General Terms And Privacy Policy

“Business as Poetry” EOOD is a legal entity incorporated and operating in accordance with the Commercial Act, registered in the Commercial Register with UIC: 208690765, registered office and principal place of business: Sofia 1606, Krasno Selo District, 1 St. Ivan Rilski Str., Floor 4, Apt. 8, represented by its Manager — Bistra Vaceva.

This Privacy Policy has been prepared in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, the Personal Data Protection Act (PDPA), and Ordinance No. 1 of 30.01.2013 on the minimum level of technical and organisational measures and the permissible types of personal data protection.

The purpose of this Privacy Policy is to inform you of what personal data the Company processes, how it collects such data and for what purposes, to whom it discloses such data, what your rights are as clients, suppliers and partners in relation to the personal data being processed, and how you may exercise those rights.

Definitions

“Personal Data” means any information relating to the Company’s clients (natural persons and natural persons representing legal entities), as well as information relating to its employees, who are identified or by means of which they may be identified directly or indirectly through an identification number or through one or more specific characteristics.

“Processing of Personal Data” means any action or set of actions that the Company performs in respect of personal data by automated or non-automated means (collection, recording, organisation, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination, provision, updating or combining, blocking, erasure or destruction, etc.).

“Specific Characteristics” means characteristics related to the physical, physiological, genetic, mental, psychological, economic, cultural, social or other identity of the individual.

“Consent of a Natural Person” means any freely given, specific and informed expression of will by which the natural person to whom the personal data relates unambiguously consents to their processing.

“Data Subject” means the natural person whose data is being processed.

Principles for Processing Personal Data

The Company adheres to the following principles when processing personal data:

  • Personal data is collected and processed lawfully and in good faith, in accordance with the principles and rights of natural persons in relation to the processing of their personal data.
  • The Company ensures transparency in communications regarding collected and processed personal data, using clear and unambiguous language in an understandable and readily accessible format.
  • Personal data is collected and processed for specific, explicit purposes only.
  • The Company does not collect or process personal data that exceeds its legal obligations or commercial needs.
  • Only the minimum necessary personal data is collected — that which is required by law, necessary for the performance of a contract, or necessary to fulfil the purposes for which it was collected — specifically, data that is retained only for as long as:
    • required by law;
    • necessary for the performance of a contract (including an order) and the related obligations;
    • necessary to fulfil the purpose for which the data was collected and processed; or
    • until the natural person requests its erasure, following which it is destroyed without undue delay.

In all cases, the Company ensures that collected and processed personal data is reviewed at least once a year, and any data falling within one of the above categories is erased without undue delay.

  • Processed personal data is accurate and kept up to date.
  • Personal data is processed by the minimum number of persons necessary who have the requisite competence and commitment to safeguard such data.
  • Personal data is stored for the minimum period necessary.

Purposes of Processing

“Business as Poetry” EOOD processes personal data for the following purposes:

  • Verifying the identity of clients, suppliers and partners at all stages of communication.
  • Managing and fulfilling client requests for products or services, and performing product and service contracts.
  • Preparing contract proposals.
  • Preparing and sending invoices and statements for products and/or services.
  • Providing comprehensive client service and collecting amounts owed for products and services received.
  • Providing technical support to ensure the highest quality products and services as agreed.
  • Notifying clients of anything related to the products and services they receive.
  • Evaluating and measuring advertising effectiveness, and delivering advertising content relevant to client needs.
  • Researching and analysing client demand for products or services, based on anonymous or personalised information, to identify key trends and improve understanding of client behaviour.
  • Complying with statutory obligations, including those under the Accountancy Act, the Tax and Social Insurance Procedure Code, the Personal Data Protection Act, and Regulation (EU) 2016/679.

“Business as Poetry” EOOD also processes personal data in order to:

  • Provide comprehensive client service and collect amounts owed for products and services received.
  • Provide technical support to ensure the highest quality products and services as agreed.
  • Prepare proposals for contracts and agreements, conclude such contracts and agreements, and send pre-contractual information and draft contracts by courier, until an agreement is reached.
  • Notify clients of anything related to the products and services they receive from “Business as Poetry” EOOD.
  • Perform contracted services for clients through “Business as Poetry” EOOD and its suppliers and subcontractors, where the processing of personal data forms part of that process.
  • Evaluate and measure the effectiveness of “Business as Poetry” EOOD’s advertising, and to deliver advertising content relevant to client needs.
  • Research and analyse client demand for products or services, based on anonymous or personalised information, to identify key trends and improve understanding of client behaviour.

“Business as Poetry” EOOD also processes identification data and data for the preparation of offers, contracts, invoices, delivery notes, statements and other documents in order to comply with statutory obligations, including:

  • Obligations to provide information to state supervisory authorities.
  • Obligations to provide information to the Commission for Personal Data Protection in connection with requirements under the Personal Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016, and other applicable legislation.
  • Obligations under the Accountancy Act and the Tax and Social Insurance Procedure Code and related legislation, in connection with keeping proper and lawful accounting records.
  • Obligations to provide information to courts and third parties in the context of judicial proceedings, in accordance with applicable procedural and substantive law.

“Business as Poetry” EOOD processes personal data only with prior consent.

Types of Personal Data Processed

The Company may process the following categories of personal data:

  • Full name, permanent address.
  • Data related to electronic communications services.
  • Data for the preparation of offers, contracts, invoices, delivery notes and other documents.
  • Information about the type and content of contractual relationships, including call recordings.
  • Other feedback received from clients.
  • Contact details: correspondence address, email address, telephone number.
  • Personal data related to competitions or promotions organised by the Company.
  • Marketing surveys of preferences for products or services.
  • Bank account number or other banking and payment information.
  • Client number, code or other identifier created by the Company for client identification.
  • Data submitted via the Company’s website or mobile applications.
  • Information about the terminal electronic communications devices used, device type, operating system, and IP address when visiting our website.

Where we process personal data and the other data described above for the purposes of providing products and services, for payment thereof, and in order to fulfil our statutory obligations, such processing is mandatory. Without this data, we would be unable to provide the relevant services. If identification data is not provided to us, we would be unable to conclude a product or service contract. No registration is required to visit our website, which means you may browse it without identifying yourself to us. In order to respond to your enquiries submitted via the contact forms on our website, it may be necessary for you to provide personal data. If you choose not to provide the personal data requested, you will be unable to access certain services or sections of the website, and we will be unable to respond to your enquiry.

Consent to Processing of Personal Data

Consents provided by data subjects for the processing of their personal data may be withdrawn at any time. Withdrawal of consent may affect the performance of the contractual obligations of “Business as Poetry” EOOD. If a data subject withdraws consent for processing for any or all of the purposes described above, the Company will cease to use that personal data for those purposes. The withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.

Withdrawal of personal data may result in the inability to perform some or all of the services provided by “Business as Poetry” EOOD. The data subject will be informed of the potential consequences of each withdrawal before it takes effect. In the case of electronic direct marketing, we will provide you with a means to opt out of receiving marketing materials, or a means to opt in, where required by law.

To withdraw consent, you must notify “Business as Poetry” EOOD using the publicly available contact details (telephone, email, etc.). In your communication, please specify the name of the website on which you provided the information, as well as the specific information you wish to have corrected, updated or deleted, together with appropriate proof of identity.

Erasure of Personal Data

The Company ceases using personal data for purposes related to the contractual relationship upon termination of the contract, but will not erase it before all financial obligations have been fully settled and the statutory retention periods have expired. These include: obligations under the Electronic Communications Act (6 months); obligations under the Accountancy Act (11 years); limitation periods under the Obligations and Contracts Act (5 years); obligations to provide information to courts and competent authorities (5 years); and obligations under employment law (50 years).

Personal data will not be erased or anonymised if it is required for pending judicial, administrative or complaint proceedings. In certain cases, personal data may be anonymised as an alternative to erasure. Upon anonymisation, all personally identifiable elements are irreversibly removed. No statutory obligation to erase exists for anonymised data, as it no longer constitutes personal data.

Processing of Personal Data

“Business as Poetry” EOOD uses identification data and data for the preparation of offers, invoices, statements and any other documents connected with its legitimate interests in order to carry out fundamental analysis aimed at tailoring the products and services we offer to individual client needs, and at developing new products and services to meet those needs. The handling of personal data is also required where a user wishes to participate in a competition, receive a consultation, or submit a question via the contact forms on the Company’s websites or social media pages.

Personal data may also be processed for statistical purposes, meaning for analyses whose results are aggregate only and whose data is therefore anonymous — for example, to assess our market performance, financial indicators, marketing information, and similar matters.

Protection of Personal Data

To ensure adequate protection of employee, client and partner data, “Business as Poetry” EOOD applies all necessary organisational and technical measures provided for under the Personal Data Protection Act, as well as best practices. Additional safeguards such as encryption and pseudonymisation may be applied to maximise security during the processing, transfer and storage of personal data.

Disclosure to Third Parties

The Company may disclose personal data to the following categories of recipients, subject to the necessary technical and organisational protective measures having been put in place:

  • Credit agencies.
  • Debt collection and enforcement companies.
  • Postal and courier operators, for the purposes of dispatching documents requiring identity verification upon delivery.
  • Persons maintaining equipment, software and hardware used for data processing and network infrastructure.
  • Service providers assisting with the sale of products and services and pre- and post-contractual client support.
  • Authorities, institutions and persons to whom the Company is legally required to provide personal data.
  • Competent supervisory authorities (courts, prosecution services, the Commission for Personal Data Protection, the Commission for Consumer Protection, the Communications Regulation Commission, and national security and public order authorities).
  • Providers of electronic trust services, where documents are signed with a qualified electronic signature.
  • Banks for card issuance and payment processing, including salary and other remuneration payments.
  • Archive management service providers.
  • Professional consultants in various fields.

Website Visits

When you visit our website, the following data is processed and logged:

  • Browser type and version.
  • Operating system used.
  • Referrer URL (previously visited page).
  • Hostname of the accessing computer (IP address).
  • Time of the server request.

Cookies

In addition to the personal data described above, “Business as Poetry” EOOD uses cookies on its website and associated websites to provide visitors with more relevant commercial and other content. A cookie is a small piece of information sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. They are typically used to authenticate registered users as part of the login process, so that you are not required to re-enter your username and password on each subsequent visit. Other uses of cookies include maintaining a shopping basket, personalising the site (presenting different pages to different users), and tracking individual user access.

Some cookies remain stored on your device until deleted, allowing the Company to recognise your browser on future visits. If you do not wish this to occur, you may configure your browser to notify you of cookie use and to allow cookies only in specific cases. Disabling cookies may limit the functionality of our web pages.

Web Analytics

The Company’s website uses Google Analytics, a web analytics service provided by Google LLC, Mountain View, CA 94043, USA. Google Analytics uses cookies to analyse how users interact with our website. The information generated by cookies about your use of the website, including your IP address, will be anonymised and transmitted to Google servers in the United States. Google uses this information to evaluate website usage and prepare reports on website activity. You may opt out of cookie tracking by downloading and installing the free Opt-out Browser Add-on, available at: https://tools.google.com/dlpage/gaoptout?hl=en. Please note that opting out may limit the functionality of our website. By using our websites, you consent to the processing of your personal data by Google in the manner and for the purposes set out above.

Statistical Research and Analysis

Our website may contain single-pixel files or web tags (also known as action tags, single-pixel GIFs, clear GIFs, invisible GIFs, or 1x1 GIFs), which are called from the server of an electronic services provider. These may be implemented through a third-party advertising partner or web analytics partner, which stores technical information, including browser data, IP address, and time of request. This information is used to improve the service technically, refine target groups and their reading habits, and to measure the effectiveness of advertising campaigns. For further information or to opt out, visit the Network Advertising Initiative website at: http://www.networkadvertising.org.

Rights of Data Subjects

Right of Access

Data subjects have the right to request:

  • Information on whether personal data is being processed, the purposes of such processing, the categories of data, and the recipients or categories of recipients to whom the data is disclosed.
  • A communication in an understandable form containing the personal data being processed and any available information about its source.
  • Information about the logic of any automated processing in cases of automated decision-making (e.g. client profiling or marketing profiling).

Right of Rectification

Where the Company processes incomplete or incorrect data, data subjects may at any time request:

  • The erasure, rectification or blocking of personal data whose processing does not comply with the requirements of the law.
  • Notification of third parties to whom personal data has been disclosed of any erasure, rectification or blocking, except where this is impossible or involves disproportionate effort.

Right to Object

Data subjects may at any time:

  • Object to the processing of personal data where there is a legal basis for such objection; where the objection is well-founded, the personal data in question may no longer be processed.
  • Object to the processing of personal data for marketing purposes.

Contact Details

If you have any questions or concerns about the processing of your personal data, or wish to exercise any of your rights, please contact us at:

  • Email: hello@businessaspoetry.com
  • Telephone: +44 7956 449543
  • Contact person: Hristina Vaceva