PRIVACY NOTICE ON PERSONAL DATA PROCESING HELD BY AIBEK EOOD

This Privacy Notice aims to provide information regarding the nature of your personal data processed by AIBEK EOOD in relation to the execution, service and performance of contracts and any other binding relations, related to the goods and services offered by it, as well as when visiting the Company's websites.

In case of any questions regarding this or should you wish to confirm whether AIBEK EOOD processes your personal data or to access any personal data that AIBEK EOOD might hold about you , please contact us via e-mail to: privacy@dabalkon.com or at: 24Г, Gen. Ivan Kolev Str., app. 20, District Triaditsa, 1401, city of Sofia, Republic of Bulgaria.

‍

INTRODUCTION

AIBEK EOOD develops and sales different innovative and sustainable solutions, leveraging cutting-edge materials and technology, including but not limited to its exclusive modular systems for comfort and functional design of balcony areas. 

With this regard the Company owns and manages the online store www.dabalkon.com („DaBalkon“) and the informative website www.aibek.co.

‍

1. CATEGORIES OF CONCERNED INDIVIDUALS (DATA SUBJECTS) AND PURPOSES OF DATA PROCESSING

For the performance of the activities, management and the development of our web store AIBEK processes personal data of the following main categories of data subjects:

• GUESTS OF www.dabalkon.com AND www.aibek.co IN RELATION TO YOUR INTERESTS IN OUR GOODS AND SERVICES, CUSTOMER BEHAVIOUR, PREFERENCES AND FEEDBACK
• REGISTERED GUESTS OF www.dabalkon.com IN RELATION TO YOUR ORDERS, CUSTOMER BEHAVIOUR AND PREFERENCES, FAVOURITES AND FEEDBACK
• INDIVIDUALS TAKING PART IN GAMES, PROMOTIONS AND OTHER MARKETING CAMPAIGNS ORGANISED BY AIBEK EOOD AND INDIVIDUALS SUBSCRIBED TO DIRECT MARKETING MESSAGES AND NEWSLETTER FROM AIBEK EOOD
• LEGAL AND/OR AUTHORISED REPRESENTATIVES AND CONTACT PERSONS OF ALL CORPORATE ORGANISATIONS HAVING CONTRACTUAL RELATIONS WITH AIBEK EOOD
• BUSINESS CONTACTS

2. HOW, WHY AND WITHIN WHAT TIME LIMITS DO WE PROCESS YOUR PERSONAL DATA 

The below information is concerned to both data subjects who provided their personal data to AIBEK EOOD by themselves as well as those whose personal data has been provided to us by third parties (e.g. by their employers). 

AIBEK EOOD with Unified Identification Code: 204877283, having its seat and registered office at: 24Г, Gen. Ivan Kolev Str., app. 20, District Triaditsa, 1401, city of Sofia, Republic of Bulgaria, represented by its manager Konstantin Vaskov Popov in its capacity of controller in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”), hereinafter referred to as “AIBEK” the “Company” or the “Controller”, processes personal data as follows:

• GUESTS OF www.dabalkon.com AND www.aibek.co IN RELATION TO YOUR INTERESTS IN OUR GOODS AND SERVICES, CUSTOMER BEHAVIOUR, PREFERENCES AND FEEDBACK

AIBEK processes the following categories of personal data of the individuals visiting its websites www.dabalkon.com and www.aibek.co and which are potential or existing clients of the Company:

1. for physical identity: names; age, email; phone number; address for invoicing and address for delivery;
2. financial information: your payment details;
3. other information: content of reviews and feedback to us; VAT numbers; 
4. automatically obtained information: IP address used to connect your computer to the Internet; device log files and configurations related to your visits at our websites; computer, device, and connection information such as device browser type and version, browser plug-in types and versions, operating system, or time zone setting; the location of your device or computer; device metrics such as when a device is in use, and any errors or event failures; purchase and content use history; the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products and content you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs). 

Please note that based on this automatically obtain information you will be subject to profiling that consists of automated processing of personal data that analyse or predict aspects concerning your personal preferences and interests of our products and services. This produces the legal effect concerning you that you might receive personalized offers and adds related to our products and services only.

‍

Purpose, legal basis and time limit of processing  

We may use the data above only for the following purposes:

• process your orders, deliveries, returns, claims and feedback. This includes execution of sales contracts, control over performance of contractual obligations; property management; accountancy and taxation; debt collection; defence in case of legal claims and protection of the legal rights and interests (incl. economic) of the Company and its customers, contractors and related parties; 
• enhancing your customer experience by ensuring functionality, analyse performance, fix errors, and improve usability and effectiveness of our services and goods;
• recommend and promoting features, goods and services of the Company that might be of interest to you, identify your preferences, and personalize your experience with our goods and services;
• to provide interest-based ads or offers for features, products, and services that might be of interest to you. We do not use information that personally identifies you to display interest-based ads;
• Compliance with legal obligations when required;
• Communication with you when such is initiated by you or is necessary for the purposes of your requests, orders, searches, feedback, claims, etc.

AIBEK processes these personal data on the following legal basis:

• execution of pre-contractual, contractual and statutory obligations of the Company with regard to the respective relations;
• performance of the legal obligations of the Company in relation to its activity;
• our legitimate interest to promote, advertise and improve our activities, goods and services.

Information how to exercise your right to object can be found in Section III What Are Your Rights below.

The time limits for processing your personal data for these purposes are as follows: 

• for data contained in accounting registers and financial statements: up to 10 years starting from January the 1^st of the reporting period following the reporting period to which they pertain;
• for data contained in documents subject to tax audits and needed for accounting purposes: up to 10 years starting from January the 1^st of the reporting period following the reporting period to which they pertain;
• for data contained in documents needed for the performance of contractual relations: up to 6 years after termination of the respective contract or until closure of dispute related procedures,
• for data collected for the purposes of errors fixing, recommending and promoting features, goods and services of the Company: up to six months from its collection, 

except where a legislative act, a judicial act, an agreement or the commercial practice require otherwise.

• REGISTERED GUESTS OF www.dabalkon.com IN RELATION TO YOUR ORDERS, CUSTOMER BEHAVIOUR AND PREFERENCES, FAVOURITES AND FEEDBACK

Along with the categories personal data of the GUESTS OF www.dabalkon.com AND www.aibek.co AIBEK processes the following additional personal data of the registered users of www.dabalkon.com:

1. Loging information: username, password and saved payment information; 
2. Others: favourite and saved products and contents preferences 

Purpose, legal basis and time limit of processing  

The same purposes, legal basis and time limits of processing as those for the GUESTS OF www.dabalkon.com AND www.aibek.co apply to the registered users of www.dabalkon.com. 

Additional time limit for registered guests’ data is the storage limitation of the additional login and information above, namely up to six months as from the profile deactivation regardless the reason for this. 

• INDIVIDUALS TAKING PART IN GAMES, PROMOTIONS AND OTHER MARKETING CAMPAIGNS ORGANISED BY AIBEK EOOD AND INDIVIDUALS SUBSCRIBED TO DIRECT MARKETING MESSAGES AND NEWSLETTERS FROM AIBEK 

AIBEK processes the following categories of personal data of individuals taking part in games, promotions and other marketing campaigns organized by the Company (including such organized for visitors of the Instagram, Facebook or other social media pages of DaBalkon) and persons who have shown interest to marketing activities organized by AIBEK and subscribed to direct marketing messages and newsletters from AIBEK: 

1. for physical identity: names, post address, email address, phone number, signature, gender.
2. data related to participation in games: data contained in photo/video recordings, comments and other social media publications (for more information regarding the data we process in relation to our Facebook and Instagram page/profile, please see our Social Media Privacy Notice in our webpage [link]);
3. data related to tax and accounting purposes: three names and personal identification code of winners in marketing campaigns. 

Purpose, legal basis and time limit of processing 

We use the above mentioned data only for the following purposes: 

• administration of games and events, including contacting the winning/awarded participants, awarding prizes, discounts and/or other marketing materials, conducting mandatory accounting and taxation;
• direct marketing of any activities, initiatives and campaigns organized by AIBEK. This purpose for processing of your personal data also includes sending newsletters and various advertising messages for our activities when you subscribed for such.

AIBEK processes these personal data on the legal basis of its legitimate interest to popularize and advertise its activities, goods and services as well as on the ground of the AIBEK’s contractual obligation to award prizes to the winning participants

Information how to exercise your right to object to this processing can be found in Section III What Are Your Rights below.

The time limits for processing of your personal data for these purposes are:

• up to 10 years from the end of the relevant marketing campaign, in the course of which the data was collected, or the receipt of your subscription and profiling request.
• for the purposes of administering the specific campaign/event your personal data will be processed for a maximum of 7 days after the expiration of the term for receiving the respective awards, discounts and/or other marketing materials (including in paper form);
• for direct marketing purposes, the data are stored in marketing databases and the data storage term is up to 10 years after the end of the marketing campaign in which the data were collected or until you exercise your opt-out right;
• data contained in documents, necessary for the execution of contracts - up to six years after termination of the respective contract or until closure of dispute related procedures;
• data contained in accounting registers and financial statements or data contained in documents subject to tax audits and needed for accounting purposes - up to 11 years, 

except where a legislative act, a judicial act, an agreement or the commercial practice require otherwise.

• LEGAL AND/OR AUTHORISED REPRESENTATIVES AND CONTACT PERSONS OF ALL CORPORATE ORGANISATIONS HAVING CONTRACTUAL RELATIONS WITH AIBEK EOOD

(together referred to as the “Contractors” below) 

AIBEK processes the following categories of personal data of its Contractors: 

1. the minimum amount of personal data necessary for the signing of relevant contracts – names and Personal Identification Number. Identity Card data are only used where the contract is signed with notary verification or by a representative authorized via notarized power of attorney.
2. personal data for business contact in the course of contract performance – this information is limited to the types of information which could be contained in business cards/electronic signature, including in e-mails: name and surname, position, name of employer, business address, business email address and business phone number.  

We receive from our Contractors the above listed personal data (contact information) of employees or other individuals assigned by our Contractors as contact persons for the respective contract. Our Contractors providing us these data are also personal data controllers of these data and are responsible to provide the respective Data Subjects with all needed information with this respect. Furthermore, our Contractors are obliged to ensure the accuracy of these data and for keeping them up-to date all the time. This means that if any data provided to us is changed or no longer accurate, we need to be duly informed on this as soon as practically possible. Until receiving such notice, we assume that the provided contact related data are accurate and we may use it for the purposes below.  

‍

Purpose, legal basis and time limit of processing

The above mentioned data are only used for the following purposes: 

• performance of pre-contractual and contractual obligations, administration of contracts (including accounting and taxation), control over performance and debt collection, protection against legal claims.

The legal basis for this processing is the performance of pre-contractual and contractual obligations of AIBEK and its legal obligation for accounting and taxation. 

Personal data mentioned in this section is processed by AIBEK in the following time limits: 

• data contained in accounting registers and financial statements: up to 11 years;
• data contained in documents subject to tax audits and needed for accounting purposes: up to 11 years;
• data contained in documents needed for the performance of contractual relations: up to 6 years after termination of the respective contract or until closure of dispute related procedures.
• data processed in relation to the compliance with statutory obligations – within the applicable statutory terms. 

except where a legislative act, a judicial act, an agreement or the commercial practice require otherwise.

• BUSINESS CONTACTS

If you provided AIBEK with your business contact information via your business card or in any other way or this information is publically available, please note that it is possible that AIBEK has included this information of you in its business contacts list. 

The above means that in case of business need, for the purpose of sending you holiday greetings or for the purpose of providing you with information about our goods, services, events etc. AIBEK may contact you but only in your official capacity in which we have your contact information. 

AIBEK provides all necessary protections to its database with business contacts as for all other personal data. 

If you do not wish AIBEK to contact you as described above, please inform us at any of our addresses listed in the next Section III and your contact information will be deleted from our business contacts database. 

‍

3. WHAT ARE YOUR RIGHTS 

If you are a person, whose personal data are processed by AIBEK under any of the above circumstances, you have the following rights in this regard: 

1. you have the right to object to the processing of your personal data for the purposes of direct marketing, if you are an addressee to direct marketing. If you make such an objection to our direct marketing messages we will no longer process your personal data for this purpose. However, in order to ensure that your objection is regarded, your data will be included in data base of objected against direct marketing data subjects;
2. all data subjects have the right: 

• to be informed about the types of personal data processed by AIBEK; 
• to access to and copy of their processed personal data; 
• to correct or erase their personal data;
• to limit processing;
• to portability. 

You can exercise and of the above mentioned rights by submitting a written request, in either of the following ways: 

• by email to: privacy@dabalkon.com 
• by letter, addressed to: AIBEK EOOD, 24Г, Gen. Ivan Kolev Str., app. 20, District Triaditsa, 1401, city of Sofia, Republic of Bulgaria, Konstantin Popov, General Manager;
• you may also object to direct marketing by other means, as specified in the relevant marketing message – for example, through following a link provided in an email. 

You also have the right to complain regarding the processing of your personal data to the relevant authority, which for the Republic of Bulgaria is the Commission for Personal Data Protection with contact details: 2, Prof. Tsvetan Lazarov blvd., Sofia 1592; kzld@cpdp.bg.

4. CONTENTS OF YOUR APPLICATION 

Please note that your application for exercise of any of your rights should contain at least your names with other identification information about you, description of your request, preferred way of communication with you, address for correspondence, signature and date of the application. 

If the application is signed by a representative, the respective power of attorney should be attached to the application. 

AIBEK may contact you for additional information, if it needs to ensure your identity or further clarify your request. 

‍

5. WHOM WE CAN SHARE YOUR DATA WITH 

AIBEK may assign any of the above mentioned personal data processing activities related to direct marketing or games to marketing agencies and IT service providers, in the course ensuring the protection of data and its lawful processing. We may also provide your personal data to our partners, where necessary (for example to couriers, software providers, etc.). 

The data might also be provided to AIBEK shareholder/s, third parties involved in the management of our activities, such as our accountants, auditors, lawyers, marketing agencies, IT suppliers and other software and hardware service suppliers as well as to competent authorities, if duly requested. 

Service Providers and Business Partners

We share your information with certain trusted third parties to help us provide, improve, and promote our services:

1. Meta (Facebook): We use Facebook's advertising and analytics services to better understand user behavior and optimize our marketing campaigns. We may share user identifiers, device information, and interaction data with Facebook to enhance ad targeting and measure campaign effectiveness.

We share data with Meta (Facebook) based on the following legal grounds:

Consent: When you explicitly agree to the use of Meta tracking technologies through our cookie consent tool or other explicit consent mechanisms.

Legitimate Interests: For certain analytics and marketing activities where we have assessed that our business interests do not override your fundamental rights and freedoms. This includes basic website analytics and measuring marketing campaign effectiveness.

Contractual Necessity: In limited cases where sharing is required to fulfill our contractual obligations to you, such as when you request services that require Meta integration.

‍

2. Google: We utilize Google's suite of services including Google Analytics, Google Ads, and Google Cloud Platform. We share analytics information, search queries, and technical data with Google to analyze website performance, deliver relevant advertising, and provide secure cloud infrastructure services.

Our data sharing with Google services is based on:

Consent: For marketing cookies, personalized advertising, and non-essential tracking activities, which you can control through our consent management platform.

Legitimate Interests: For essential analytics that help us understand how users interact with our website to improve user experience and functionality.

Contractual Necessity: For services you explicitly request that require Google integration, such as using Google authentication options.

‍

3. HubSpot: As our customer relationship management (CRM) platform, we share contact information, communication history, and user preferences with HubSpot to manage our customer relationships, marketing campaigns, and sales activities effectively.

We share information with HubSpot based on:

Contractual Necessity: To fulfill our obligations to you when you request information, support, or services from us.

Legitimate Interests: To manage our customer relationships effectively, respond to inquiries, and provide relevant communications about our products and services.

Consent: For sending marketing communications and newsletters, which you can withdraw at any time.

You maintain certain rights regarding how your information is shared, including the right to object to processing based on legitimate interests and the right to withdraw consent for specific processing activities.

For more information about how these companies process your data, please refer to their respective privacy policies:

Meta Privacy Policy

Google Privacy Policy

HubSpot Privacy Policy

‍

6. EXCESSIVE DATA PROVIDED BY/ABOUT YOU

If we receive any personal data in excesses of what is needed for us to comply with our purposes above, we will delete this information immediately but not later than a month after its receipt. 

‍

7. PROTECTION OF YOUR DATA

To help protect the privacy of your personal data, we maintain physical, personal, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those assigned processors who need to know that information to provide benefits, goods or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

‍

8. USING OUR WEBSITES

As is true of most other websites ours also collects certain information automatically and stores it in log files. The information may include the data listed above such as internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of our websites, including a history of the subsections you view, etc. We use this information to help us design our sites to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. AIBEK websites also use cookies and web beacons. More information with this regard you may find in our Cookies Policy. 

‍

9. CHANGES AND UPDATES TO THIS PRIVACY NOTICE 

As our organization, goods and services change from time to time, this Privacy Notice is expected to change as well. We reserve the right to amend the Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice at this Site. We may e-mail periodic reminders of our notices and terms and conditions and will e-mail our partners and hotel guests of material changes thereto, but you should check our website frequently to see the current Privacy Notice that is in effect and any changes that may have been made to it.

‍

The present document represents privacy notice within the meaning of Art. 13 and Art. 14 of 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).