;
  • Genetic and biometric data, health data, or data about sexual life or sexual orientation.


(3) Personal data is collected by the Administrator from the individuals to whom it pertains.

(4) The Administrator does not engage in automated decision-making with data.

(5) The Company does not collect data about individuals under 14 years of age, except with the explicit consent of their parent or legal guardian.

Article 4. (1) The Administrator processes the following categories of personal data and information for the following purposes and on the following grounds:

Your personal identification data during registration on our website (email, name, phone number, date of birth, etc.)
Purpose for collecting the data: 1) Establishing contact with the user and sending information to them, 2) For user registration in the online store, 3) For sending newsletters and electronic messages, 4) For sending gifts upon your explicit consent.

Grounds for processing your personal data: By accepting the general terms and registering in the online store, or placing an order without registration, or by entering into a written contract, a contractual relationship is established between SAFRONO and you, based on which we process your personal data – Article 6, para. 1, letter (b) GDPR. Your data for sending newsletters and electronic messages, as well as gifts, are processed based on your explicit consent – Article 6, para. 1, letter (a) GDPR.

Data for order delivery (names, email, phone number, address)
Purpose for collecting the data: Fulfillment of SAFRONO’s obligations under the sales contract and delivery of the purchased goods.

Grounds for processing your personal data: By accepting the general terms and registering in the online store, or placing an order without registration, or by entering into a written contract, a contractual relationship is established between SAFRONOand you, based on which we process your personal data – Article 6, para. 1, letter (b) GDPR.

Retention Period of Your Personal Data

Article 5. (1) SAFRONO retains your personal data for no longer than the duration of your profile in the online store or the completion of your order without registration. Once your profile is deleted or your order is completed, SAFRONO ensures that all your data is erased and destroyed without unnecessary delay or anonymized (i.e., transformed into a form that does not reveal your identity).

(2) SAFRONO retains the personal data you provide in relation to online orders for a period of 5 years to protect its legal interests in judicial or administrative disputes with users of the online store. Accounting documents are stored for the statutory period as required by law.

(3) SAFRONO will inform you if it is necessary to extend the retention period of your data due to compliance with a legal obligation or in consideration of legitimate interests of SAFRONO or another party.

(4) SAFRONO retains personal data required by applicable legislation for the period specified by law, which may exceed the duration of your profile in the online store or the completion of the order.

Transfer of Your Personal Data for Processing

Article 6. (1) SAFRONO may, at its discretion, transfer part or all of your personal data to processors for the purposes of processing to which you have consented, while complying with the requirements of Regulation (EU) 2016/679 (GDPR).

(2) SAFRONO will notify you in the event of intent to transfer part or all of your personal data to third countries or international organizations.

Your Rights Regarding the Collection, Processing, and Retention of Your Personal Data

Withdrawal of Consent for Processing Your Personal Data

Article 7. (1) If you do not wish all or part of your personal data to continue being processed by the Company for specific or all processing purposes, you may withdraw your consent at any time by submitting a free-text request.

(2) SAFRONO may request you to verify your identity and confirm that you are the person to whom the data pertains.

(3) Upon withdrawal of consent for processing personal data necessary for creating and maintaining a profile in the online store, your account will become inactive. However, you will still be able to browse the online store, view the offered products, and place orders or create a new registration.

(4) If you have placed an order currently being processed, the earliest point at which you can withdraw your consent for processing is upon the successful completion of the order.

(5) You may withdraw your consent for the processing of your personal data for direct marketing purposes at any time.

(6) The withdrawal of consent does not affect the legality of data processing carried out by SAFRONO up to the point of withdrawal.

Right of Access

Article 8. (1) You have the right to request and receive confirmation from SAFRONO about whether personal data related to you is being processed. You can view the data we process about you at any time through your profile if you are a registered user.

(2) You have the right to access the data related to you, as well as information regarding the collection, processing, and storage of your personal data.

(3) Access to the data is provided free of charge, but SAFRONO reserves the right to impose an administrative fee in cases of repeated or excessive requests.

Right to Rectification or Completion

Article 9. You have the right to rectify or complete inaccurate or incomplete personal data related to you directly through your profile on the website or by submitting a request to SAFRONO.

Right to Erasure

Article 10. (1) You have the right to request from SAFRONO the erasure of part or all of the personal data related to you, and SAFRONO is obliged to erase it without undue delay when any of the following grounds apply:

  • The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
  • You withdraw your consent on which the processing is based, and there is no other legal basis for the processing;
  • You object to the processing of your personal data, including for direct marketing purposes, and there are no overriding legitimate grounds for the processing;
  • The personal data has been processed unlawfully;
  • The personal data must be erased to comply with a legal obligation under EU law or the law of a Member State that applies to SAFRONO;
  • The personal data has been collected in connection with the provision of information society services.


(2) SAFRONO is not required to erase personal data if it is retained and processed:

  • For exercising the right to freedom of expression and information;
  • To comply with a legal obligation that requires processing under EU law or the law of a Member State applicable to SAFRONO, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in SAFRONO;
  • For reasons of public interest in the area of public health;
  • For archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes;
  • For the establishment, exercise, or defense of legal claims.


(3) In exercising your right to erasure, the Company will erase all your data, except for the following information:

  • Information necessary to certify that your right to erasure has been fulfilled;
  • Technical information regarding the functioning of the online store, which cannot be associated with your identity in any way;
  • The email address used to register in the online store.


(4) To exercise your right to erasure, you need to undertake the following steps:

  • Submit a request via email;
  • Verify your identity as the account holder.


(5) Once we verify the identity of the individual submitting the request and the individual to whom the data pertains, as described in the steps above, we will erase all the data we process about you, in accordance with paragraph 3.

(6) If you have placed an order that is still being processed, the earliest point at which you can request to be “erased” is upon the successful completion of the order.

(7) Upon the erasure of your personal data, your account will become inactive. However, you will still be able to browse the online store and the products offered, place orders as a guest, or create a new registration.

(8) SAFRONO does not erase data that it is legally obligated to retain, including for the defense against legal claims or to prove its rights.

Right to Restriction

Article 11. (1) You have the right to request SAFRONO to restrict the processing of your data when:

  • You contest the accuracy of the personal data for a period that allows SAFRONO to verify the accuracy of the personal data;
  • The processing is unlawful, but you do not wish for the personal data to be erased and instead request a restriction of its use;
  • SAFRONO no longer needs the personal data for the purposes of processing, but you require it for establishing, exercising, or defending legal claims;
  • You have objected to the processing while awaiting verification of whether SAFRONO’s legitimate grounds override your interests.


(2) If you exercise your right to restriction, the Company will cease processing your data but will not remove publications you have made in the online store.

Right to Receive Information

Article 12. You may request that SAFRONO informs you about all recipients to whom the personal data subject to correction, deletion, or restriction has been disclosed. SAFRONO may refuse to provide this information if it is impossible or requires disproportionate effort.

Right to Object

Article 13. You may object at any time to the processing of personal data by SAFRONO that concerns you, including if it is processed for profiling or direct marketing purposes.

Your Rights in Case of a Personal Data Security Breach

Article 14. (1) If SAFRONO establishes a breach of your personal data security that could result in a high risk to your rights and freedoms, it will notify you without undue delay about the breach and the measures that have been taken or are planned to be taken.

(2) SAFRONO is not obliged to notify you if:

  • It has implemented appropriate technical and organizational measures to protect the data affected by the breach;
  • It has subsequently taken measures that ensure the breach will not result in a high risk to your rights;
  • Notification would require disproportionate effort.


Entities to Whom Your Personal Data Is Provided

Article 15. For the purposes of processing your personal data and providing the service in full functionality, while considering your interests, SAFRONO may provide your data to the following data processors:

Data Processor: Delivery Provider

Purpose of Data Processing: Performing delivery to the specified address

The listed data processors comply with all legal and security requirements for processing and storing your personal data.

Article 16. SAFRONO does not transfer your data to third countries.

Article 17. In case of a violation of your rights under the aforementioned or applicable personal data protection legislation, you have the right to file a complaint with the Commission for Personal Data Protection, as follows:

Commission for Personal Data Protection

Address: Sofia 1592, “Prof. Cvetan Lazarov” Blvd. No. 2

Tel.: (02) 915 3 518

Fax: (02) 940 36 40

Email: kzld@government.bg, kzld@cpdp.bg

Website: www.cpdp.bg

We would, however, appreciate the chance to address your concerns before you approach the Commission for Personal Data Protection, so please contact us first.

Article 18. You can exercise all your rights regarding the protection of your personal data by submitting your requests in any form that contains a statement to this effect and identifies you as the data subject.

Article 19. The Company may amend the Privacy Policy by publishing a notice on its website.

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