Effective from August 2020


I. Introduction

We at INVENTSTREAM EOOD EOOD (hereinafter referred to as “INVENTSTREAM EOOD”) respect the privacy of our customers and guarantee the maximum protection of their personal data. This Privacy and Data Protection Policy (hereinafter referred to as the "Privacy Policy") has been prepared and is based on the current Bulgarian and European legislation in the field of personal data protection.
This Privacy Policy governs the processing of personal data of individuals or representatives of legal entities of our customers or potential ones, as well as users of our websites: www.whiteflower.bg, (the "Site"), in connection with the services provided by INVENTSTREAM EOOD, including provided through and available on the Site.

This Privacy Policy, together with the General Terms of Use of the Site, the Policy for the use of Cookies and any other documents mentioned on the Site, sets out the rules that INVENTSTREAM EOOD will follow when processing personal data that we collect from you. or for you, or which you provide to us. This Privacy Policy does not affect, restrict or revoke your rights arising from the Personal Data Protection Act (“PDPA”) or other relevant legislation.
If you have any questions or comments about this Privacy Policy, please contact us at: gdpr@whiteflower.bg
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, with a view to using certain services provided by us and the use of the Site and / or access to it, as well as with a view to 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 the product you have requested if you do not provide us with the necessary information. Please also keep in mind that in certain cases your consent to the processing of personal data may not be required if INVENTSTREAM EOOD has another legal basis, e.g. fulfillment of normatively established obligations.

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

INVENTSTREAM EOOD EOOD (“INVENTSTREAM EOOD”, “we”) is the company registered in the Commercial Register at the Registry Agency with UIC 201387413 which collects, processes and stores your personal data under the terms of this Privacy Policy. INVENTSTREAM EOOD is a personal data administrator within the meaning of the Personal Data Protection Act (PDPA). You can contact us at any of the following coordinates:
Address: Sofia, 1715, Mladost 4, bl. 485, ent.2
phone: 0885 844589
e-mail: gdpr@whiteflower.bg

III. Categories of personal data processed by INVENTSTREAM EOOD.

1. INVENTSTREAM EOOD may process publicly available personal data and / or personal data provided by you. The main types of personal data that are processed are:

(a) Personal identification information (including name, email address, language of communication, etc.);
(b) Contact details (including postal and e-mail addresses, telephone and fax numbers of you or a contact person designated by you, etc.);
(c) Financial information (bank account and others);
(d) Information about a representative (legal representative or proxy of such) of our client legal entity;
(e) Profile data on the Site (including name, postal and e-mail addresses, telephone number, etc.);
(f) Data on concluding contracts for sale, dealership, wholesale, deferred payment, etc. with natural or legal persons (such as names, PINs, etc.).

2. INVENTSTREAM EOOD may process data prepared and generated by INVENTSTREAM EOOD in the process of providing the services:

(a) details of the final electronic communications device used, the type of device, the operating system used, the IP address, the location;
(b) details of your preferred goods and services
(c) Data from the communication between us and you, habits, preferences, your satisfaction with our services (activity in using the services, complaints, requests, etc.);
(d) Information about visits to the Site and use of the Site, including operations and history of use of the Site;
(e) Data obtained in the performance of obligations arising from regulations (ie data arising from inquiries, regulations, investigative bodies, notary, tax authorities, court, bailiff);
(e) Video recording of site / office visits;

3. In order to ensure the good performance of the services and the obligations arising from customer contracts, INVENTSTREAM EOOD has the right to process any information that is available in public registers (including public database and data published on the Internet) as well as information received from third parties in connection with the implementation of legal provisions concerning customers.

4. INVENTSTREAM EOOD EOOD has the right and obligation to check the accuracy of the personal data recorded in the database, for this purpose it requires you to verify the data and, if necessary, to correct them or to confirm the truth of your data. The different types of personal data may be processed alone or in combination with each other.

ІV.Objectives and legal grounds for personal data processing

1. Processing of personal data that is necessary for the conclusion or execution of contracts with us or in connection with the preparation for the conclusion of contracts with us.

INVENTSTREAM EOOD processes your data for the following purposes:

(a) Identification of a client when: concluding a new or amending an existing contract with us; explanations for the used services; execution of a concluded contract.
(b) Data received from you in the performance of obligations arising from contracts concluded with you or a company represented by you, the exercise of rights and ensuring the performance of contracts by our customers;
(c) Administration and response to customer complaints / inquiries / complaints / complaints; return of amounts and goods; product replacement;
(d) Payment of debts, rescheduling of amounts due; management of receivables collections;
(e) Sharing important information regarding changes in our policy and other administrative information;
(f) Management and administration of online shopping activities; payment management.

2. In fulfillment of its legal obligations, INVENTSTREAM EOOD processes your data for the following purposes:
(a) Issuance of invoices;
(b) For tax and social security control by the relevant competent authorities;
(c) Fulfillment of obligations in connection with distance selling, off-site sales, provided for in the Consumer Protection Act;
(d) Provision of information to the Commission for Personal Data Protection in connection with obligations provided for in the data protection legislation - Personal Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016, etc. ;
(e) Obligations provided for in the Accounting Act and the Tax and Social Security Procedure Code and other related regulations in connection with the maintenance of proper and lawful accounting.

3. INVENTSTREAM EOOD processes the respective data provided with the explicit written consent of the client for their processing for the following purposes:
(a) Creating and managing a personal profile on the Site; technical assistance for creating account (s) and recovering a forgotten password to access our Site;
(b) Direct marketing of products and services;
(c) Participation and management of surveys, gift games, promotional campaigns;

4. The processing is necessary for the purposes of the legitimate interests of INVENTSTREAM EOOD.
(a) In order to protect and ensure the protection of the property, interests and security of INVENTSTREAM EOOD, its visitors and employees, INVENTSTREAM EOOD uses video surveillance equipment.
(b) Evaluate and establish customer satisfaction, as well as the effectiveness of the advertising we offer to you and others, and meet your expectations by presenting adequate advertising;
(c) Analysis of data on the history of purchases, preferences and customer behavior;

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

(a) Transport / courier companies, postal operators with a view to fulfilling our contractual obligations, sending correspondence and communications in connection with the contract between us, sending purchased goods;
(b) Persons who, on behalf of INVENTSTREAM EOOD, maintain equipment and software used for processing your personal data;
(c) Debt collection service providers, notary, lawyer, bailiff or other third party, if the client has breached the obligation arising from a contract with us;
(d) Banks servicing payments made to and from you;
(e) Persons to whom INVENTSTREAM EOOD has provided 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 INVENTSTREAM EOOD process your personal data on behalf of INVENTSTREAM EOOD;
(f) Persons performing consulting services in various fields - lawyers, accountants, marketing agencies, etc .;
(g) Authorities, institutions and persons to whom we are obliged to provide personal data under applicable law;

VI. How long is your personal data stored?

The duration of storage of your personal data depends on the purposes of processing for which they were collected:
1. The personal data processed for the purpose of concluding / amending and executing contracts between INVENTSTREAM EOOD and you or a company represented by you - for the term of the contract and until the final settlement of all financial relations between the parties. INVENTSTREAM EOOD may store some of your personal data for a longer period until the expiration of the relevant statute of limitations in order to protect against any claims of customers in connection with the execution / termination of contracts with us, as well as for a longer period in case of a legal dispute that has already arisen until its final settlement by an effective court / arbitration award;
2. Personal data processed for the purpose of issuing accounting / financial documents for tax and social security control, as well as not only - invoices, debit, credit notices, handover protocols, contracts for the provision of services / goods are stored at least 11 years after the expiry of the limitation period for repayment of the public receivable, unless the applicable legislation provides for a longer period.
3. The personal data processed for the purpose of issuing and administering and managing the account on the Site - until the explicit withdrawal of the given consent or receiving an objection for processing personal data for account management in INVENTSTREAM EOOD.
4. Personal data processed for the purpose of direct marketing - until the explicit withdrawal of the given consent for direct marketing or receipt of an objection for processing of personal data for direct marketing.

VII. Your Rights in connection with the processing of your Personal Data

1. General rights
In connection with the processing of personal data, you have the following rights, which you can exercise at any time while storing or processing your personal data by sending an application to the address of INVENTSTREAM EOOD, mentioned above, or by e-mail: gdpr @ whiteflower.bg.

You have the right to ask INVENTSTREAM EOOD:
• a copy of your personal data and access to them at any time;
• correct without undue delay your inaccurate personal data as well as data that is no longer up to date;
• your personal data in a form convenient for transfer to another controller of personal data, or to ask us to do so without being hindered by us (right of portability);
• your personal data to be deleted without undue delay in the presence of any of the legal grounds for this;
• restrict the processing of your personal data, in which case your data will only be stored but not processed. Our refusal to limit will be explicit only in writing, and we are obliged to motivate it with the lawful reason;

You also have the right to:
• to withdraw your consent for the processing of your personal data at any time with a separate request addressed to INVENTSTREAM EOOD, for processing based on a given consent;
• object to the processing of your personal data;
• object to automated processing, including profiling;
• not be subject to a solution based solely on automated processing, including profiling;

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

You have the right to file a complaint directly to the supervisory body, the competent body being the Commission for Personal Data Protection, address: Sofia 1592, Blvd. "Prof. Tsvetan Lazarov ”№ 2 (www.cpdp.bg).
In case you wish to file a complaint regarding the processing of your personal data by INVENTSTREAM EOOD, you can do so on the contact details of the Administrator or directly on the Data Protection Officer (on the above contact details).
3. Automated processing and profiling
When you visit our Site, we use automated processing to tailor products and services to your needs in the best possible way.

4. Objection to use for direct marketing

You have the right to object to the future processing of your personal data for the purposes of direct marketing and advertising, as well as to their disclosure to third parties and their use on their behalf for the purposes of direct marketing and advertising, by withdrawing your consent. anytime. For this purpose, you can send an e-mail with the relevant request to stop using your data for direct marketing purposes to: gdpr@whiteflower.bg

5. Can you refuse to provide personal data to INVENTSTREAM EOOD and what are the consequences?
In order 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 our legal and subsequent contractual obligations, INVENTSTREAM EOOD needs certain data to identify the party to the contract, its proxy, contact details, payment details.
Failure to provide such information prevents us from entering into a contract with you.
In order to make a purchase from our Site and to deliver the goods or services you have ordered, you must have created an account on the Site. During the process of creating an account, INVENTSTREAM EOOD needs certain data to identify you, contact details, payment details. Failure to provide such information impedes the ability to purchase and deliver goods or services from you.

VIII. How we protect your data

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

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

  • - INVENTSTREAM EOOD has established the requirements for processing, registration and storage of personal data with the internal procedures, the observance of which is constantly monitored;
  • - the access of the employees of INVENTSTREAM EOOD to personal data and the permission for processing of personal data in the database of INVENTSTREAM EOOD is limited, depending on their obligations;
  • - INVENTSTREAM EOOD has established confidentiality obligations for its employees;
  • - the access to the office equipment of INVENTSTREAM EOOD and the computers of each employee is limited.
  • - we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as the best practices of 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, etc.
    The security measures we apply are subject to constant improvement and adaptation to the latest technologies.

Link to other sites
Sometimes the Site may contain links (hyperlinks) to other sites. We do not operate the linked sites and do not endorse the content, services and products of these sites. We advise you to use the linked sites carefully and with due regard to their content and terms of use. INVENTSTREAM Ltd. is not responsible for the privacy policy or the content of such sites and we advise you to review their privacy policies. However, as soon as INVENTSTREAM EOOD receives information about illegal activities or illegal information on such Internet pages, INVENTSTRIM EOOD will take immediate measures to remove the electronic links to them.

X. Cookies Policy

To read the Cookies Policy on whiteflower.bg, please visit here.

Personal data for children
We do not knowingly collect personal information from children under the age of 16. If we learn or are notified that we have collected personal information from a child under the age of 16, we will take steps to delete the information as soon as possible or obtain the consent of the person responsible for the child.

Amendments to the Privacy Policy

We may periodically update our Privacy Policy. In the event of a change in this policy, a notice will be published on our website, as well as the updated Privacy Policy. All changes and additions to the Privacy Policy will be applied only after the publication of its current content, available through our Site.

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