This Personal Data Protection Policy (PDPP) aims to explain to you what information we collect about you, why and how we do it, what your rights are under the Personal Data Protection Act (PDPA) and the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 – GDPR – hereinafter referred to in this policy as "GDPR").

This PDPP is current as of February 1, 2023.

"ET Todor Oprev" reserves the right to change and/or supplement the PDPP at any time, with the changes entering into force immediately after their publication at: www. Opreff.com (The Site).

For the purposes of this PDPP:

"Personal data" means any information relating to an identified natural person or a natural person who can be identified by it – directly or indirectly, by name, unique number, address, and other location data, online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, and psychological, economic, cultural, or social identity of that natural person.

"Controller" means a body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union law or the law of the Republic of Bulgaria, the controller or the specific criteria for its determination may be established in European Union law or in Bulgarian law. In this case, the controller is

ET "Todor Oprev".

With its registered office and management address at Silistra, 24 Pleven St.

"Personal data processor" means a natural or legal person, public authority, agency, or other structure that processes personal data on behalf of the controller.

"Processing" means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.

"Supervisory authority" means an independent public authority of a European Union Member State responsible for monitoring the application of the personal data protection rules. For the Republic of Bulgaria, the supervisory authority is the Commission for Personal Data Protection.

Policy Objective:

This privacy policy aims to ensure that the Controller:

complies with the applicable legislation in the field of data protection and follows good practices

protects its users, employees, customers, and partners

ensures transparency about the ways in which subjects' personal data are stored and processed;

provides protection against risks associated with data breaches

How do we collect information about you?

We may collect information about you in several ways:

Through forms filled out and sent by you (requests; orders, reports, and other notifications) related to the services you use on the Site – by sending them, you knowingly share personal data and give your consent for it to be processed for the purpose for which you provided it, pursuant to Art. 6, para. 1, letter "a" of the GDPR. The volume of data is relative to the stated purposes.

Data collected through observation:

Sometimes we collect information about you by observing your behavior on the Site. For this purpose, we use standard Internet approaches to track user behavior, e.g., using network equipment to track your IP address, analyzing the information available as part of the communication in the protocols we use to record and exchange identifiers of you and your device, e.g., HTTP GET/POST requests, using JavaScript and other standard and widely used WEB programming languages to extract data and information about your context, etc. HTTP GET/POST requests, using JavaScript and other standard and widely used WEB programming languages to extract data and information about your browser, operating system, screen resolution, language, etc. By visiting our website, you knowingly share this personal data and give your consent for it to be processed for the purpose for which you have provided it in accordance with Article 6, paragraph 1, letter "a" of the GDPR.

Data received from third parties:

Sometimes we may receive data from third parties, e.g. data from your social media profile on Facebook. This data may be combined with other personal data about you that we already have. We only receive this data if you have previously given your express consent in accordance with Article 6(1)(a) of the GDPR via the partner's tools for your data to be collected and processed for this purpose and provided to third parties.

Cookies

ET "Todor Oprev" uses cookies on its website to store settings and identifiers necessary for providing the services listed on the Website. Some of these cookies are technically necessary for the normal functioning of the Website, while others are intended to facilitate its use by making it more functional and enjoyable for you. By visiting our website, you consciously share the personal data about you collected through cookies and give your consent for it to be processed for the purpose for which you have provided it in accordance with Article 6, paragraph 1, letter "a" of the GDPR. More information about ET "Todor Oprev" policy regarding cookies can be found in the Cookie Policy available on the Website.

What information do we collect and process when you use our services?

In forms filled out and sent by you, we collect personal data necessary for the purposes of the form. Typically, these are your names; mobile phone; e-mail; city and physical delivery address, data necessary for the purposes of payment and delivery of your requested orders. In this case, the collection of your personal data is necessary to fulfill our contractual obligations to you. In the event that you refuse to provide your personal data, we would not be able to fulfill your order.

When you fill out and submit forms, we collect personal data necessary for the purposes of the form. This usually includes your name, mobile phone number, email address, city and physical delivery address, and data necessary for the purposes of payment and delivery of your orders. In this case, the collection of your personal data is necessary in order for us to fulfill our contractual obligations to you by processing and delivering your order. If you refuse to provide us with your personal data, we will not be able to fulfill your order

Data collected through monitoring

For all visitors to the website, we usually collect the following data: the IP address from which you are visiting; your browser ID; your mobile device ID; your non-personal ID; your behavior history – pages visited, time spent on them, and others; behavior in relation to the content of the website/mobile application – navigation, interface elements used, time spent; your searches; behavior in relation to the advertisements served to you – what and how many advertisements are served; where they are served; advertisements viewed; clicks made, advertisements skipped, and others; your comments. In this case, the collection of your personal data is necessary in order for you to access the Site and use its functionalities in the most optimal way according to your preferences. If you refuse to provide us with your personal data, you will not be able to access or use the full functionality of the Site.

Data obtained from third parties

Depending on the source of the data, this includes: basic profile information such as name, email address, date of birth; details you choose to share according to your specific social media account settings; your contacts and how you connect with them. In this case, the collection of your personal data is necessary in order for you to use the features of the Site in the most optimal way according to your preferences. If you refuse to provide us with your personal data, you will not be able to use the full functionality of the Site.

For what purposes do we process the information?

The information we collect and process about you may be used for the following purposes:

Normal functioning of the Website

This data is strictly necessary for the normal functioning of the Website. It allows us to show you better content, load the Website faster, and protect the Website and you from attacks. Such data includes, for example, data from your session – cached content and others. This also includes data related to your identification in connection with the use of our service.

For contractual performance of our services

We use your personal data to complete the process of selling and delivering the goods you have selected.

For storing and accessing information

This purpose is ancillary to the fulfilment of other purposes – by using various technical mechanisms, we will be able to fulfil any of the other purposes described. This includes storing and accessing information stored on your device, e.g., device identifiers, user identifiers, advertising identifiers, cookies, and other technologies.

To process your personal data, including for provision to competent authorities in cases provided for by law and for the fulfillment of legal obligations of ET "Todor Oprev," as well as for purposes related to the fulfillment of the obligations of the parties under the contract.

Who else has access to this information?

We sometimes disclose your personal information to third parties – partners of ET "Todor Oprev" or bodies authorized by law to verify and/or control our activities, such as:

Industrial recognized solution providers who have publicly declared compliance with GDPR and e-privacy policies, such as Google and Facebook. Consent also includes the placement and use of unique depersonalized identifiers, including the use of cookies, localStorage, or other appropriate generally accepted web technology;

Third parties providing services to ET "Todor Oprev" such as Accountants and accounting firms; Auditors and Auditing firms; Lawyers - Attorneys, law firms, and legal advisors; Notaries; Advertising and PR agencies; Companies performing data administration activities; Competent authorities in the cases provided for by law and for the performance of the legal obligations of ET "Todor Oprev".

How long do we store your data?

We store the personal data you provide to us only until the purpose for which you provided it has been achieved. We may store the personal data you provide to us after this period only if its storage is related to the fulfillment of our regulatory obligations.

What are your rights in relation to personal data?

You have the following rights when it comes to the processing of your personal data:

The right to withdraw your consent to the processing of your personal data at any time. Withdrawing your consent to the processing of your personal data does not affect the lawfulness of the processing based on your consent before its withdrawal;

To request correction or supplementation of your data in case of inaccuracy by sending us a written request;

Right of access to your personal data;

Right to restrict the processing of your personal data;

Right to object to the processing of your personal data;

Right to data portability;

Right to request the deletion of your personal data that is being processed unlawfully or without legal basis (withdrawn consent, fulfilled initial purpose for which it was collected, etc.);

Right to request that the Controller of your personal data notify third parties to whom the Controller has provided your data regarding the correction, deletion, or restriction of the processing of personal data.

You have the right to lodge a complaint with the Personal Data Protection Commission when you believe that your rights under this policy or applicable laws have been violated.

How can I obtain, update, and manage my personal data?

You can obtain additional information about the processing of your personal data by the administrator ET "Todor Oprev" by sending an explicit request to that effect. You can send your request to the following address: Silistra 24 Pleven Street – in person, by letter, or to the following email address: [email protected]

You can easily update and manage your information collected through the Site's features. Additional information on how to do this can be found in the Privacy Policy published on the Site.

COOKIE POLICY

This information on the use of cookies is intended to familiarize you with the features and purpose of using cookies on the website of Oprev Winery (https://www.opreff.com/en).

WHAT ARE "COOKIES"?

Cookies are small text files containing a limited set of text information that are loaded into your browser and temporarily stored on your end device (computer, smartphone, or other terminal device) for the duration of your visit or for a longer period, depending on the type of cookie. Each cookie is unique to your browser and contains anonymous information. Cookies usually contain the name of the website to which they belong, the time they are stored on the user's computer, and a unique number.

WHAT "COOKIES" DO WE USE AND WHY?

MANDATORY COOKIES

These cookies allow you to use the full functionality of our website. You can set your browser to block or alert you about these cookies, but some parts of our website will not work without them. These cookies do not store any personal information about you.

THIRD-PARTY COOKIES

We also use some third-party cookies as part of our services. These cookies are managed by the relevant organizations and are not controlled by us. Below is a list of the third-party cookies we use, some of which can be disabled using your browser's general settings. For others, you will need to visit the relevant websites and follow the instructions provided there.

GOOGLE ANALYTICS

Our website uses Google Analytics. Thanks to the cookies used by this tool, we monitor traffic to our website and can analyze how easy it is for our users to navigate it. They show us which pages of the site our users view, what devices they use, how much time they spend on our site, and other anonymous data. These cookies do not provide us with any information about your personal data. We store analytical data in Google Analytics for a period of 26 months.

Details on how Google collects and processes data can be found at the following link: https://goo.gl/mVozWw

FACEBOOK-PIXEL

Our page uses Facebook Pixel. Facebook Pixel is an HTML code that allows us to set, measure, and optimize our audience when conducting marketing campaigns. Facebook Pixel measures conversions on different devices, allows automatic creation of target groups of website visitors, as well as retargeting and creating dynamic ads. The data collected in this way is anonymous to us and we do not receive any information about the identity of users.

More information about how Facebook collects and processes data can be found at the following link: https://goo.gl/5oS5dj

COOKIE MANAGEMENT

Most browsers allow cookies to be placed on the user's end device by default. If you wish, you can change your browser settings and delete cookies that are currently stored on your device, as well as automatically block future cookies (including those from third parties).

Information about browsers and how to set your cookie preferences can be found on the following web pages or in other documentation for the internet browsers you use:

Chrome

Firefox

Internet Explorer

Android

iPhone и iPad