Overview of the Personal Data Protection Policy

We understand that your personal data and the protection of the information you share with us are extremely important. That is why our Privacy Policy describes how we process your data and what measures we take, in order to protect it. It also explains where and how we collect your personal information, and what your rights are to all information about you that we store, including how you can control the use and disclosure of your information and how your information is protected.

This policy applies to you in case you provide us with personal data by phone, in an online registration form through the website www.home.fivo.bg, by mail or by courier, through social networks, in a corporate or promotional website, or otherwise. Our privacy policy is an expression of our readiness to protect your personal information and to inform you about everything relating to the processing of your personal data.

In this privacy policy we will address the following key issues:

1. Who are we?
2. What information do we store and process about you?
3. Cookie policy.
4. Purposes for which we use the data you provide to us and grounds for processing it.
5. With whom we can share your data.
6. International transfer of your personal data.
7. How will you receive information about our products and/or services?
8. What are your rights relating to your data and how can you exercise them?
9. For how long we store your personal data.
10. Data protection.
11. Contact us.
12. Change in the data protection policy.

1. Who are we?

When we say “we” (or “our”) in the framework of this Privacy Policy, we refer to the following legal entity:

“Eco Water Solution” Ltd., with UIC 205383914, with registered office and address of management Sofia, p.k. 1404, Triaditsa district, Manastirski Livadi residential area, Charles Shampoo Str., Bl. 21, ent. B, ap. m.16 – personal data administrator.

This list may be supplemented by new legal entities that are or will be part of our group in the future.

2. What information do we store and process about you?

The information you share with us when using the functionalities of our corporate website (www.home.fivo.bg) and/or inquiries for services/prices.

This information may include any or all of the following: Your names, telephone number, email address, geographic location, IP address, details about your preferences, and any feedback you provide to us by mail, telephone, email:

In case you visit us at the address: Sofia, p.k. 1404, Triaditsa district, Manastirski Livadi residential area, Charles Shampoo Str., Bl. 21, ent. B, ap. m.16, data of your physical identity can be collected – recording images through video surveillance equipment in the office of the Administrator.

Use of children’s data

We do not deliberately collect or store personal information about children under the age of 16, nor do we offer any of our products or services directly to children under the age of 16.
In case personal data from children under the age of 16 is accidentally collected through our website in connection with the products or services we offer, it is subject to immediate deletion.

3. Cookie policy.

3.1. Cookie Policy Overview

When you access the website www.home.fivo.bg and the information contained therein (the “website”), you automatically receive a notification about the “cookies” that have been implemented on the website, you are allowed to consent to the use of “cookies”. , to limit the use of cookies to the necessary for the functioning of the site, as well as information about the protection measures taken by us and the rights you have, under the adopted Cookie Policy and applicable law, which can be found at the following address: www.home.fivo.bg.

4. Purposes for which we use the data you provide to us and grounds for the processing.

As a Data Administrator and in order to fulfill our obligations under the General Data Protection Regulation, we may use your personal data for one, several, or all of the purposes listed below:

• To send a response to your inquiry about any of our products or services;
• To send you emails with news and suggestions from the company (“newsletter”);
• To send you invitations to events we organize – alone or with our partners;
• To help us understand more about you as our customer, the products and/or services you use, the way you use them, and to provide you with a better service from our employees;
• To find ways to improve our products, services, applications, or websites.
• For direct marketing and advertising.

The processing of your personal data is based on one of the following conditions:

•  You have consented to the processing of your personal data for one or more specific purposes;
• The processing is necessary for the execution of a contract to which you are a party or for undertaking steps on your request before signing a contract between us and you;
• The processing is necessary to comply with a legal regulation that applies to us as a personal data administrator;
• The processing is necessary to protect your vital interests or that of another individual;
• The processing is necessary for the performance of a service in the public interest or the exercise of official powers conferred on us as a personal data administrator;
• The processing is necessary for the purposes of our legal interest or those of a third party, except when such interests supersede your interests or fundamental rights and freedoms, which require special protection of your personal data.

5. With whom can we share your data?
We share your personal data only if there is a legal basis for it or your explicit, prior consent.

5.1. With companies from the group – related parties

We may share your data (only with your consent) with other companies – related parties when we have your consent. This way we will be able to provide you with a first-class service.

5.2. With our partners and/or suppliers

We work with partners and suppliers who can also process your personal data on our behalf, but only if they meet our standards for data storage, processing, and protection! Such partners are, for example:

• When you use the service we offer, as a credit intermediary, to finance the sale, we disclose your personal data to Unicredit Consumer Financing EAD.
• Facebook ads – for advertising purposes and direct marketing.
• Google Ads – for advertising purposes and direct marketing.
• ADVENTO Ltd. – technical support.
• OUTMARK LTD – technical support.
• Courier or postal companies that must deliver documents or other materials on our behalf;
• Printers used to prepare personalized materials for you;
• Companies that organize advertisements and promotional events of our products or services when you have registered to participate in such an event.

We only provide them with the information they need to obtain the relevant product and/or service from us that you are interested in. For example, if you have indicated that you are interested in marketing information from us and/or our partners, you may see advertisements for our products and/or services on websites you visit.

5.3. Other organizations or individuals:

We may provide your personal information to other organizations in certain cases. For example:

• If we are discussing the sale of all or part of our business, we may share data about you with potential buyers – but only in generic form so that they can assess the potential of the business;
• If required by law, by a public or private institution, in the conduct of its statutory obligations (eg police, NRA, NSSI, CPDP, etc.);
• If we need to share your personal data to protect our legal interest or exercise our rights under цуррент легислатион, as well as to protect our customers, users of our products and/or services, systems, and servers; or
• In response to a request from other individuals (or their representatives) who are trying to protect their legally regulated rights or the rights of other individuals or organizations.

6. International transfer of your personal data

International transfer of your personal data may be carried out for direct marketing, advertising, and improvement of our products.

Any international transfer of personal data is carried out based on legal grounds or your prior consent.

7. How will you receive information about our products and/or services?

When you have explicitly stated that you agree with this, we will be happy to share with you via email information about our special offers, ideas, products, and/or services when we have something to share with you.

In case you do not agree with this or want to withdraw your consent to receive emails/newsletters from us, you can do so in the following ways:

• by sending us a cancellation email request to privacy@home.fivo.bg.
• by contacting us by phone on 070012341.

8. What are your rights concerning your data and how can you exercise them?

8.1. Access to and correction of your personal data

You have the right to access your personal data that we process for the purposes set out above. If we process this data and receive a request from you (or from a third party authorized by you), we will provide this access free of charge. You also have the right to request a copy of your personal data that we process.

Before we provide access to the personal data to you or a person authorized by you, we may request proof of identity, as well as details of your relationship with us or our partners, so that we can locate the data related to you.
If any personal data we store and process about you is inaccurate or out of date, you have the right to ask us to correct it, including by adding a declaration.

8.2. Right to delete your personal data

You have the right to request that we delete your personal data without undue delay if:

• personal data is no longer needed for the purposes for which it was collected;
• when you have withdrawn your consent;
• when you have objected to its processing, if it is illegal;
• where personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to us as a personal data administrator;
• when personal data has been collected in connection with services provided by the information society.

Under certain conditions, we may refuse to delete your personal data in the cases outlined under the current legislation.

8.3. Right to data portability and right to appeal

You have the right to receive the data we process about you in a structured, widely used, and machine-readable format so that you may transfer your data to another Administrator.

You have the right to file a complaint with the local regulator, the Data Protection Commission, or the court if you believe that your rights have been violated. For this purpose, you can visit the website of the CPDP at https://www.cpdp.bg/, where you can learn more. Contact details of the CPDP: Sofia 1592, Prof. Tsvetan Lazarov ”№ 2; E-mail: kzld@cpdp.bg.

8.4. Right to withdraw consent

You have the right to withdraw your consent to the processing of your personal data by us at any time by sending a request to us:

• by sending us an email at privacy@home.fivo.bg.
• by contacting us by phone on 070012341.
• by sending us a written request to address: Sofia, p.k. 1404, Triaditsa district, Manastirski Livadi residential area, Charles Shampoo Str., Bl. 21, ent. B, ap. м.16.

8.5. Right to object

You have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling insofar as it relates to direct marketing. The objection can be made by phone or by e-mail to the contact details below in item 10.

8.6. Restricting the processing of personal data

You have the right to request that we restrict the processing of your personal data when you believe that your personal data is inaccurate, the processing of your personal data is unlawful, we do not need your personal data for the purposes of processing or you have objected to their processing. . In this case, personal data will only be stored, but not processed.

8.7. The right not to be subjecto an automated solution involving profiling

You have the right not to be the subject of a fully automated decision, including profiling, when this has legal consequences for you or significantly affects you.

If you wish to exercise any of your rights described here, please contact us at the contacts listed in section 8.4.

9. For how long do we store your data?

We keep a record of your personal data to provide you with high quality and consistency of our services within the group. We always store and process your data in accordance with the law and never keep it longer than it is necessary. In the general case, unless we specify otherwise, your data is stored for a period of 1 (one) calendar year from the date of receipt. For the purposes of processing personal data in relation to a commodity loan from Unicredit Consumer Financing EAD, personal data is stored for a period of 5 (five) years.

10. Data protection

We treat your personal information as strictly confidential. To protect them, we take a number of measures, including:

• We restrict access to the premises in which we work only to the people who must be there;
• We also implement access control to our information technology systems using firewalls, ID validation, and other technical methods.
• We would never ask you to send us your password;
• We advise you to never send an account number, password, or other sensitive information in an email to us.

11. Contact us

If you wish to exercise any of your rights described in this Privacy Policy, or if you have a question or complaint related to this policy or the way your personal information is processed, please contact us in one of the following ways:

• by email: privacy@home.fivo.bg.
• By post: To the attention of the person responsible for the processing of personal data at “Eco Water Solution” Ltd. – Nikolinka Konova, at: Sofia, p.k. 1404, Triaditsa district, Manastirski Livadi residential area, Charles Shampoo Str., Bl. 21, ent. B, ap. м.16.
• By phone: contact us on 0700 12341 during business hours, from 9:00 to 17:30.

12. Change in the data protection policy

The current Privacy Policy was last updated on 11.11.2020.