PRIVACY POLICY 
of the PLATFORM
for home and office deliveries www.devin2u.bg 
(hereinafter referred to as "Policy")

The security and the correct and lawful use of personal data are of utmost importance to Devin EAD, with UIC 040428304, which is part of the SPADEL group of companies.

The rules laid down in this Policy derive directly from the GDPR - the 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" or "GDPR", the Law on the Personal Data Protection and the General Data Protection Policy of SPADEL.

With this Policy, we would like to inform you about what information we process about users of the Platform http://www.devin2u.bg (hereinafter referred to as the "Platform") and how we use this information.

The platform http://www.devin2u.bg is an e-commerce platform created in connection with home and office delivery of products offered by Devin EAD.

If you would like to receive information on how we process your personal data related to the use of cookies, please see our Cookie Policy at http://www.devin2u.bg/cookie-policy/

1. In general

 Upon registration with the Platform, your personal data will be processed by "Devin" EAD, with UIC 040428304 (hereinafter "Devin" EAD, "we", "us", "our"). You can contact us by email at [email protected].

Any reference in this Policy to specific laws or regulations will also include any amendment or revocation of those laws or regulations, including any related decisions on the implementation of the laws or regulations.

2. Types of data we process

To become a user of the Platform, you need to register by filling in a registration form (registration form). The registration form can be completed online at http://www.devin2u.bg. All fields marked with a star on the registration form must be filled in to be successfully registered. It is not obligatory to subscribe to our e-newsletter.

The registration form contains the following data to be filled in:

For natural persons:

  • Full name
  • City and address for delivery
  • Contact telephone
  • E-mail

For legal entities:

  • Name
  • UIC and VAT number, if registered under the Law on VAT
  • Registered address and head office
  • Full name of the accountable person
  • City and address for delivery
  • Contact telephone
  • E-mail
  • Number of employees

If you are unwilling to provide the minimum information required above, we will not be able to register you on the Platform.

We will use the personal data you provide only to administer the Platform and for the other purposes specified in this Policy.

Fors who have opted to register on the Platform, the profile is created automatically upon confirmation of registration /registration is confirmed by opening the link contained in the confirmation message/. The username is the email address filled in the registration form and the password is the one specified by the user.

If the person who registers a legal entity account on the Platform is different from the accountable person indicated by him/her, he/she should provide him/her with the text of this Policy.

3. The purposes for which we process your personal data and legal basis for that processing

In general:

  • We process your personal data to perform the delivery of the products you order.
  • We process your personal data to assist you with an order to a supplier for cities other than Sofia and Plovdiv.
  • We process your personal data for marketing purposes, that is, to provide you with targeted messages, offers or advertisements by Devin.
  • We process your personal data in order to comply with legal obligations or to comply with any reasonable request from the competent authorities or bodies, including competent authorities on data protection.
    Your personal data may be passed to the police or judicial authorities on our initiative as evidence or if there is reasonable suspicion of an illegal act or crime committed by you through your use of your registration on the Platform or other communication with us.
  • We process your personal data in order to perform statistical analyses, in view of our legitimate interest to improve our Platform, advertising, services, or to develop new products and services.
  • We also process your personal data to protect our legitimate interests or those of our partners or third parties, if your use of your registration on the Platform could be deemed to be:
    (a) a violation of the applicable terms of use of the Platform or the intellectual property rights) or any other right of a third party,
    (b) a danger or threat to the security or integrity of our Platform or the underlying IT systems belonging us or any of our subcontractors because of viruses, Trojan horses, spyware, malware or any other form of hacking code, or
    (c) conduct that is in any way malicious, indecent, discriminatory, racist, defamatory, libelous, harmful, or otherwise unlawful or illegal.

More specifically:

3.1. Administration of the Platform

We process your data in order to deliver the products you have ordered and to administer the Platform. The contact details allow us to notify you and contact you in connection with the execution of the deliveries, to notify you of changes to this Policy, as well as of the occurrence of new facts and circumstances relevant to the operation of the Platform and the products we offer. We use the data to improve the quality of the Platform and optimize its capabilities. The legal basis for the processing of data related to the administration of the Platform is the need to fulfil our contractual obligation to you, if you are a natural person - party to the contract /Art. 6, para. 1, letter "b" of the GDPR - only for the cities of Sofia and Plovdiv, for which the deliveries are made by Devin EAD/, and the legitimate interest of Devin EAD for the effective administration of the Platform, including to assist registered users for the delivery of the ordered goods and other, as set out in Article 3 above /Art. 6, para.1, letter "f" of the GDPR/. It is possible that the processing of your personal data will be based on our legal obligation /Art. 6 para. 1, letter "c" of the GDPR/ - e.g. to comply with applicable tax and accounting rules or where we need to comply with a request by a competent authority.

3.2. Sending non-personalised messages

We may use your data to send you news and information about new products, promotions and services. We send non-personalised messages to develop and enhance the Platform and to improve the quality of the services we offer. At any time, you may opt-out of receiving non-personalised messages, without stating any reasons, by emailing us at [email protected] or by following the instructions in the message you receive. In the event of such notification, Devin EAD will cease sending non-personalised messages and your registration on the Platform will not be affected. The legal basis for sending non-personalised messages is your consent /Art. 6, para. 1 letter "a" of the GDPR/ which you give when you register or in your user profile when you indicate that you want to subscribe to our e-newsletter. We send non-personalised messages to notify you of changes in the Platform's functionality, to inform you about upcoming activities, services and products, and to receive feedback from you via surveys about the quality of the services we offer.

4. Quality Assurances

We make every effort to process only those personal data that are necessary to achieve the purposes stated in Article 3 above.

Your personal data will be processed only to the extent necessary to achieve the purposes specified in Article 3 above or until the moment you withdraw your consent to the processing where the processing is based on your consent. Your withdrawal of consent will mean that you can no longer use our Platform. We will delete your personal data when it is no longer necessary for the purposes set out in Article 3 above, unless there is:

o An overriding interest of DEVIN EAD or a third party to keep the personal data accessible for identification;

o A legal or regulatory obligation or a court or administrative order that prevents us from deleting them.

If you withdraw your consent, please note that we will cease the active processing of your personal data, but we may retain some of your personal data until the expiry of the applicable limitation periods under Bulgarian law. 

If you withdraw your consent, your data may also be anonymised. Anonymisation is an alternative to data erasure. In the case of anonymisation, all recognisable elements allowing your identification are deleted. For anonymised data, there is no legal obligation for erasure, as they do not constitute personal data.

We will take appropriate technical and organisational measures to protect your personal data from unauthorised access or theft, as well as accidental loss, tampering or destruction. Access by our staff or third-party data processors engaged by us 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.

5. Who we share the data with, location, transmission

We rely on third-party data processors to provide you with the operation of the Platform and to process your personal data on our behalf. These third-party processors are permitted to process your personal data only on our behalf and under explicit written instructions from us. We guarantee that all third-party processors are selected with due care and are committed to ensuring the security and integrity of your personal data. These processors process data only for the purposes specified by Devin EAD and only have access to your data to the extent and for the period of time necessary to provide the services and always within the scope and time in which Devin EAD is entitled to process the data. These persons are obliged to comply with data protection legislation and the instructions of Devin EAD.

For orders to cities other than Sofia and Plovdiv, information about you and your order will be provided to a supplier who will deliver the ordered goods to you.

 

We do not send your personal data in a way that allows them to be shared with anyone other than the persons specified in this Article 5 without your explicit consent. However, we may send anonymous data to other organisations that may use that data to improve products and services.

As a rule, Devin EAD strives not to send data about Platform users outside the territory of the European Union (EU) and the European Economic Area (EEA). However, in certain cases it may be necessary to send certain data to processors outside the EU and EEA. In the event that such a transfer is necessary, it will be done in a manner which ensures compliance with all applicable data protection regulations in the EU and in a country which provides an adequate level of personal data protection.

Devin EAD may provide the data of users in the Platform to government authorities and institutions that, by virtue of the legislation in force, have the right to request the provision of information, including personal data, for example - courts, prosecutors, regulatory authorities /such as the Commission for Personal Data Protection, the Commission for Consumer Protection/, etc.

6. Your rights

As a data subject, you have the right to access the data we process about you, the right to rectification, the right to object to processing, the right to erasure of data, the right to withdraw a consent, the right to restrict data processing, the right to portability, the right to complain to a supervisory authority. You can exercise your right by sending an email to [email protected].

6.1. Right of access

You have the right to request access to any personal data related to you that we process. We reserve the right to charge an administration fee for multiple subsequent access requests that are made with the clear intention of causing us inconvenience or harm. Each request must specify for which processing activity you wish to exercise your right of access and which categories of data you wish to access.

6.2. Right of rectification

You have the right to request that any personal data related to you which is inaccurate be corrected free of charge. If you make a request for rectification, your request must be accompanied by proof of the inaccurate nature of the data for which you are requesting rectification.

6.3. Right to object

You have the right to object to the processing of your personal data which is based on our legitimate interest or is for direct marketing purposes, unless we provide compelling legitimate grounds for the processing which override your interests, rights and freedoms or to determine, exercise or defend legal claims. In certain cases, your right to object is unconditional and Devin EAD will cease processing the data within a reasonable period of time. These are the cases where Devin EAD processes data for direct marketing purposes - sending non-personalised messages. You can exercise your right to object by sending an e-mail. If you subsequently provide your consent, Devin EAD may resume sending such messages. In all other cases, depending on the nature of the objection, Devin EAD will carry out an internal check and inform you of the decision made - suspension of processing or reasoned refusal due to the existence of a legal basis for this.

6.4. Right to withdraw consent and right to erasure

You have the right to withdraw the consent you have previously given for the processing of your personal data. You have the right to request that personal data related to you be erased, if this data is no longer required within the context of the purposes stated in Article 3 above or if you withdraw your consent to the processing of the data where the processing of personal data is based on consent. However, we will assess the erasure request against:

The overriding interests of Devin EAD or any other third party;
The statutory or regulatory obligations, or administrative or court orders, that may be in conflict with such deletion.
Instead of erasure, you may also request that we restrict the processing of your personal data, if (a) you contest 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.

6.5. Right to restrict the processing

In certain cases, you have the right to request restricted processing of your personal data. For example, if you dispute the accuracy of your personal data, we may restrict its processing for the period during which we verify their accuracy. You may also request restriction of processing in cases where you no longer participate in the Platform, but the data must be kept for certain periods.

6.6. Right to portability of the data

You have the right to receive from us, in a structured, generally used, and machine-readable format, all personal data concerning you and to request that we transfer that data to another administrator where technically feasible.

6.7. The right to request the exercise of the above rights. Right to complain

If you wish to make a request to exercise one or more of the above rights, you can send an email to [email protected]. The email requesting the exercise of a right will not be construed as consent to the processing of your personal data beyond that required to process your request. This request must clearly state:

1. name, address, unique citizen number (EGN) or alien ID number (LNCh) or other similar identifier;

2. description of the request;

3. preferred form for receiving information when exercising your rights;

4. signature, date of submission of the request and address for correspondence.

We may also ask you to provide additional information necessary to confirm your identity.

We will notify you immediately of the receipt of this request. If the request proves to be valid, we will attend to it as soon as possible and at the latest within thirty (30) days of receipt of the request.

You can also exercise some of the above rights through the functionalities available in your user profile on the Platform.

In case of complaints, questions, uncertainties concerning the processing of personal data, you may contact us at any time. The contact details are: [email protected].

In addition, we inform you that you have the right to file a complaint or report with the Personal Data Protection Commission if you believe that there is a violation of the personal data protection legislation.

7. Supplementary provisions

We work continuously to improve our services. As a result, we may need to update this Policy from time to time to accurately reflect our services and practices. We will only make changes, if the clauses are no longer appropriate or are incomplete, if the changes are reasonable and necessary in light of your interests, and in order to comply with the legislation in force and effect.

This Policy is published at http://www.devin2u.bg. When you register in the Platform, you must confirm that you have read this Policy.

We reserve the right to amend this Policy from time to time at our discretion. If we need to update this Policy, the changes to this Policy will be effective as of the date it was posted at http://www.devin2u.bg, of which there will be an explicit notice.

This Policy is effective from 21.02.2024