WHO IS REPONSIBLE FOR THE PROCESSING OF MY DATA AND WHO IS THE DATA PROTECTION OFFICER?

The responsible party for data processing in the sense of Art. 4 No. 7 of the General Data Protection Regulation (GDPR) is:

Name: Zero Counter Ltd.

Address: 1 Volna Pesen str., residential area Zora, Stara Zagora, Bulgaria

Registration with the Commercial Register of the Republic of Bulgaria � UIC/BULSTAT: 205886552

Registration under the Value Added Tax Act: No. BG205886552

Telephone: +359 890� 515 692

 

WHAT IS THE SUBJECT OF DATA PROTECTION?

Data protection law governs the handling of personal data. Personal data are information relating to an identified or identifiable natural person (hereinafter referred to as „data“).

 

WHAT CATEGORIES OF DATA DO WE PROCESS AND WHERE DO THEY COME FROM?

Through your use of our store, we particularly process the following categories of data:

Data you provide us: In the context of your order, when contacting us (e.g., via contact form or email), or when opening a customer account, you provide us with data. The specific data you provide can be seen from the respective input forms. For example, this may include your name, your email address, your telephone number, your other contact details including your address, or your payment data. You can recognize from the input form whether you are obligated to provide us with the respective data. �When you visit our website, we may also store access data in so-called server log files.

Data we collect from third parties: When you order from our store, we may also collect data about you from third parties, such as credit agencies and payment service providers.

Cookies: To make the visit to our website attractive and to enable the use of certain functions, we use so-called cookies or similar technologies on our website, including for advertising and analysis purposes. Further information on this can be found in our Cookies Policy. You can change your cookie preferences there at any time.

Special categories of personal data: We do not collect and process any special categories of personal data.

 

FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS IS MY DATA PROCESSED?

We process your data for the purposes listed below. Generally, you are neither legally nor otherwise obliged to provide us with your data for these purposes. However, without your data, we may not be able to offer you our website and services.

Contract-related processing purposes on the legal basis of Art. 6 para. 1 sentence 1 lit. b) GDPR

Opening a customer account: To open a customer account, you must first register with us. During this registration, we process certain data from you, such as your name and email address. The exact data we collect can be seen from the respective input form. We collect this data to establish a customer account for you.

Data collection and use for contract processing: We collect and process data when you provide it to us as part of your order. The data collected can be seen from the respective input forms. We use the data you provide to fulfill our contractual obligations to you and to process your requests, especially for processing your order, handling your payment, and for contract-related communication with you, such as answering questions and complaints. Thus, your data is necessary for contract execution, especially to process your order. The input forms indicate which information is required and which additional information you may optionally provide.

Data processing based on consents under the legal basis of Art. 6 para. 1 sentence 1 lit. a) GDPR

Use of your data for advertising and analysis purposes: We use your data based on your consent to contact you for advertising purposes (newsletter, customer satisfaction surveys, availability notifications) by email. If you give us your consent, we personalize the content of the newsletters according to your interests. We also use your data based on your consent to display interest-based advertising on our website and the websites of our advertising partners, based on cookies or similar technologies we use. Additionally, with your consent, we use cookies or similar technologies that enable us to offer you certain convenience functions and to analyze website usage to measure and improve its performance. Further information on the use of cookies and similar technologies can be found in our cookie settings.

You can revoke your consent to the use of your data for advertising and analysis purposes at any time with effect for the future. For email advertising, you can click the unsubscribe link in the respective advertising messages or contact us at via the email address provided on our website�or via the address mentioned in section 1 of this privacy policy. You can revoke your consent to the use of cookies and similar technologies in our cookie settings.

Data processing to fulfill legal obligations on the legal basis of Art. 6 para. 1 sentence 1 lit. c) GDPR

Data security: In operating the online store, we must fulfill legal obligations. This includes, among other things, the obligation to ensure the security of your data when using the store. For this purpose, we may process your data as part of measures to ensure data security.

Retention obligations: We must also retain certain data (e.g., commercial letters and receipts) for a legally specified period. Such data may only be deleted after the legally specified retention periods have expired, even in the case of deletion requests.

Data processing based on legitimate interest under the legal basis of Art. 6 para. 1 sentence 1 lit. f) GDPR

Below you will find information on data processing, including transmissions, which we carry out on the legal basis of our legitimate interest in the respective purpose of processing, as described in more detail below. Processing only takes place if it is necessary to protect our legitimate interests or those of a third party and does not outweigh your interests, fundamental rights, and freedoms. If you need more information on the interest assessment carried out, please contact us using the address mentioned in section 1 of this privacy policy.

Storage of access data in server log files: During your visit to our online store, we store access data in so-called server log files, such as the name of the requested file, date and time of access, amount of data transferred, and the requesting provider. If personal data is processed in this context, this processing is based on our overriding legitimate interest in ensuring the trouble-free operation of the website and improving our offer.

Country and language preference: When you first access our store or if you delete our country preference cookie, you will be asked to select the country relevant to your order and possibly a language for that country so that we can display the prices in our store in the respective currency. Based on your IP address, we can also suggest suitable countries via a pop-up window, which our service provider determines as the likely delivery region based on your IP address. The data processing is based on our overriding legitimate interest in providing a user-friendly website.

Product recommendations: When you order goods from us, we can use your data to send you product information about similar products. This is based on our legitimate interest in being able to make suitable product recommendations to you. You can object to our use of your data for these advertising purposes at any time with effect for the future. For this purpose, you can click the unsubscribe link in the respective advertising messages or contact us at the email address provided on our website or via the address mentioned in section 1 of these privacy information.

Credit check and fraud prevention: We use your data to reduce the risk of payment defaults and fraud in online orders and the operation of our online store, especially if you choose payment by invoice. This is based on our legitimate interest in protecting ourselves and our customers and other users from misuse of your data, especially through fraudulent orders. For this purpose, we process, in particular, device and access data as well as purchase and payment data. We work with credit and fraud prevention service providers, who provide us with credit data, such as information for assessing the risk determined for your person by our service providers. The processing of your data for the aforementioned purposes is necessary for contract execution, and without the data, we may not be able to fulfill your order. You can object to our use of your data for these purposes at any time with effect for the future, stating the reasons arising from your particular situation. For this, you can contact us at the email address provided on our website or via the address outlined in section 1 of these privacy information.

 

WHO WILL MY DATA BE SHARED WITH?

Even when we share your data with service providers, we ensure that your data is processed, protected, and transmitted in accordance with applicable legal requirements.

We transfer your data to the following entities for the respective purposes:

Shipping

As part of fulfilling your order and for the purpose of parcel delivery, we pass on your data to shipping or transport companies based in the EU, as far as it is necessary for the delivery of your ordered goods.

The transfer of data is necessary for processing your order and thus for fulfilling our contractual obligations and is therefore based on Art. 6 para. 1 sentence 1 lit. b) GDPR.

Credit Check

If you decide to make a purchase on account, we have a legitimate interest in being able to assess the associated economic risks before concluding the contract. If you have selected the payment method „purchase on account,“ we therefore transfer your data (name, address, and possibly date of birth) for the purpose of credit assessment, to assess the risk of payment default based on mathematical-statistical procedures using address data, and to verify your address (delivery check) to a financial service provider. The legal basis for these transfers is Art. 6 para. 1 sentence 1 lit. f) GDPR. The transfer is based on our legitimate interest in ensuring your creditworthiness when purchasing our products on account.

Fraud Prevention

We conduct a fraud check on orders and transfer your order data to our service providers for this purpose. If an order is classified as risky as a result of the check, your order may be canceled.

For purchases on account or payment via PayPal, we transfer your order data (name, address, gender, date of birth, cart value, order time, IP address, payment method) to a service provider based in the EU for the purposes of fraud prevention.

If you select a credit card as the payment method, we transfer your order data to a service provider based in the USA. In the fraud check by this service provider, probability values are used to identify orders that pose a fraud risk to us. You can always receive more information about how our service provider processes personal data from us using the contact details shown in section 1 of these privacy information. If you do not agree with a data transfer to this service provider, please use a different payment method.

The legal basis for these transfers is our legitimate interest in preventing fraud cases at your or our expense, Art. 6 para. 1 sentence 1 lit. f) GDPR.

Debt Collection

If there are outstanding claims from your orders, we will contact you by email with a renewed payment request. If you do not comply with this request despite the existence of a legitimate claim, we may hand over the enforcement of the claim to our collection service provider, to whom we will pass your order and contact details for this purpose.

The legal basis for transmitting your data to this service provider is its necessity for contract performance, Art. 6 para. 1 sentence 1 lit. b) GDPR.

Newsletter, Personal Product Recommendations, and Surveys

For the technical handling of newsletter distribution and personal product recommendations, as well as personalized messages based on user behavior via email, a service provider is used.

We also use a service provider for conducting customer satisfaction surveys to receive customer feedback, e.g., regarding awareness of our brand and our products.

Our partners process your data exclusively according to our instructions and on our behalf. We have contractually ensured that our partners comply with all data protection requirements. The scope of the transmitted data is limited to the necessary minimum. The transfer of data is based on Art. 28 para. 1 GDPR.

Furthermore, as part of the use of tracking functions on our website, we transfer additional data for advertising purposes to third parties. For more information, including your configuration options, please see our cookie settings.

 

WILL MY DATA BE TRANSFERRED TO A THIRD COUNTRY?

Some of our service providers and group companies to whom we transmit your data are located outside the European Economic Area (EEA). In these countries, the protection of your personal data may not be comparable to that under the GDPR. In particular, government agencies in these countries may have the right to access your data without effective legal remedies available to you to oppose this. Such a transfer therefore only takes place if the EU Commission has confirmed an adequate level of data protection in the third country (Art. 45 para. 1 GDPR) or if you have given us your explicit consent to transfer your data to recipients outside the EEA (Art. 49 para. 1 lit. a) GDPR). Otherwise, we ensure through appropriate contractual, technical, and/or organizational measures (especially by agreeing to the EU standard contractual clauses and additional measures and regular reviews) that an adequate level of data protection is maintained. Further information and copies of the EU standard contractual clauses can be obtained using the contact details provided in section 1 of these privacy information.

 

HOW LONG WILL MY DATA BE STORED?

Your data will be stored in accordance with Art. 5 para. 1 lit. e) GDPR as long as we are legally obliged to do so or as long as we need your data for the purposes mentioned above. Subsequently, the processing of your data will be restricted or your data will be deleted to comply with the principles of data minimization and storage limitation.

If you need more detailed information regarding our deletion and retention periods, please contact us using the address shown in section 1 of this privacy policy.

 

WHAT DATA PROTECTION RIGHTS CAN I EXERCISE AS A DATA SUBJECT?

You can assert your data subject rights, as described in more detail below. You can reach us via the contact details provided in section 1 of this privacy policy.

Right to Access

You can request information according to Art. 15 GDPR about your personal data processed by us. In your request for information, you should specify your concern to facilitate the compilation of the necessary data. Please note that your right to information may be limited under certain circumstances according to legal regulations.

Right to Rectification

If the information concerning you is not (or no longer) accurate, you can request rectification according to Art. 16 GDPR. If your data is incomplete, you can request completion.

Right to Erasure

You can request the erasure of your personal data under the conditions of Art. 17 GDPR. Your right to erasure depends, among other things, on whether we still need the data concerning you for fulfilling our contractual or legal obligations.

Right to Restriction of Processing

You have the right, under the provisions of Art. 18 GDPR, to request a restriction on the processing of your data.

Right to Object

According to Art. 21 GDPR, you have the right to object at any time to the processing of your data for reasons arising from your particular situation. However, we may not always be able to comply with this, e.g., if legal regulations oblige us to process your data. If we process your data for direct marketing purposes, you can object at any time to the processing (Art. 21 para. 2 GDPR).

Right to Lodge a Complaint with a Data Protection Supervisory Authority

We commit to working with you to find a fair solution to any complaints regarding data protection.

Regardless, you also have the right to lodge a complaint with a data protection supervisory authority, especially in the EU member state of your residence, place of work, or the place of the alleged infringement, if you believe that the processing of your personal data by us violates applicable data protection law.