PERSONAL DATA PROTECTION POLICY
PERSONAL DATA PROTECTION POLICY
OF “HORIZON USA” EOOD
- how and when we collect your personal data and what information we collect;
- how and why we use your personal data; and
- Your rights to control your personal data.
- General Information.
- 1. Some important concepts to better understand this policy:
– “Personal Data” – this is any information that refers to a natural person and which, alone or in combination with other information, can lead to his identification or identifies him.
– “Subject of personal data” – living natural persons who are identified or identifiable by means of the processed personal data.
– “Processing personal data” – this is any action, what we do or may do with your personal data, including but not limited to its collection, analysis or destruction
– “Personal Data Administrator” – in relation to personal data , which is administered by HORIZON USA. We determine the purpose of processing your data, on one of the grounds provided for by law; essentially, we also determine the means by which this processing takes place – for example, the technical infrastructure and applications with which the processing takes place. Obligations regarding the security and protection of your personal data arise for us.
– “Processor of personal data” – this is a third party that processes your personal data on our assignment, where HORIZONT USA has strictly determined the purpose of the processing, the means by which it occurs and checked whether the person meets the requirements of the GDPR. Such a processor can be, for example, an agency responsible for marketing campaign of HORIZON USA in a social network and creates reports on its success.
– “Privacy Breach” is a security breach that results in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to personal data that is transmitted, stored or otherwise processed.
– “Digital Assets” – the website www.7gwines.com all landing pages maintained by the Company, web, native and mobile applications available to customers.
- Who are we?
“HORIZONT USA” EOOD We are the main investor and leader and investor in the city of Ruse
which has as its subject of activity wine production, hotel and restaurant business.
3. How can you contact us?
“HORIZON USA” EOOD has its headquarters and management address in the village of Mechka, Ruse Region, Ivanovo Municipality, address: Tsar Boris I Street 57. 7091 and contact phone: + 359 87 624 5920 You can contact us by visiting us at the Company address listed, as well as on our website www.7gwines.com
- Who in the organization is responsible for protecting my personal data and how can I contact them?
Personal data protection officer (“DPO”) – e-mail: email@example.com, contact phone – +359 87 624 5920
- Type, purpose and basis of the processing of personal data collected by “HORIZONT USA” EOOD:
|First and last name, phone, address, email
|Conclusion/execution of a contract at a distance for an order made for goods
|Conclusion/execution of a contract at a distance for an order made for goods
|Send a short text message (SMS) to the customer’s phone number
|Send a text message to the customer’s phone number via the VOIP application “Viber”
|Date of Birth
Your personal data will be processed by HORIZON USA EOOD only in accordance with applicable data protection regulations. When you correspond with us through any of the communication channels , You confirm that the data you have provided is accurate, correct and up-to-date.
We would like to inform you that any consent to the processing of your personal data can be withdrawn at any time, as by submitting a request in writing to the Company’s management address in Mechka Ruse Region, Ivanovo Municipality with address Tsar Boris I Street 57. 7091 and contact phone: +359 87 624 5920 and/or sending an e-mail to firstname.lastname@example.org. The withdrawal of your consent to the processing of your data will in no way reflect negatively on the conclusion of the distance contract for the order of goods placed on our website.
- For how long will my personal data be stored?
Personal data are stored for the periods necessary to achieve the purposes for which they were collected. After achieving the purposes for which the personal data were collected, we will destroy them immediately.
“HORIZON USA” EOOD takes all necessary technical and organizational measures to destroy the data that is no longer needed, except for cases where there is a legal basis for “HORIZON USA” ” EOOD to process them for a longer period of time; upon your request to restrict processing, in accordance with your rights detailed below; or with a view compatible with the original purpose of processing, of which you will be promptly informed.
“HORIZON USA” EOOD stores the collected personal data in the following terms:
a) when the data is processed on the basis of a distance contract concluded for an order for goods – for a period of 5 years, which period starts from the date of termination of the contract from distance for placed order of goods.
b) when the data is processed on the basis of consent – until the express withdrawal of consent.
c) when the data is processed to protect the realization of rights and interests of the Company, which have a justified advantage over the interests of natural persons – until the right is extinguished and/or the interest ceases .
After the expiration of the specified terms, if there is no other reason for processing the data, they will be deleted. In order to obtain and analyze information related to the products and services you use, as well as to improve the service, the Company may delete only part of the data. In these cases, it continues to store such a part of the data that does not allow natural persons to be subsequently identified.
- Will my personal data be accessible to third parties?
Access to your personal data may also be given to the following categories of persons who, based on concluded contracts with the Company, may be processors, namely:
– the persons who maintain the Company’s information systems located in the Republic of Bulgaria, as well as, if necessary, the customer service centers in the Republic of Bulgaria;
– the persons who are entrusted with the creation, printing, assembly, delivery (including via SMS-messages or electronically) of written correspondence from the Company to its customers;
The company is obliged to provide personal data about its customers to the competent authorities and institutions under the applicable legislation and in the event that such information is requested by law that reason.
“HORIZON USA” EOOD does not transmit personal data to a third country or international organization outside the European Union.
- How do we protect your personal data?
To ensure adequate data protection of the Company and its customers, we implement all necessary organizational and technical measures provided for in the Personal Data Protection Act and the General Regulation on the Protection of Personal Data data.
The Company has established structures to prevent abuses and security breaches, as it has also designated a Data Protection Officer, which supports the processes of protecting and ensuring the security of your data.< /span>
In order to ensure maximum security when processing, transferring and storing your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.
- Your rights
As a data subject whose data is processed by HORIZON USA LLC, you have rights, the content of which is comprehensively described below.
You should keep in mind that the provision of personal data is voluntary – it is necessary for the conclusion of a contract with the Company. If the data is not provided, the Company will not be able to provide a product or service.
HORIZON USA EOOD satisfies your requests without delay, within up to 30 calendar days from their submission. With our decision we grant or deny access and/or the information requested by the requester , but we always motivate our answer. For the purpose of the Company’s website, a link to this Policy is placed in a clearly visible place.
Applications regarding the exercise of your rights are submitted:
– in person or by a person expressly authorized by you, through a notarized power of attorney at the address of the Company’s management in the village of Mechka, Ruse Region, Ivanovo Municipality with address Tsar Boris I Street 57 7091 and contact phone: +359 87 624 5920
– electronically by sending e-mail: email@example.com
– by calling phone:+359 87 624 5920
Exercising the rights is free of charge and covers all structured and unstructured data, as well as all databases maintained by the Company.
Exceptions to the period for the satisfaction of the rights and the free principle are allowed for requests from the same client for data with a frequency greater than 3 times a year and requiring the mobilization of significant administrative resource from the Company. In this case, we may impose a reasonable fee in view of the administrative costs incurred.
When the data subject makes a request by electronic means, the information shall be provided by electronic means whenever possible, unless the data subject has requested otherwise.
When the Company has reasonable concerns regarding the identity of the natural person who submits a request to exercise his rights under this point, the person directly responsible should immediately consult with the official data protection in order to identify the client.
You should also note that the withdrawal of the given consents does not affect the lawfulness of the processing of your personal data before the withdrawal. Despite withdrawn consent, your personal data may be processed by the Company, if there are other grounds for data processing specified in item 5.
You have the following rights:
- Right to information
As a personal data subject, you have the right to receive information about important features of the processing of your personal data, including but not limited to its purpose, term and basis, the recipients and the categories of recipients of personal data and others.
In addition to the information set out above, you should be aware that you are subject to automated decision-making, including profiling. This means that the data you provide is used for the purpose of creating a suitable “profile” for you and aims to prevent fraud, to diversify the products offered by the Company, as well as to select suitable advertising, marketing and promotional materials for you.< /span>
Under applicable personal data law, you have the rights below, and we undertake to rim of each of your requests within 1 month of receipt of the request and without any fee due. In the event of any difficulties in the timely implementation of such requests, the deadline for implementation may be extended by another 2 months, for which you will be notified within 1 month of receiving the request.
- Right of Access
You can request information about what personal data we process and whether we process it. You can request access to this data.
We will provide you with a statement of the personal data that is being processed. For additional statements, we may charge a reasonable fee based on administrative costs. When you submit a request by electronic means, we will, where possible, provide the information in a widely used electronic form, unless you have requested otherwise.
- Right to corrections
If we process incomplete or incorrect personal data from you, you can request their correction or completion at any time.
- Right to erasure
You can request the deletion of your personal data in the following cases:
- the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
- you believe that personal data has been processed unlawfully.
Please note that there may be other reasons that prevent the immediate deletion of your data, such as statutory retention obligations, pending proceedings, the establishment, exercise or defense of legal claims claims, etc.
- Right to restriction of processing
You have the right to request restriction of processing if:
- dispute the accuracy of the personal data, for a period that allows us to verify the accuracy of the personal data;
- the processing is unlawful, but you do not want the personal data to be deleted, but instead require the restriction of its use;
- we no longer need the personal data for the purposes of processing, but you require them for the establishment, exercise or defense of legal claims
- you have objected to the processing of the data pending verification of whether the legal grounds of “HORIZONT USA” EOOD for processing the data take precedence over your interests.< /li>
If processing restriction is requested, we will inform you before the processing restriction is lifted.
- Right to data portability
You can ask us to provide you with the personal data we process about you in a format that can be easily read by a computer and transferred to another financial institution, for example. This only applies when
- the processing of the specific data is based on your consent or in connection with the conclusion and performance of a contract at a distance for an order for goods; and
- processing is done in an automated way.
- Right to object
You have the right, at any time and on grounds related to your specific situation, to object to the processing of your personal data, which is based on a legitimate interest – the grounds are specified in the table above, including profiling based on this basis.
When you have given your consent to the processing of data for the purposes of direct marketing, you have the right at any time to object to the processing of personal data without specifying any grounds.</ span>
- Right to lodge a complaint
If you believe that we have violated applicable data protection legislation when processing your data and as a result affected your rights, please contact us. Of course, you also have the right to file a complaint with the Commission for the Protection of Personal Data, which is the supervisory authority in the field of personal data protection at the address: Sofia 1592, Prof. Blvd. Tsvetan Lazarov” No. 02/91-53-518, e-mail: firstname.lastname@example.org.
All requests, as well as additional explanations and information related to the exercise of your rights, can be submitted directly to “HORIZON USA” EOOD by contacting the Data Protection Officer specified in item 4 above.< /span>