Confidentiality and Personal Data Protection

Of SPORT-DEPOT JSC

Effective from 25.05.2018


1. Introduction

Sport-Depot JSC ("Sport-Depot") respects the privacy of its customers and guarantees the protection of their personal data to the maximum extent possible. This Privacy Policy and Protection of Personal Data (hereinafter referred to as "Privacy Policy") has been prepared and is based on applicable Bulgarian and European legislation in the field of personal data protection.

The current Privacy Policy regulates the processing of personal data by individuals or representatives of legal entities who are our customers or potential customers, as well as users of our website: www.absolute-teamsport.bg/en ("The site"), in connection with the services provided by Sport-Depot, including those provided through and accessible on the Site.

The current Privacy Policy, including the General Terms and Conditions for Website Use, the Cookie Usage Policy and any other documents mentioned on the Site, sets out the rules that Sport-Depot will follow when processing personal data we collect from you, about you, or which you provide to us. This Privacy Policy does not affect, restrict or cancel your rights arising from the Personal Data Protection Act ("PDPA") or other applicable legislation.

If you have any questions or comments regarding this Privacy Policy, please contact us at: [email protected]

Please read this Policy carefully before using the Site or providing your Personal Data, whether electronically on the Site or on paper, as by providing your Personal Data you agree to its terms. If you do not wish us to process your personal data in the manner described in this Privacy Policy, please do not provide it to us. The provision of personal data by you is voluntary, for the purpose of using certain services provided by us and using the Site and/or accessing it, as well as for online shopping on the Site. Please note that in some cases we will not be able to provide you with the service and/or sell you the goods you have requested if you do not provide us with the necessary information. Please also note that in certain cases your consent for personal data processing may not be necessary if Sport-Depot has another legal basis, such as the performance of legally established obligations.


2. Who processes and is responsible for your personal data?

Sport-Depot JSC ("Sport-Depot", "we") is a commercial company registered in the Commercial Register with the Agency for Registration with UIC 175399518, which collects, processes and stores your personal data under the terms of this Privacy Policy. Sport-Depot is a personal data controller under the meaning of the Personal Data Protection Act (PDPA). You can contact us at any of the following coordinates:

  • Management address: Sofia, 6 "Vasil Radoslavov" Street, Sport Depot Building, 3rd floor
  • Telephone: 0701 90009
  • e-mail: [email protected]
  • Data Protection Officer: Denitsa Milkova

3. Categories of personal data processed by Sport-Depot.

3.1. Sport-Depot may process publicly available personal data and/or personal data provided by you. The main types of personal data processed are:

  • Personal identification information (including name, email address, language of communication, etc);
  • Contact details (including postal and electronic addresses, telephone and fax numbers of you or a person you designate for contact, etc);
  • Financial information (bank account and others);
  • Information about a representative (legal representative or proxy) of our client legal entity;
  • Profile data in the Site (including name, postal and electronic addresses, telephone number, date of birth, etc);
  • Data for the conclusion of contracts for sale, dealership, wholesale sales, deferred payment, etc. with natural or legal persons (such as names, PIN and others).

3.2. Sport-Depot may process data created and generated by Sport-Depot in the process of providing services:

  • Data about the end electronic communication device used, the type of device, the operating system used, IP address, location;
  • Data about goods and services preferred by you;
  • Data from communication between us and you, habits, preferences, your satisfaction with our services (activity in using services, complaints, requests and others);
  • Information regarding visits to the Site and use of the Site, including operations and usage history of the Site;
  • Data obtained in the performance of obligations arising from regulatory acts (i.e. data arising from inquiries, regulations, investigating bodies, notary, tax services, court, court executor);
  • Video recording when visiting stores or central office; voice recording - calls made to Sport-Depot's contact center;
  • Video recording or photography made in accordance with pre-announced conditions for participation in games and/or other promotional campaigns organized by Sport-Depot.

3.3. In order to ensure proper performance of services and obligations arising from customer contracts, Sport-Depot has the right to process any information available in public registers (including public database and data published on the internet) as well as information obtained from third parties in performance of legal requirements regarding clients.

3.4. Sport-Depot has the right and obligation to verify the accuracy of personal data recorded in the database, and for this purpose requires you to verify the data and if necessary, correct it or confirm your data.

3.5. The different types of personal data may be processed independently or in combination with each other.


4. Objectives and legal bases for the processing of personal data

4.1. Processing of personal data necessary for the conclusion or performance of contracts with us or in connection with the preparation for the conclusion of contracts with us.

Sport-Depot processes your data for the following purposes:

  • Customer identification when: c signing a new or changing an existing contract with us; clarifications of the services used; execution of contract.
  • Preparation of offers for contracts, sending pre-contractual information and draft contract; management of pre-sales activities;
  • Data obtained from you in fulfillment of obligations arising from contracts concluded with you or represented by you company, exercise of rights and ensuring performance of contracts by our customers;
  • Administration and response to customer complaints/requests/grievances/claims; refund of amounts and goods; product replacement;
  • Technical assistance for account creation and recovery of forgotten password for access to our Site, for electronic service of electronic invoices.
  • Identification and validation of legally required age for online shopping;
  • Payment of obligations, installment of due amounts; management of debt collection;
  • Warranty and service maintenance;
  • Update of offers to dealers; sharing of important information in connection with changes in our policy and other administrative information;
  • Management and administration of online shopping activities; payment management.

4.2. In fulfillment of its legal obligations, Sport-Depot processes your data for the following purposes:

  • Invoices issuing;
  • For performance of tax and insurance control by the respective competent bodies;
  • Performance of obligations in connection with distance selling, off-premises selling provided for in the Consumer Protection Act;
  • Providing information to the Personal Data Protection Commission in connection with obligations provided for in the regulatory framework for personal data protection – Personal Data Protection Act, Regulation (EU) 2016/679 of April 27, 2016, etc.;
  • Obligations provided for in the Accountancy Act and the Tax and Social Insurance Procedural Code and other related regulatory acts, in connection with maintaining proper and lawful accounting.

4.3. Sport-Depot processes the respective data provided with explicit written consent of the customer for their processing for the following purposes:

  • Creation and management of personal profile in the Site; technical assistance for profile creation and recovery of forgotten password for access to our Site;
  • Direct marketing of products and services;
  • Participation and management of surveys, prize draws, promotional campaigns;
  • Participation and management of Sport Depot Club.

4.4. Processing is necessary for the purposes of legitimate interests of Sport-Depot.

  • In order to protect and ensure the protection of property, interests and safety of Sport-Depot, its visitors and employees, Sport-Depot uses video surveillance equipment.
  • Assessment and establishment of user satisfaction, as well as the effectiveness of advertising that we offer to you and others, and to respond to your expectations by presenting appropriate advertising;
  • Analysis of Purchase History, Customer Preference, and Customer Behavior;
  • Ensuring quality of customer service (video recording, audio recording)

5. Categories of third parties that receive access and process your personal data

  • Transport/courier companies, postal operators in order to fulfill our contractual obligations, sending correspondence and communications, in connection with the contract between us, sending purchased goods;
  • Persons who on behalf of Sport-Depot maintain equipment and software used for processing your personal data;
  • Debt collection service providers, notary, lawyer, court executor or other third party if the customer has violated the obligation arising from a contract with us;
  • Banks serving the payments made from and to you;
  • Persons to whom Sport-Depot has entrusted the performance of part of the activities or obligations related to a specific service that we owe to you; persons processing personal data who on the basis of a contract with Sport-Depot process your personal data on behalf of Sport-Depot;
  • Persons providing consulting services in various fields - lawyers, accountants, marketing agencies etc.;
  • Bodies, institutions and persons to whom we are obliged to provide personal data by virtue of applicable legislation;
  • Security companies holding a license for private security activities, processing video recordings from Sport-Depot facilities/offices and/or maintaining other registers in the process of ensuring access control at the same facilities.

6. For what period is your personal data stored?

The period of time that your personal data is stored depends on the processing purposes for which it was collected:

  • Personal data processed for the purpose of conclusion/amendment and performance of contracts between Sport-Depot and you or represented by you company - for the duration of the contract and until final settlement of all financial relations between the parties. Sport-Depot may retain some of your personal data for a longer period until the expiration of the respective limitation period in order to protect against any claims by customers in connection with performance/termination of contracts with us, as well as for a longer period in case of an already existing legal dispute until its final resolution with a final court/arbitration decision;
  • Personal data processed for the purpose of issuance of accounting/financial documents for the performance of tax and insurance control, and not only - invoices, debit, credit notes, acceptance-transfer protocols, service/goods delivery agreements are retained for at least 11 years after the expiration of the limitation period for extinction of public claims, unless applicable legislation provides for a longer period.
  • Personal data processed for the purpose of participation in Sport Depot club and management of profile in the Site - until explicit withdrawal of given consent or receipt of objection to processing of personal data for profile management or participation in Sport-Depot club.
  • Personal data processed for the purpose of direct marketing - until explicit withdrawal of given consent for direct marketing or receipt of objection to processing of personal data for direct marketing.
  • Data from video recordings from security cameras - up to 60 days from creation of the recording. Telephone conversations are retained until 360 days from the conduct of the conversation.

7. Your Rights in connection with the processing of your personal data

7.1. General rights

In connection with the processing of personal data, you have the following rights, which you may exercise at any time while we store or process your personal data, by sending an application to the address of Sport-Depot indicated above, or electronically by email: [email protected]

You have the right to request from Sport-Depot:

  • a copy of your personal data and access to them at any time;
  • to correct without undue delay, inaccurate personal data of yours, as well as data which are no longer current;
  • your personal data in a form suitable for transfer to another personal data controller, or to request us to do so, without being hindered by us (right to portability);
  • your personal data to be deleted without undue delay if there is any legal basis for this;
  • to restrict the processing of your personal data, in which case your data will be only stored but not processed. Our refusal to restrict will be explicit only in writing, and we are obliged to justify it with the lawful reason;

You also have the right:

  • to withdraw your consent for processing of your personal data at any time with a separate request directed to Sport-Depot, for processing based on given consent;
  • to object to the processing of your personal data;
  • to object to automated processing, including profiling;
  • not to be subject to a decision based solely on automated processing, including profiling;

7.2. You have the right to appeal to the supervisory authority

You have the right to file a complaint directly to the supervisory authority, and the competent authority is the Personal Data Protection Commission, address: Sofia 1592, "Prof. Tsvetan Lazarov" Blvd. No. 2 (www.cpdp.bg).

If you wish to file a complaint regarding the processing of your personal data by Sport-Depot, you can do so at the contact details of the Controller indicated above or directly to the Data Protection Officer (at the contact details indicated above).

7.3. Automated processing and profiling

When you visit our Site, we use automated processing to adapt products and services to your needs in the best possible way.

7.4. Objection to use for direct marketing

You have the right to object to the processing in the future of your personal data for the purposes of direct marketing and advertising, as well as against their disclosure to third parties and their use on their behalf for the purposes of direct marketing and advertising, by withdrawing your given consent at any time. For this purpose you can send an electronic message with the respective request to stop using your data for the purposes of direct marketing to the address: [email protected]

7.5. Can you refuse to provide personal data to Sport-Depot and what are the consequences?

In order for us to enter into a contract with you and/or to provide you with the requested products and/or services and/or to deliver the ordered goods in accordance with the legal and subsequently contractual obligations towards you, Sport-Depot needs certain data to identify the contracting party, its proxy, contact details, payment details.

Not providing such data prevents us from signing a contract with you.

In order to make a purchase from our Site and for us to deliver the goods or services ordered by you, you must have a created profile in the Site. During the profile creation process, Sport-Depot needs certain data to identify you, contact details, payment details. Failure to provide such data prevents the possibility for purchase and delivery of goods or services from us.


8. How we protect your data

Sport-Depot applies organizational, physical, information technology and other necessary measures to ensure the security and protection of your personal data and monitoring of the processing of personal data.

Among other things, such security measures include the following activities:

  • Sport-Depot has established requirements for processing, registration and storage of personal data with internal procedures, compliance with which is constantly monitored;
  • access by Sport-Depot employees to personal data and permission to process personal data in the Sport-Depot database is limited, depending on their responsibilities;
  • Sport-Depot has established confidentiality obligations for its employees;
  • access to Sport-Depot office equipment and each employee's computers is limited.
  • we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as best practices from international standards;
  • In order to ensure maximum security in the processing, transmission and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization and others.

The security measures we apply are subject to continuous improvement and adaptation to the most advanced technologies.


9. Links to other websites

Sometimes the Site may contain links/references (hyperlinks) to other websites. We do not operate the linked websites and do not endorse the content, services and products of these websites. We advise you to use the linked websites carefully and with due attention to their content and terms of use. Sport-Depot is not responsible for the privacy policy or content of such websites and we advise you to review their privacy policies. However, as soon as Sport-Depot receives information about illegal activities or illegal information on such Internet pages, Sport-Depot will immediately take measures to remove electronic links (links) to them.


10. Cookie Usage Policy

To learn about the Cookie Usage Policy, please visit the page Cookie Usage Policy.


11. Personal data for children

We do not consciously collect personal information from children under the age of 16. If we learn that we have collected personal information about a child under the age of 16, we will take steps to delete the information as soon as possible or to obtain the consent of the person with parental responsibility for the child.


12. Amendments to the Privacy Policy

We may periodically update our Personal Data Protection Policy. When there is a change in this policy, an announcement will be published on our website, as well as the updated Personal Data Protection Policy. All changes and additions to the Privacy Policy will only be applied after publication of its current content, available through our Site.