Privacy Policy

We at LUNIEM TRADE LTD take a responsible approach to the privacy, security and protection of our customers' personal data and want you to be aware of how we collect, use and process your personal data. We process your personal data in accordance with the principles of lawfulness and transparency.

GENERAL PROVISIONS

This Privacy Policy applies to the Personal Data we process when you interact with our website located at cacao-besos.com whether you are using a computer, mobile phone, tablet, television, in-home device or other device to access our services.

This Privacy Policy may be changed at any time in the event of changes in applicable laws, as well as changes in the way your Personal Data is processed. The current version of the Privacy Policy will always be available on this page, and you will find the date of the last update at the end of this page. We may notify you in the event that the changes may significantly affect your rights.

Processing of Personal Data will always be in accordance with the General Data Protection Regulation 2016/679 („Regulation“).   For the purposes of this Privacy Policy, the terms „personal data“, „data subject“, „processing“, „third party“, „consent of the data subject“ shall have the same  meaning as provided by  the European legislator when implementing the Regulation.

DATA WE PROCESS

You do not need to provide Personal Data in order to use our Website, but if you wish to use certain services through our Website, the Processing of Personal Data may become necessary.

We collect the following Personal Data that you provide to us while using our Website

• first and last name;
• delivery address;
• telephone number;
• e-mail;
• other personal data provided by you;

In addition, if you give your prior consent, we collect information about your use of our Website – this is done through the so-called cookies. Information could include time and frequency of website visits, browser type, operating system type, network and IP address information, and more. For more information about cookies and how you can manage them, see our Cookie Policy.

PROCESSING PURPOSES

We only use your Personal Data for specific purposes specified in advance at the time of collection and following your explicit Consent (where Consent is the legal basis for processing), or for additional compatible purposes in accordance with the law.
The purposes for which we process your Personal Data are:

• to respond to your requests submitted through our contact form;
• to provide products and services that you order through our website;
• to provide an efficient service to our customers; and  to improve the content and functionality of our website;
• to improve the quality of our services;
• to contact you to provide newsletters, special offers, useful tips,&nbsp, updates and information that we think will be of interest to you;
• to contact you with information about your use of our website;
• to ask for your feedback on our products and services;
• for our marketing and advertising purposes;
• for any other purpose in accordance with this Privacy Policy or for which we have obtained your specific Consent.

Providing Personal Data to Third Parties

• Your Personal Data may only be provided to third parties provided that they undertake the same obligations to provide adequate levels of protection as set out in the Regulation. 
• Your Personal Data may also be transferred to third parties acting on our behalf for further processing in accordance with the purposes for which it was originally collected or to be lawfully processed in other ways, such as service delivery, evaluation of the usefulness of this website, marketing, data management or technical support.
• Our contractual relationships with these third parties oblige them to use your Personal Data only for the agreed purpose and not to sell your Personal Data to third parties or disclose it to third parties except as required by the Regulation or as permitted by us or as set out in this Privacy Policy.
• The Personal Data we collect from you may be processed, accessed and stored outside the European Union in countries with a lower level of Personal Data protection than that provided for in the Regulation. In the event that we transfer your Personal Data to outside companies in other jurisdictions, we will ensure that these transfers of Personal Data are protected against the appropriate protections provided by the Framework, such as standard data protection clauses. You have the right to request a copy of the available standard data protection clauses on the basis of which we transfer your Personal Data to such countries. Where the risk regarding the protection of your Personal Data is very low, we may rely on your informed consent for such transfers.
• Your Personal Data may be disclosed: to third parties if we are required to do so by applicable law, court order, summons or government regulation; if we believe in good faith that disclosure is necessary to protect legal rights, protect your safety or that of others; as part of a criminal or other legal investigation or proceeding in the Republic of Bulgaria or abroad.
• We do not transfer, sell or exchange your Personal Data to third parties (including for marketing purposes).
• We may provide analytical data to third parties based on the use of cookies. For more information about cookies and how we use them, see our Cookie Policy..

LEGAL BASIS FOR PROCESSING

Article 6(1)(a) of the Regulation is the legal basis for which we require your Consent for the purposes of specific processing. If the Processing of Personal Data is necessary for the performance of an agreement to which you are a party, such as where the Processing is necessary for the supply of goods or the provision of another service, the Processing is based on Article 6(1)(b) of the Regulation. The same applies to Processing that is necessary to carry out pre-contractual measures, for example in the case of enquiries concerning our products or services. If our company has a legal obligation by virtue of which Processing of Personal Data is necessary, such as for compliance with tax obligations, the Processing is based on Article 6(1)(c) of the Regulation. Processing that does not fall within the legal grounds set out above but is necessary for the legitimate interests of our company, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject, is based on Article 6(1)(f) of the Regulation. In this case, the legitimate interest of our company is to carry out our activities for the benefit of our customers and employees.

Storage periods for personal data

Your Personal Data will not  be kept for longer than is necessary for the purposes for which it was collected. This means that once the goals have been fulfilled, the data will be deleted or  rendered anonymous.

Also, your personal data is stored for the period relative to our contractual relationship and for a certain period thereafter imposed by legal obligations.

Where there are no other grounds that  oblige us to store (part of) your Personal Data, you may request the deletion of your information. For more information see the section „Your rights“

DATA SECURITY

We endeavour to use appropriate organisational, technical and administrative measures to protect Personal Data within our organisation. To this purpose, we apply all legal and technical measures for the protection of Personal Data in relation to Article 32 of the Regulation, as well as taking into account the latest technological developments. Note, however, that despite adequate steps to protect information, no website, Internet connection, computer system or wireless connection is completely secure.

YOUR RIGHTS

• Right to information and access:
  
  At any time, you have the right to obtain free information about whether we process your Personal Data and the ways in which we process it, including the purposes of the processing, the types of data, the recipients of the data, your rights and more. If you wish to exercise your right of access, you may contact us at any time at the contacts listed at the end of the Privacy Policy.
  
  
• Right to data portability:
  
  Where the processing of your Personal Data occurs in an automated manner on the basis of your Consent or on the basis of a contractual  agreement, you have the right to receive a copy of your data in a structured, commonly used and machine-readable format transferred to you or to another party.
  
  
• Right to correction:
  
  You have the right to have your Personal Data corrected without undue delay if it is inaccurate, and to have the data completed in the event of incomplete information. You can correct your personal data directly in your user panel at cacao-besos.com or by contacting us at the contacts listed at the end of the Privacy Policy.
  
  
• Right to deletion (the right “to be forgotten“):
  
  You have the right to request the deletion, or to delete by yourself via the user panel, all personal data processed by us, at any time, in the following situations:
  
  - The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
  
  - You wish to withdraw your consent on which the processing is based pursuant to Article  6 (1) (a) or  9 (2) (a) of the Regulation and there is no other legal basis for the processing;
  
  - You wish to object to the processing pursuant to Article 21 (1) of the Data Protection Regulation and there are no legitimate grounds for the processing which override, or you object to the processing pursuant to Article 21 (2) of the Regulation;
  
  - The personal data have been unlawfully processed;
  
  - The personal data must be deleted in order to comply with a legal obligation under European Union or Member State law to which the controller is subject;
  
  - The Personal Data have been collected in connection with the provision of services to the information society pursuant to Article 8 (1) of the Regulation.
  
  
  If we have provided your Personal Data to third parties, we are obliged – to take  appropriate steps, including technical measures, to inform those third parties that you have requested deletion of your data or copies or replicas of that Personal Data, subject to available technology and implementation costs.
  
  The right to be forgotten may not be exercised in the following situations:
  
  - if you have an open order that has not yet been dispatched or has been partially dispatched;
  
  - if you have an outstanding debt to us, regardless of the method of payment;
  
  - if you are suspected of abuse or have misused our services;
  
  - if you have made a purchase, we will retain your personal data in relation to your transaction against legal obligations.
  
  
• Right to object to processing based on legitimate interest:
  
  You have the right to object to the processing of your Personal Data on the basis of our legitimate interest. We will stop processing your Personal Data unless it is proven that there are compelling legal grounds for doing so that take precedence over your interests and rights or due to legal claims.
  
  
• Right to object to direct marketing:
  
  You have the right to object to receiving marketing communications, including profiling and analysis for direct marketing purposes.
  
  You can unsubscribe from direct marketing in the following ways:
  
  - by following the instructions in any message received in your email;
  
  - by editing the settings in your user panel;

• Right to restriction of processing
  
  You have the right to request the restriction of Processing where one of the following circumstances applies:
  
  - if you claim that your Personal Data is inaccurate, we will restrict the Processing until a data accuracy check has been passed.
  
  - the Processing is unlawful, but the data subject does not wish the personal data to be deleted, but requests instead the restriction of their use;
  
  - if we no longer need your personal data for the purposes of the Processing, but it is necessary  for the establishment, exercise or defence of legal claims;
  
  - if you object to Processing on the basis of our legitimate interest, in which case we will restrict Processing pending the outcome of the lawful basis check.

• Right to withdraw consent
  
  You have the right, at any time, to withdraw your consent to the Processing of your Personal Data where such Processing is carried out on the basis of consent.
  
  
• Automated individual decision-making, including profiling
  
  You have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects the data subject, unless the decision: (1) is necessary for the conclusion or performance of a contract between a data subject and a controller; or (2) is permitted by the European Union or Member State law applicable to the controller and which also provides appropriate measures to safeguard the rights and freedoms, and legitimate interests; or (3) is based on the data subject’s explicit consent.
  
  For your information, our activities do not require the making and use of automated decisions, including profiling.
  
  
• Right to file a complaint with a supervisory authority:
  
  If you believe that we are processing your Personal Data in an unlawful manner, you have the right to file a complaint with a supervisory authority in the European Union. The supervisory authority of the Republic of Bulgaria is:

Commission for Personal Data Protection

1592 Sofia, 2 Prof. Tsvetan Lazarov Blvd.

e-mail: kzld@cpdp.bg 

phone: 02/91-53-555

How can you use your rights?

If you wish to exercise any of your legal rights, or need assistance in exercising them or have any questions relating to them, you may at any time contact us at the contacts listed at the end of the Privacy Policy.

Protection of personal data of persons under the age of 14

We understand the importance of protecting the privacy of children. Our website is not intended for persons under the age of 14. We do not have a policy to intentionally process data about persons under the age of 14.

Data controller information and contacts

• LUNIEM TRADE LTD
• 207584453
• Sofia, Bulgaria, Maistor Aleksi Rilec 12
• info@cacao-besos.com

Date of last update: 26.11.2020