Privacy policy
Privacy Policy
"Modena 44" Ltd.
(Notice regarding the processing of personal data)
Personal Data Controller:
Name: "Modena 44" Ltd.
UIC (Company ID): 208914099
Registered office and management address: Stara Zagora, "St. Patriarch Evtimiy" Blvd. 57, apt. 36
Phone: +359 886 356 213
Email address: racecafe44@gmail.com
Website: www.racecafe44.com
"Modena 44" Ltd. (the "Company" or the "Controller") conducts its activities in accordance with the Personal Data Protection Act and 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 (the "General Data Protection Regulation" or the "Regulation"). This Privacy Policy (the "Privacy Policy" or the "Policy") aims to inform every Client (as defined below) of the Company about the processing of data by which a specific Client is identified or can be identified.
For the purposes of the Policy, a "Client" is any natural person who is a party to a contract with the Company for the purchase and sale of goods, as well as a natural person who has expressed the will to enter into pre-contractual relations with the Controller and/or a user of the Online Store, accessible on the Internet at: www.racecafe44.com, as well as a director, manager, representative, authorized agent, employee, partner, shareholder, beneficial owner of a legal entity or other legal structure using the Online Store.
1. What personal data do we process?
The Company processes, as a personal data controller, the following categories of Clients' personal data:
Physical identity – names, phone, email address;
Economic identity – bank account number information.
The personal data is collected by the Controller from the individuals to whom it relates.
2. How we collect personal data
We collect personal data:
during the registration process on the Online Store's website and when using the Online Store without registration;
when carrying out correspondence with the Client, which may include communication in written form, including electronic form, and oral form;
through "cookies" when using or browsing our website.
In some cases, we may also collect information from third parties or from public sources.
Our website collects data in log files. This information contains data about your IP address, internet provider, the browser you use, your operating system, when you visited our website, and the pages visited.
Our website uses "cookies." Cookies are small files of information that the website sends to the visitor's browser. The browser stores this information in a text file on the user's end device. They help us make our website work better for you. More information about the use of "cookies" can be found in our Cookie Policy, published on the Online Store's website: www……………….com.
3. Do we process special categories of personal data?
The Company does not process special categories of Clients' personal data.
4. For what purposes do we process personal data?
The Company processes Clients' personal data for the following purposes:
providing information and assistance that you have requested from us;
identifying and contacting clients and beneficial owners;
for all activities related to the existence, modification, and termination of the relationship between the Company and the Client;
offering and promoting additional services;
compliance with regulatory requirements;
providing protection in the event of a dispute and cooperation with regulatory authorities to the extent required by law.
If we do not process this personal data, we may not be able to provide you with our services or the assistance you have requested.
5. On what legal basis do we process personal data?
Clients' personal data is collected, processed, and used on the basis of several grounds for processing:
For the performance of a contract or for entering into pre-contractual relations;
For compliance with a legal obligation applicable to the Company;
For the purposes of the legitimate interests of the Company or a third party, where the rights and interests of the data subjects do not override them – for resolving disputes; for preventing, detecting, and investigating fraud, violations, or other unlawful conduct; for the establishment, exercise, or defense of legal claims;
Under the conditions of freely given consent, where this is required under applicable law.
6. For how long do we store personal data?
The Company stores personal data during the contractual relationship and until the settlement of the claim under the contract, and during a transitional period (e.g., to comply with obligations related to the archiving and storage of accounting data). If legal or other action is initiated, personal data may be stored until the end of such action, including all possible appeal periods, and thereafter will be deleted or archived as permitted by applicable law. Specifically, the various media of accounting and tax information containing personal data are stored for a period of 10 years, starting from January 1 of the reporting period following the reporting period to which they relate.
In cases where your personal data is obtained and processed on the basis of consent given by you, we will process your personal data only insofar as we have your consent to process your personal data.
7. With whom do we share personal data? Do we transfer it to third countries?
The Company may, at its own discretion, transfer part or all of the personal data to personal data processors for the fulfillment of the processing purposes, in compliance with the requirements of the Regulation.
The Company shares personal data with:
third parties – service providers engaged by us to perform functions or activities on our behalf;
third parties: regulatory authorities, tax, financial, judicial, administrative, and law enforcement authorities, all in accordance with applicable law.
This list is not exhaustive and there may be other legitimate purposes for storing, disclosing, or otherwise processing your personal data.
The Company notifies the data subject in the event of an intention to transfer part or all of their personal data to third countries or international organizations.
8. Is personal data protected?
The Company provides and maintains appropriate technical and organizational measures to protect personal data against unauthorized access or unlawful use of the personal data and/or against its accidental loss, alteration, disclosure, access, and/or damage or copying. These measures are intended to ensure the ongoing protection and integrity of the personal data. The Company reassesses the measures regularly in order to achieve continuous security of the personal data.
9. Do we carry out automated decision-making?
The Company does not carry out automated decision-making with data.
10. What are the Clients' rights in relation to the protection of personal data?
Each Client may proceed to exercise the rights listed below through a written communication to the Company.
Withdrawal of consent for the processing of personal data
When the processing of a Client's personal data is based on consent given by the Client for the processing of their personal data, the Client has the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent given before its withdrawal.Right of access
Each Client has the right to obtain confirmation from the Company as to whether their personal data is being processed by the Company. This includes the right of access to the personal data, the right to receive a free copy of the data (except in cases of excessive and repetitive requests), unless otherwise provided in the applicable data protection rules, as well as the right of the Client to be provided with a description of the basic information related to the processing of their personal data.
The Company provides the Client free of charge with a copy of their personal data that is being processed, but reserves the right to impose an administrative fee in the case of repetitive or excessive requests.Right to rectification
Each Client has the right to rectify or to request that the Company rectify, without undue delay, inaccurate, incomplete, or outdated personal data relating to them.Right to erasure ("right to be forgotten")
Each Client has the right to request that the Company erase the personal data relating to them without undue delay, where any of the grounds listed below applies:
(i) The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
(ii) The Client withdraws the consent on which the processing of their data is based and there is no other legal ground for processing it;
(iii) The Client objects to the processing, as set out below;
(iv) The Client's personal data has been processed unlawfully; or
(v) The Client's personal data must be erased in order to comply with a legal obligation under EU law, the law of a member state, or the law of another country;
(vi) the personal data was collected in connection with the offering of information society services.
The Company may refuse to erase a Client's personal data insofar as the processing is necessary:
(i) for exercising the right of freedom of expression and the right to information;
(ii) for compliance with a legal obligation requiring processing provided for by EU law or the law of the member state applicable to the Controller, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in it;
(iii) for reasons of public interest in the field of public health;
(iv) for archiving purposes in the public interest, for scientific or historical research, or for statistical purposes;
(v) for the establishment, exercise, or defense of legal claims.
Right to restriction of processing
Each Client has the right to require the Company to restrict the processing of their personal data in the following cases:
(i) Where they contest the accuracy of the personal data as provided by the Client and processed by the Company (the restriction is for a specified period that allows the Company to verify the accuracy of the personal data);
(ii) Where the processing is unlawful, but the Client does not wish the personal data to be erased and requests instead the restriction of its use;
(iii) Where the Company no longer needs the personal data for the purposes of the processing, but the Client requires it for the establishment, exercise, or defense of legal claims;
(iv) Where a Client has objected to the processing and awaits verification by the Company as to whether the Company's legitimate grounds for processing the personal data override the interests of the Client.Right to object
Each Client has the right, at any time and on grounds relating to their particular situation, to object to the processing of personal data relating to them.
A Client may exercise this right only with respect to the processing of their personal data carried out by the Company for the purposes of the Company's legitimate interests.
In the event that the objection is well-founded, the Company will cease processing the personal data concerning the objecting Client, unless the Company demonstrates that there are compelling legal grounds for the processing which override the interests of the Client.Right to data portability
This right includes the following possibilities:
(i) to receive the personal data in a structured, commonly used, and machine-readable format, in order to transfer it to another controller, or
(ii) to obtain the direct transfer of the personal data to another controller, where this is technically feasible.Right to complaint
Each Client has the right to file a complaint regarding the processing of their personal data by the Company with the Commission for Personal Data Protection, which is the competent supervisory authority.
Commission for Personal Data Protection
Address: Sofia, postal code 1592, "Prof. Tsvetan Lazarov" St. No. 2,
Tel. (02) 91 53 519, Fax: (02) 91 53 525
Email: kzld@cpdp.bg
Website: www.cpdp.bg
11. What happens in the event of a change?
In the event of a material change in the way the Company processes Clients' personal data and/or in the types of personal data it processes and/or in any other aspect of the subject matter of this notice, the Company will notify Clients of the relevant change immediately, by issuing and providing Clients with an updated version of the notice.