Privacy Policy

PERSONAL DATA PROTECTION POLICY

1. Identification of UNITRIX Ltd

UNITRIX LTD („UNITRIX“ or „Controller“) is a personal data controller. UNITRIX LTD limited liability company, registered in the Bulgarian Commercial Register with the Registry Agency under UIC 206672003

2. Contact with the Controller

You can contact the Controller in one of the following ways:

• In writing at the following address: Sofia, Georgi Raychev 23
• By phone: +359883520045
• By e-mail: [email protected]
• Website: smartwheels.store

3. Personal data, processed by the Controller

The Controller collects and processes your personal data in connection to your access and usage of the website operated by the Controller - www.smartwheels.store, contact with users of the website, as well as operation of the online store of the Controller on the website  www.smartwheels.store and conclusion of contracts for purchase of goods from the online store, including – in the process of performing the contracts for purchase of goods from the online store, pursuant to Art.6, Para 1 of the Personal Data Controller and any necessary information as required by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

In addition, in order to customize your preferences for the purpose of your better service, the Controller can collect and then process certain information about your behaviour upon browsing the website and using the online store. Upon operation of the online store, the Controller may collect and store information by cookies and identical technologies according to the Cookie Policy (“the Cookie Policy”) available on the website of the online store.

The Controller does not collect or otherwise process sensitive data included in special categories of personal data in the General Data Protection Regulation. Additionally, the Controller does not want to collect or process data of minors under the age of 16.

3.1. Personal data

The personal data, that the Controller collects and processes for you, are:

3.1.1. Automatically collected personal data:

• Log Files – as soon as you access the website smartwheels.store, the Controller automatically receives information from log files (a set of system information for the user): Internet Protocol (IP) addresses, browser type and language, Internet Service Provider (ISP), Referral and Output Pages, Operating System, Date/Time Tag and Data Clicks; the time spent on a website, and which webpages you've visited on the website. The information contained in these files includes the use of cookie files - more information about using cookies can be found in the Cookie Policy available on www.smartwheels.store .

3.1.2. Personal data provided by you:

• names;
• postal address, email address;
• telephone number;

Please note that the data you might be requested to provide upon payment – bank account, number, dates and/or data from bank cards are not received by the Controller, but by a third party via which the payment is processed. The Controller is not able to control processing of these data by the third party and the Controller cannot be held responsible for its processing. 3.2. Legal grounds for the personal data processing by the Controller

The Controller processes your personal data on the basis of:

a/ Art. 6, paragraph 1, letter a) of the General Data Protection Regulation, namely – on the basis of your explicit consent with regard to accessing and browsing the website of the online store and/or contacting the online store and/or creating a profile in the online store and/or usage of cookies;

b/ Art. 6, paragraph 1, letter b) of the General Data Protection Regulation, namely - processing is necessary in order to take steps prior to entering into a contract as well as for the conclusion and performance of the contract for purchase of goods from the online store;

 c/ Art. 6, paragraph 1, letter c) of the General Data Protection Regulation, namely – processing is necessary for compliance with a legal obligation to which the Controller is subject, including but not limited to – for fulfilment of the legal obligations of the Controller under the Law on Accounting as well as the applicable tax legislation.

d/ Art. 6, paragraph 1, letter f) of the General Data Protection Regulation, namely – processing is necessary for the purposes of the legitimate interests pursued by the Controller for performance and protection of its commercial activity (including but not limited to - measures to protect the website and its users, measures to prevent and detect attempts at fraud; measures to manage various other risks);

3.3. Purposes of the personal data processing by the Controller

The specified personal data provided by you with regard to your access and browsing the website www.smartwheels.store, contacting, creating a profile and usage of the online store, including – upon conclusion of a contract for purchase of goods from the online store is processed by the Controller for the following purposes:

• access to and viewing the website smartwheels.store, on which the online store operates;
• contacting the users of the website smartwheels.store;
• creating a profile and providing full functionality upon using the online store;
• individualization of a party to the contract and performance of the contract for purchase of goods from the online store (processing of orders, confirmation, delivery and invoicing of the order, verification, confirmation and processing of payments and transfers, rejection of orders, claims, returns goods and other actions of any kind related to an order and/or a contract for purchase of goods from the online store, providing access to services, including - the performance of contracts for purchase of goods from the online store and all relations between the parties in connection with such contracts), as well as the fulfilment of the resulting legal and contractual obligations of the Controller;
• functioning and improving the operation of the website of the online store, analysis of the behaviour of the users of the website and marketing purposes;
• fulfilment of the legal obligations in the field of accounting and tax legislation.

3.4. The specified personal data of yours may be provided to the following recipients and categories of recipients:

1. a) Competent state bodies - in fulfilment of the obligations of the Controller in accordance with the Bulgarian legislation;
2. b) Various service providers of the Controller as follows:

• Legal, tax and other consultants and auditors;
• A service provider under a contract for the provision of accounting & financial services;
• A courier under a contract for the provision of courier services (DHL, Speedy) for delivery of goods ordered by you, being user of the online store and buyer under the contract for purchase of goods from the online store;
• Service providers under payment/banking services and banking institutions (PayPal and all banks and banks’ branches on the territory of the Republic of Bulgaria and abroad) in terms of processing cash transfers in connection to concluded contracts for purchase of goods from the online store;
• Service providers of marketing services;
• Service providers of services related to market researches;
• Insurance companies;
• Service providers of IT services;
• Other companies in cooperation with which the Controller may develop joint programs for sale of the goods offered by the Controller in the online store.
• Other companies - providers of the Controller with regard to the functioning of the website and the online store, including – providers of programs and web solutions - products and services of Google – Google platforms and other online platforms.

In case the Controller is required by law or if it is necessary to protect its legitimate interests, the Controller may disclose certain personal data to public authorities as well.

The Controller shall ensure that access to your personal data by third parties - private entities takes place in accordance with the legal provisions on personal data protection and the confidentiality of information on the basis of contracts concluded with them.

3.5. Term of storage of the provided personal data by the Controller

а) For the term of effectiveness of the contract for purchase of goods from the online store concluded between you and the Controller, and within the 5-year limitation period afterwards;

1. b) For the term of existence of your profile in the online store. After deletion of your profile the Controller will take the necessary steps to delete and/or anonymize your personal data provided in connection with the use of the online store;
2. c) For the term until withdrawal of the consent of the user of the website (provided that processing of the personal data depends on the consent of the user of the website), accordingly – for the term until raising an objection by the user of the website (provided that processing of the personal data is connected to the technology of the cookies and other related and/or marketing activities) and according to the technical ability for deletion of these files, until the settings of the browser/the device are used;
3. d) For a longer term, if provided for by law (e.g. accounting or tax legal acts). In the event that an extension of the period for storing the data is required to fulfil a legal or contractual obligation of the Controller and/or the legitimate interests of the Controller or a third party, you will be duly notified by the Controller.

3.6. Providing personal data outside of the territory of Bulgaria

The Controller does not intend to provide your personal data to recipients in countries outside of the European Union and/or the European Economic Area. Nevertheless, provided that in case any of your personal data is transmitted to recipients in countries outside of the European Union including in countries for which the European Commission has not recognized an adequate level of personal data protection, the Controller will take action to ensure that any international transmission of personal data is carefully conducted in order to protect your rights and interests.

4. Your rights in relation to your personal data processed by the Controller

• You have the right at any time to request from the Controller:

4.1. Rectification of your personal data in case the personal data processed for you is inaccurate. You also have the right to have any incomplete personal data of yours completed, including by adding a declaration thereto.

4.2. Erasure of your personal data in case:

а) The personal data is no longer necessary for the purposes, for which they have been collected and processed;

4. b) You withdraw your consent, based on which your personal data is being processed (for the personal data, processed under consent), as set out in details in item 4.5 below;
5. c) you object processing, as set out in details in item 4.4 below, and there are no legal grounds for processing that override as well as in all cases when you object processing personal data for direct marketing purposes;
6. d) Your personal data is being processed unlawfully;
7. e) The personal data must be deleted in order to comply with a legal obligation of the Controller in accordance with the Bulgarian legislation and/or the legislation of the European Union;

The Controller may refuse to fulfil your request for erasure of your personal data provided that the processing of personal data is required:

- for fulfilment of legal obligation; or

- in order to establish, exercise or protect a legal claim;

4.3. Restriction of the processing of your personal data in case:

а) You dispute the accuracy of the personal data – for a period that allows the Controller to verify the accuracy of your data;

1. b) The processing of personal data is illegal, yet you do not wish to erase them, but instead to limit their use;
2. c) The Controller no longer needs your personal data for the specified purposes, but you request to obtain them in order to establish, exercise or protect legal claims;
3. d) You object processing as set out in details in item 4.4 below, pending the verification whether the legitimate grounds of the Controller override yours;

• You have the right at any time to:

4.4. Object the processing of your personal data in case:

а) The processing of your personal data is necessary for the legitimate interests of the Controller or a third party;

1. b) Your personal data is processed for direct marketing purposes;
2. c) Your personal data is being processed for scientific and/or historical research purposes or for statistical purposes.

4.5. Withdraw your consent for processing personal data

You have the right to withdraw your consent for processing your personal data at any time (regarding the personal data processed under consent) – but it shall not affect the lawfulness of processing performed by the Controller based on your consent before its withdrawal. Irrespective of the above, the Controller will process your personal data for purposes related to the performance of the contract concluded between you and the Controller for purchase of goods from the online store as well as any possible disputes between you and the Controller in connection with or resulting from the concluded contract for purchase of goods from the online store.

All rights hereunder this item 4 may be exercised by sending a written request to the Controller’s address or by sending an electronic request to the Controller’s e-mail address, specified hereinabove, in item 2 of this document.

5. Right of access to the personal data

You have the right to obtain from the Controller:

а) confirmation as to whether or not personal data concerning you are being processed;

1. b) providing a copy of your personal data;
2. c) providing information about your personal data;

For any further copies requested by you, the Controller may charge a reasonable fee based on administrative costs.

6. Right to data portability

You have the right to receive the personal data concerning you that you have provided to the Controller in an appropriate format and have the right to transmit those data to another controller regarding the personal data the processing of which by the Controller is based on your consent or needed for fulfilling of the contractual obligations under the contract for purchase of goods from the online store and the processing is carried out by automated means (i.e. by automated electronic systems and not in a paper archive). You have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

7. Right of appeal to a supervisory authority

You have the right to lodge a complaint with the Bulgarian Personal Data Protection Commission (CPDP) if you believe that your personal data is being processed unlawfully or your rights in relation to your personal data are being violated.

Contacts of the CPDP:

2 Prof. Tsvetan Lazarov Blvd., Sofia 1592,

E-mail: [email protected]

Website: www.cpdp.bg.

8. Provision of personal data

Please note that the provision of your personal data in connection with your order and the conclusion of a contract for purchase of goods from the online store is necessary for the conclusion and performance of the contract for purchase of goods from online store and your rights arising from the contract or the applicable law. You are not obliged to provide your personal data in connection with ordering goods from the online store and the conclusion of a contract for purchase of goods from the online store but the provision of your personal data is an absolutely necessary condition and a requirement for the conclusion of a contract for purchase of goods from the online store and its execution. You may choose not to provide your personal data and you may at any time exercise your rights regarding the personal data provided by you, but in case the Controller does not have your personal data, it may prevent the performance of the contract for purchase and fulfilment of the contractual or legal obligations of the Controller in relation to the concluded contract.

Please note that the provision of your personal data in connection with the access to the website of the online store, its viewing and using, including – creation a profile in the online store, as well as in connection with sending a message to the online store/the Controller is necessary for the usage of the website in its full functionality, respectively – for contact with the online store. You may choose not to provide your personal data and you may at any time exercise your rights regarding the personal data provided by you in connection with the access to the website of the online store, its viewing and using, respectively - in connection with contacting the online store/the Controller, but in this case the Controller is not able to grant you access to the content of the online store or guarantee that you can use the website in full scope functionality, respectively – in this case it is not possible to contact the online store/ the Controller.

9. Usage of a system for automated decision-making

In order to perform analyses to improve the performance of the website and provide personalized service to each individual user of the website, according to its individual preferences, the Controller can collect and process data about the user's interests and preferences, such as analysing the number of visits and/or viewed/ordered goods from this user. This allows for a better understanding of the user's expectations and adaptation to his/her needs without significantly affecting his/her decisions. Thanks to the use of advanced technologies by the Controller, the above activities can be run by the system automatically, thanks to which the submitted content will be as up-to-date and useful to the user of the website as possible.

An analysis of interests or preferences can also be used for automatic creation, delivery and performance of user-targeted ads, offers or promotions (discounts). The result of such actions of the Controller can significantly affect your consumer choices - e.g. the result may be a very good temporary offer for goods addressed to you only based on the history of your purchases and your behaviour in the website of the online store that will not be accessible for our other users of the website.

You have the right to request from the Controller not to be subject to a decision based solely on automated processing, but only provided that such decision:

а) produces legal effects concerning you, or

1. b) similarly and significantly affects you.

The above shall not apply if the decision:

• is necessary for the Controller for entering into, or performance of, a contract for purchase of goods from the online store;
• is authorized by law which lays down suitable measures to safeguard your rights and freedoms; or
• is based on your explicit consent.

10. Links to other websites

The online store may contain links to other websites. You can separately check the terms and conditions as well as personal data privacy policy applicable to such other websites where the Controller is not responsible for them. The present Personal Data Protection Policy shall be applied for the activities of the Controller as stipulated above only.

The present Personal Data Protection Policy was adopted on 01.07.2020 and it is valid until revoked or amended upon the respective publication on the website www.smartwheels.store.