Security and the proper and lawful use of personal data are particularly important for the company Devin EAD, Unified Identification Code 040428304, which is part of the SPADEL group of companies.

The rules laid down in this Policy arise directly from GDPR - General Data Protection Regulation (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), hereinafter referred to as the “Regulation”, from the Electronic Commerce Act and from the General Data Protection Policy of SPADEL.

 The Cookies Policy governs the use of “cookies” on the e-commerce platform www.devin2u.bg  created for the purpose of home and office delivery of products offered by Devin EAD (hereinafter referred to as the “Platform”) and the extensions in social media. Cookies are small text files stored on the hard drive of a given device, which contain certain information and, sometimes, personal data.

If you would like to receive general information about how we process your personal data related to the Platform use, other than the information about the cookies, please, refer to our Privacy Policy with respect to the platform at http://www.devin2u.bg/privacy-policy/.

By accepting the use of cookies and extensions in social media through the information banner that pops up when you visit the Platform and by continuing to use the Platform, you confirm that you have read and accepted this Cookies Policy. 

1. GENERAL
1.1. Your personal data entered upon registration in the Platform are processed by Devin EAD, Unified Identification Code 040428304 (hereinafter referred to as Devin EAD, “we”, “us”, “our”). You may also contact us via email [email protected].
1.2. Any reference to specific laws or regulations in this Cookies Policy shall also include any amendment or repeal to these laws and regulations, including any decisions on their implementation related thereto.
1.3. We reserve the right to periodically amend this Cookies Policy at our discretion. Any such amendment will be announced in the Platform.

2. COOKIES AND SOCIAL MEDIA EXTENSIONS  
2.1. With the exception of the cookies strictly necessary for the proper functioning of the Platform, you can either accept or reject the use of other cookies via the information banner that pops up when you visit the Platform. The different categories of cookies used during your visit to the Platform are described in detail in paragraph 2.4 below.

2.2. You can avoid the placement of cookies by configuring your browser for this purpose. For instructions how to do this, see the information about your browser, for example:

• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
• Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
• Safari: https://help.apple.com/safari/mac/8.0/en.lproj/sfri11471.html

If you do not allow cookies when visiting the Platform, certain or all functions of the Platform may stop working properly.

2.3. When you visit the Platform, we place multiple cookies. The placement and use of cookies allows us to identify you and we use them to get an idea of how you and other visitors use the Platform by collecting statistical and user data, which allows us to make your visit to the Platform more enjoyable.
2.4. We are aware of the following cookies used on the Platform:

2.5. You can find more detailed description of the cookies, as well as information about the storage period of cookies (“cookie lifetime”) in the cookies management banner of the Platform. To access it, you can press the “Cookies Settings” button you can find at the bottom of each page in the “GENERAL TERMS” section, and press “Select an option”.

2.6. You can withdraw your consent to our use of cookies at any time. To exercise this right or if you want to change your choice regarding cookies, you can press the “Cookies Settings” button you can find at the bottom of each page in the “GENERAL TERMS” section.

3. THE PURPOSES WE USE YOUR PERSONAL DATA FOR
3.1. We process your personal data to perform statistical analyses so that we can improve our Platform and services or develop new products and services..
3.2.  We may also process your personal data for the protection of our legitimate interests if your registration on the Platform or your use of the Platform may be considered to be (a) a violation of the Platform Privacy Policy or the intellectual property rights or any other third party right, (b) a hazard or threat for the security or integrity of our Platform or of our or our subcontractors’ underlying IT systems because of viruses, Trojan horses, spyware, malware or any other form of hacking code; or (c) any conduct that could be malicious, obscene, discriminating, racist, defamatory, malevolent, harmful or otherwise unlawful or illegal.
3.3. Your personal data may be provided to the police or judicial authorities as evidence or if there are reasonable grounds for any illegal deed or offence committed by you by your use of part of the Platform.

3.4. Your personal data could be used for the purpose of marketing or promoting our products, services, brands and the overall successful marketing performance of our products and services.

4. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA 
4.1. The processing of your personal data for statistical analysis and marketing is based on your consent.
4.2. The processing of your personal data for provision of information to competent authorities may be based on a legal obligation we must comply with.
4.3. In some cases, the processing of your personal data may be necessary for the purposes of our legitimate interests, such as:

• continuous improvement of our Platform, our products and services to provide you with the best possible experience;
• protecting our Platform and our services from abuse and illegal actions;
• protecting and exercising our legal rights.

5. WHO WE SEND YOUR DATA TO
5.1. We rely on third-party data processors who provide you with our Platform and process your personal data on our behalf. These third-party data processors are only allowed to process your data on our behalf and upon our express written instruction. We guarantee that all third-party data processors have been carefully selected and are committed to respecting the security and privacy of your personal data.
5.2. We do not send your personally identifiable information to any third party other than those mentioned in Articles 5.1 without your express consent. We may, however, send anonymous data to other organisations, which can use them for improvement of products and services, as well as for performing specific marketing, presentation or sale of these products and services.

6. LOCATION AND TRANSMISSION
6.1. As a rule, Devin EAD strives to refrain from sending data about Platform participants outside the territory of the European Union (EU) and the European Economic Area (EEA). Nevertheless, it may be necessary in certain cases to send certain data to data processors outside the EU and EEA. If such transmission is necessary, this will be done in a manner that ensures compliance with all personal data protection provisions that are currently in force in the EU and in the country in order to ensure adequate level of personal data protection.

7. GUARANTEES
7.1. We exercise the maximum effort to process only those personal data that are necessary to achieve the objectives mentioned in Article 3 above.
7.2. Your personal data are processed only as far as necessary for achieving the objectives mentioned in Article 3 above or until you withdraw your consent to their processing, where it is based on your consent. We will erase your personal data when they are no longer necessary for the objectives mentioned in Article 3 above, unless there is:

• any overriding interest on the part of Devin EAD or third party in keeping the personal data available for identification;
• any legal or regulatory obligation or a court or administrative order that prevents us from erasing them.

7.3. We will take appropriate technical and organisational measures to protect your personal data from unauthorised access or theft, as well as from accidental loss, tampering or destruction. Access by our staff or our third-party data processors will only be on a “need to know” basis and will be subject to confidentiality obligations. However, the safety and security of information in an electronic environment can never be fully guaranteed.

8. YOUR RIGHTS
8.1. You have the right to request access to all personal data relating to you that we process. We reserve the right to charge an administrative fee for multiple subsequent requests for access submitted with the clear purpose of causing us inconvenience or harm. Each request must specify the processing activity you wish to exercise your right of access for and the categories of data you wish to obtain access to.
8.2. You have the right to request that all personal data relating to you that are incorrect be corrected free of charge. If you submit a request for correction, it shall be accompanied by evidence about the inaccurate nature of the data you want corrected.
8.3. You have the right to withdraw your consent to process your personal data you have previously given.
8.4. You have the right to request erasure of the personal data relating to you, if these data are no longer required in the context of the purposes indicated in Article 3 above or if you withdraw your consent to the data processing, where the personal data processing is based on a consent. However, we will evaluate the request for erasure based on:

• the overriding interests of Devin EAD or other third party;
• the legal or regulatory obligations or any administrative or court orders that may be in conflict with such erasure.

Instead of erasure, you can also request restriction of the processing of your personal data if (a) you dispute the accuracy of the data, (b) the processing is unlawful, or (c) the data is no longer necessary for the purposes stated in Article 3 above.

8.5. You have the right to object to the processing of your personal data if you can prove that there are serious and justified reasons for such an objection. If the intended processing qualifies as direct marketing, you have the right to object to such processing free of charge and without reason.
8.6.  You have the right to receive all personal data concerning you in a structured, commonly-used and machine-readable format, as well as to request us to transfer these data to another controller, where this is technically possible.
8.7. If you want to submit a request for exercising one or more of the abovementioned rights, you can send an email to [email protected]. The email with the request to exercise any right will not be interpreted as a consent to the processing of your personal data outside what is required for the processing of your request. This request should clearly indicate:

1. The name, address, personal number or foreigner’s personal number or another equivalent identifier;
2. Description of the request;
3. The preferred form for receiving information when exercising your rights;
4. Signature, date of submission of the request and correspondence address.
We may also request the provision of additional information necessary to confirm your identity.
We will immediately notify you about the receipt of this request. If your request is a valid one, we will examine it as soon as possible, but no later than thirty (30) days after receiving the request.
You can also exercise some of the rights mentioned above through the functions available in your user profile in the Platform.
If you have any complaints about our processing of your personal data, please, do not hesitate to contact us at email address [email protected].
You also have the right to submit a complaint to the Commission for Personal Data Protection.

21.02.2024