PRIVACY POLICY

 

1. Identification: MORGANA TRADE Ltd. (hereinafter called "Administrator") is a personal data administrator. MORGANA TRADE Ltd. is a company, based in Bulgaria, Registry Agency number UIC 206761605, registered as an online trader in the Bulgarian National Revenue Agency, represented by its manager Nela Andonova.

1.1 Contact details of the Administrator

• postal address: 4 “Panagyurishte” str, Varna, Bulgaria

• e-mail: eshop@morganabg.com

• website: www.morganabg.com

• contact person: Nela Andonova

2. Personal data, collected and processed by the Administrator

The Administrator collects and processes users’ personal data in regard to access to and use of the www.morganabg.com website and e-shop, managed by the Administrator, communicating with the users of the website and executing contracts for purchase and sale of goods on the online store, including - in case of execution of contracts for purchase and sale of goods from the online store, pursuant to Article 6, paragraph 1 of 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 and on the free movement of such data and repealing Directive 95/46 / EC (hereinafter "the General Data Protection Regulation").

In addition, in order to personalize users’ preferences, the Administrator may collect and subsequently process certain anonymized information about users’ behaviour when browsing the website and using the online store.

While operating the online store, the Administrator may store and collect information by using cookies and similar technologies in accordance with the Policy for the use of cookies and other similar technologies (hereinafter "Cookie Policy"), available on this website.

The Administrator may not collect or otherwise process sensitive data included in special categories of personal data in the General Data Protection Regulation. In addition, the Administrator does not collect or store data from minors under the age of 16. The Administrator does not collect and store any credit/debit card data.

3. Personal data

The users’ personal data that the Administrator collects and processes are:

3.1. Personal data that is collected automatically:

• Log Files - by accessing the www.morganabg.com website, the Administrator automatically receives information, located in log files (system information about the user): Internet Protocol (IP) addresses, type, and language of the browser, Internet service provider name (ISP), reference and landing pages, operating system, date/time stamp, and clickstream data; the time spent on the website and the pages visited. The information, which these files contain, includes the use of cookies - more information on the use of cookies can be found in the Cookie Policy available on this website.

3.2. Personal data the users shall provide:

• name and surname;

• postal address and e-mail address;

• phone number;

The data that users may be required to provide when paying - bank account number, dates, and/or bank card data are not processed by the Administrator, but by a third party through which the payment is made. In case the payment method is “Cash on Delivery”, the data is processed by the respective postal service provider (Speedy or Econt). The Administrator has no control over the processing of this data by the third party and cannot be held responsible for their processing.

3.3. Legal basis for the processing of personal data by the Administrator

The administrator processes users’ personal data based on:

a / art. 6 (1) (a) of the General Data Protection Regulation, namely on the basis of users’ explicit consent in relation to accessing and browsing the website of the online store and/or communicating with the online store and/or the creation of an account in the online store and/or the use of cookies.

b / art. 6 (1) (b) of the General Data Protection Regulation, particularly the steps to be taken before the execution of a contract and the execution and performance of a contract for the sale of goods on an online store;

c / art. 6 (1) (c) of the General Data Protection Regulation, namely - processing is necessary to comply with a legal obligation applicable to the Administrator, including, but not limited to, compliance with the Administrator's legal obligations under the accounting and applicable tax legislation;

d / art. 6 (1) (f) of the General Regulation on Data Protection, in particular when it is necessary for the purposes of the legitimate interests of the Administrator for the implementation and protection of his business (including, but not limited to - measures to protect the website and its users, measures to prevent and detect attempted fraud; measures to manage various other risks);

3.4. Purposes of the processing of personal data by the Administrator

The personal data provided by the users with regard to access to the website and e-shop, communication, account creation, and use of the online store, including – when entering into a legal contract for the sale of goods from the online store, are processed by the Administrator for the following purposes:

• access to www.morganabg.com website and e-shop;

• communicating with users of the www.morganabg.com website;

• creating a profile and providing full functionality when using the online store;

• order processing, confirmation, delivery, and invoicing of an order; verification, confirmation, and processing of payments and transfers; the refusal of orders, complaints, return of goods, and other actions of any nature related to the order and/or contract for the sale of goods from the online store, providing access to services, including the execution of contracts for the sale of goods from the online store and all relations between the parties in connection with such contracts, as well as fulfilment of the resulting legal and contractual obligations of the Administrator;

• for the functioning and improvement of the website of the online store, analysis of visitors’ behaviour of the website and marketing goals;

• in fulfilment of legal obligations in the field of accounting and tax legislation.

3.5. Users’ personal data may be provided to the following recipients and categories of recipients:

a) legal state institutions - in fulfilment of the obligations of the Administrator according to the Bulgarian legislation;

b) providers of various services of the Administrator, as follows:

• legal, tax, and other advisors and auditors;

• providers of accounting and financial services;

• courier service company for delivery of goods ordered by the users/buyers under the contract for the sale of goods on the online store;

• providers of payment/banking services and banking institutions (all banks and branches of banks on the territory of the Republic of Bulgaria), related to the execution of money transfers for the signed contract for the purchase and sale of goods from the online store;

• marketing service providers;

• market research service providers;

• insurance companies;

• IT service providers;

• other companies, with which the Administrator can cooperate in developing solutions for the sale of goods offered in the online store.

• other companies - providers of the Administrator in connection with the operation of the website and online store, including, but not limited to - providers of software and web solutions – Google, Facebook, or other online platforms.

If obliged by law, or if this is necessary to protect its legitimate interests, the Administrator may disclose certain personal data to public authorities.

The Administrator guarantees that access to users’ data by private third-party entities is carried out in accordance with the legal provisions in General Regulation on Data Protection regulations, based on signed contracts with the third parties.

3.6. Duration of storage of the personal data by the Administrator

a) For the duration of the contract for purchase and sale of goods from the online store, signed between the user and the Administrator and within the 5-year limitation period thereafter;

b) During the existence of the user profile. After deleting the user account, the Administrator will take the necessary measures to delete and/or anonymize all personal data provided in connection with the use of the online store;

c) For the time until the withdrawal of the consent of the user of the website (if the processing of personal data depends on the consent of the user of the website), respectively - for the period until the objection of the user of the website (if the processing of personal data is related to Cookies and other similar and/or marketing activities) and according to the technical possibilities for deleting these files while using the browser/device settings;

d) In the long term, if legislation (e.g., accounting or tax regulations) requires it. In case it is necessary to extend the period for data storage in order to fulfill a legal or contractual obligation of the Administrator.

 

4. Users' rights in regard to their personal data processed by the Administrator

The User has the right at any time to request from the Administrator the following:

4.1. Correction of his personal data - in case the personal data are inaccurate or incomplete.

4.2. Deletion of his personal data - in case of:

(a) personal data are no longer needed for the purposes for which they were collected and processed;

b) the user withdraws his consent on processing personal data (for personal data that are processed on the basis of consent);

(c) objections to the processing, as detailed in section 4.4 below, and there are no legitimate grounds for processing to take precedence, as in all cases where objections to the processing of personal data for direct marketing purposes, including profiling, as far as it is related to direct marketing;

(d) his personal data have been processed unlawfully;

e) personal data must be deleted in order to comply with a legal obligation of the Administrator under Bulgarian law and/or European Union law;

The Administrator may not comply with the request for deletion of the user's personal data if their processing is required in order to fulfill a legal obligation or to process or defend a legal claim;

4.3. Restriction of the processing of his personal data - in case:

a)  the user disputes the accuracy of personal data - for a period allowing the Administrator to verify the accuracy of the data;

b) The processing of personal data is illegal, but the user does not want his personal data to be deleted, but to limit their use;

c) The Administrator no longer needs the personal data for the stated purposes, but the user requires them for processing or protection of legal claims.

d) Objections to the processing of personal data, pending verification of whether the legitimate interests of the Administrator or a third party take precedence over his interests; his personal data are processed for the purposes of direct marketing or for scientific and/or historical research, or statistical purposes.

4.4. User withdrawal from consent for the processing of his personal data

The User may withdraw the consent given for the processing of his personal data at any time (the personal data processed on the basis of consent) if this does not affect the legally the processing performed by the Administrator based on the consent given by the user. before the withdrawal of the user's consent. However, the Administrator will process user data for purposes related to the implementation of the contract between the user and the Administrator for the sale of goods from the online store, as well as possible disputes between the user and the Administrator in regard to the contract. purchase and sale of goods from the online store.

4.5 Access to his personal data

The User may request from the Administrator:

(a) to confirm that he processes the user’s personal data;

(b) to submit a copy of this information;

(c) to provide information concerning the user’s personal data;

4.6. Getting and transferring his personal data

The User has the right to have his personal data which he has provided to the Administrator under the contract for the sale of goods from the online store and to transfer this data to a third party, in respect of personal data processed by the Administrator, based on consent or fulfilment of contractual obligations, and when the processing of this personal data is made through automated electronic systems. The User has the right to request a direct transfer of personal data from the Administrator to a third party when this is technically feasible.

The above may be requested by submitting a written request to the address or e-mail of the Administrator, specified in item 2 of this document.

 

6. Providing of personal data by the user

Providing personal data when ordering goods from the online store is a necessary requirement for the conclusion and implementation of the consumer contract for the sale of goods. The User may choose not to provide this personal data, and may at any time withdraw his consent with regard to the personal data provided, but if the Administrator does not have this personal data, this may prevent the execution of the contract of sale and the fulfillment of the contractual or legal obligations of the Administrator with regard to this contract.

Providing personal data when accessing, viewing, creating an account, and using the website of the online store, is necessary in order to use the website in its full functionality, respectively - for communication with the online store / Administrator. The user may choose not to provide this personal data, and at any time may withdraw his consent with regard to personal data provided, but in this case, the Administrator cannot provide access to the full content of the online store or guarantee that the user will be able to use the website in its full functionality, respectively - in this case, there is no way to communicate with the online store / Administrator.

 

7. Use of an automated decision-making system

In order to perform analyzes, improve the site and provide personalized service to each individual user of the website, according to his individual preferences, the Administrator may collect and process data on user interests and preferences, such as analyzing the number of visits and/or items ordered by this user. This allows for a better understanding of the consumer's expectations and adaptation to his personal needs, without significantly affecting his decisions. Thanks to the use of advanced technologies by the Administrator, the above activities can be performed by the system automatically, thanks to which the submitted content will be as up-to-date and useful as possible for the user of the website.

The analysis of interests or preferences can also be used for the automated creation, provision, and implementation of personalized ads, offers, or promotions (discounts). The result of such actions of the Administrator can significantly affect the user's choice - e.g., the result can be a personal offer for goods, addressed only to the user based on the history of his purchases and his behaviour on the site, to which other users of the site will not have access.

The User may request from the Administrator not to be the subject of a decision based on automatic processing, only when this decision has legal consequences for the user or affects him significantly.

This right does not apply if the decision is taken after the automatic decision and:

• it is needed by the Administrator in order to sign and/or fulfill a contract with the consumer for the purchase and sale of goods from the online store;

• is permitted by law and there are adequate guarantees for the rights of the customer;

• is based on the user’s explicit consent.

8. Links to other websites

The online store may contain links to other websites. Each user may view the terms and conditions of the privacy policy applied to these other websites, and the Administrator is not responsible for them. 

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