Privacy policy.

General information

From May 25, 2018. a new Data Protection Protection Regulation adopted by the European Union comes into force. The regulation aims to ensure the protection of data of individuals from all EU Member States and to harmonize the regulations for their processing.

As a data administrator for services, Puzzlenarium Ltd. meets all the requirements of the new regulation by collecting only the data of the persons insofar as they are necessary for the provision of the service and keeping them responsibly legally.

Information about the Privacy Controller

  1. Name: Puzzlenarium Ltd.
  2. Headquarters and management address: 10 Ekaterina Nencheva Str., Sofia
  3. Address for the exercise of the activity: 10 Ekaterina Nencheva Str., Sofia
  4. Correspondence data: 10 Ekaterina Nencheva Str., Sofia
  5. E-mail: info@puzzlenarium.bg
  6. Contact number: 0879380665

Information about the Data Protection Officer

  1. Personal Data Administrator: Ofeliya Petkova
  2. Address: 10 Ekaterina Nencheva Str., Sofia
  3. Contact number: 0879380665
  4. Email: info@puzzlenarium.bg

Information on the competent supervisory authority

  1. Name: Commission for Personal Data Protection
  2. Headquarters and address of management: Sofia 1592, "Prof. 2 Tsvetan Lazarov
  3. Correspondence data: Sofia 1592, "Prof. 2 Tsvetan Lazarov
  4. Contact number: 02 915 3 518
  5. Email: kzld@government.bg, kzld@cpdp.bg
  6. Website: www.cpdp.bg

Puzzlenarium Ltd. operates in accordance with the Personal Data Protection Act and Regulation (EC) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement movement of such data.

Reason for collecting, processing and storing your personal data

Art. 1. (1) Puzzlenarium collects and processes your personal data in connection with the provision of training, translation and legalization on the grounds of Art. 6, para. 1, Regulation (EC) 2016/679, and in particular on the basis of the following:

  • Explicitly received consent from you as a customer;
  • Execution of the obligations of Puzzlenarium Ltd. under contract with you;
  • Compliance with a legal obligation that applies to Puzzlenarium Ltd.;
  • For the purpose of the legitimate interest of Puzzlenarium Ltd..

(2) Puzzlenarium Ltd. is the administrator of personal data regarding your data as a user of our services. Based on the personal data you process using our services, Puzzlenarium Ltd. acts in its capacity as processor of personal data.

Objectives and principles of collecting, processing and storing your personal data

Art. 2. (1) Puzzlenarium collects and processes the personal data you provide us in connection with the use of our services and for the conclusion of a contract with the company as well as for subscribing to our events, including for the following purposes:

  • individualisation of a party to the contract;
  • accounting purposes;
  • statistical purposes;
  • protection of information security;
  • securing the execution of the contract for the provision of the respective service;
  • sending informational messages and changes to the service;
  • improving and personalizing the service by offering you appropriate service offers that may be of interest to you;

(2) Puzzlenarium Ltd. complies with the following principles when processing your personal data:

  • lawfulness, good faith and transparency;
  • limitation of processing goals;
  • relevance to processing goals and minimization of data collection;
  • accuracy and timeliness of the data;
  • restriction of storage in order to achieve the objectives;
  • integrity and confidentiality of the processing, and ensuring an adequate level of security of personal data.

(3) When processing and storing personal data, Puzzlenarium Ltd. can process and store personal data to protect its legitimate interests:

  • fulfilling its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.

What types of personal data collect, process and store Puzzlenarium Ltd.?

Art. 3. (1) Puzzlenarium Ltd. performs the following personal data operations for the following purposes:

  • Registering users of entertainment services. The Data Protection Officer considers that Operation User Registration for a Service in the Entertainment Area is permissible for performance and provides sufficient safeguards to protect the rights and legitimate interests of the data subject in accordance with the GDPR requirements.
  • Conclusion and execution of a commercial transaction with a client or a partner - the purpose of this operation is to conclude and execute a contract with a commercial partner or client and its administration;
  • Sending Information Messages - The purpose of this activity is to administer the process of sending messages to customers regarding improvements or changes to services under the Service Agreement.
  • Send newsletter (newsletter) - The purpose of this operation is to administer the bulletin sending process to clients who have declared they wish to receive;

(2) Puzzlenarium Ltd. processes the following categories of personal data and information for the following purposes and for the following reasons:

  • Data: Your individualized data (name, surname, e-mail, telephone)
    • Purpose for which data is collected: 1) User registration in a customer management system; 2) Making a contact with the user and sending information to him, including when he or she so requests - to send bulletins and advertisements; 3) When completing and submitting a request or inquiry in any of the forms on a current site;
    • Reason for processing your personal information – By accepting the terms of service and purchasing a service, Puzzlenarium Ltd. and you are creating a contractual relationship on which we process your personal data - art. 6, para. 1, b. (b) GDPR.
  • Other data that Puzzlenarium Ltd. processes – When entering our website or your account, Puzzlenarium collects data about the IP address used.
    • Purpose for which data is collected: Improve service security and interface localization, statistical and marketing research.
    • Grounds for data processing: The processing is necessary for the execution of a contract under which the data subject is a party - Art. 6, para. 1, b. (b) of the GDPR. Until the creation of a user profile, the IP address is collected on the basis of the legitimate interests of the administrator - Art. 6, para. 1, b. (f) by GDPR;
  • Your personal invoice data - If you would like an invoice to be issued to you as an individual, you should provide your single personal identification number.
    • Purpose for which data is collected: Issuing an invoice for making payments under a contract for the provision of services for the use of the e-shop platform.
    • Reason for processing your personal information – With the acceptance of the General Terms or upon the conclusion of a written agreement between Puzzlenarium Ltd. and you, a contractual relationship is created, on which basis we process your personal data - art. 6, para. 1, b. (b) GDPR.

(3) Puzzlenarium Ltd. does not collect or process personal data that relate to the following:

  • reveal racial or ethnic origin;
  • reveal political, religious or philosophical beliefs, or membership of trade unions;
  • genetic and biometric data, health data, or data on sexual life or sexual orientation.

(4) Personal data are collected by Puzzlenarium Ltd. by the persons to whom they refer or by their authorized representatives.

(5) The company does not make automated decision making with data.

Term of storage of your personal data

Art. 4. (1) Puzzlenarium Ltd. keeps your personal data for a period of five years. Upon expiry of this period, Puzzlenarium Ltd. takes the necessary care to erase and destroy all your data without undue delay.

(2) Puzzlenarium reserves the personal data that it is required to keep under the applicable law for the relevant term, which may exceed the duration of your registration.

Transmitting your personal data for processing

Art. 5. (1) Puzzlenarium may, at its own discretion, transmit all or part of your personal data to processors for the purposes of processing, subject to the requirements of Regulation (EC) 2016/679.

(2) Puzzlenarium Ltd. notifies you in case of intent to transfer all or part of your personal data to third countries or international organizations.

Your rights in the collection, processing and storage of your personal data

Withdrawal of consent to process your personal data

Art. 6. (1) If you do not wish all or any of your personal data to continue to be processed by Puzzlenarium for any or all processing purposes, you may at any time withdraw your consent to processing by filling in the form in your client profile or by request in free text.

(2) Puzzlenarium Ltd. may ask you to certify your identity and identity with the data subject.

(3) By withdrawing the consent to the processing of personal data that is required to create and maintain your registration for the use of the Services, any information on past training or translations will be inaccessible.

Right of access

Art. 7. (1) You have the right to request and obtain from Puzzlenarium Ltd. confirmation of the processing of personal data relating to you.

(2) You have the right to access the data related to it, as well as information relating to the collection, processing and storage of your personal data.

(3) Puzzlenarium Ltd. provides you with a copy of the processed personal data relating to you on request, in electronic or other appropriate form, and in the case of an excessive number of queries Puzzlenarium reserves the right to impose an administrative fee.

Right of adjustment or replenishment

Art. 8. You may correct or fill in inaccurate or incomplete personal data by requesting Puzzlenarium Ltd..

Right to delete ("to be forgotten")

Art. 9.(1) You have the right to request Puzzlenarium Ltd. to delete the personal data relating to you and Puzzlenarium Ltd. has the obligation to delete them without undue delay when any of the following reasons exists:

  • personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • You withdraw your consent on which the processing of the data is based and there is no other legal basis for the processing;
  • You object to the processing of personal data related to you, including for the purposes of direct marketing, and there are no legitimate grounds for processing that have an advantage;
  • personal data has been tampered with;
  • personal data must be deleted to comply with a legal obligation under EU law or the law of a Member State that applies to Puzzlenarium Ltd.;

(2) Puzzlenarium Ltd. is not obliged to delete personal data if it keeps and processes it:

  • for the exercise of the right to freedom of expression and the right to information;
  • to comply with a legal obligation that requires treatment provided for under EU law or the law of the Member State that applies to the Administrator or for the performance of a public interest task or the exercise of official authority;
  • for reasons of public interest in the field of public health;
  • for purposes of archiving in the public interest, for scientific or historical research or for statistical purposes;
  • for the establishment, exercise or protection of legal claims.

(3) In order to exercise your right to "forget", you should submit a request through the option in your account / in case you have a registration / or a written request sent to Puzzlenarium Ltd. as well as to certify your identity and identity with the person, to which the data before Puzzlenarium Ltd. refers, by presenting your identification document on the spot.

(4) Puzzlenarium Ltd. does not delete the data that it has a legal obligation to store, including for protection against claims brought against it or proof of its rights.

Right of limitation

Art. 10. You have the right to request from Puzzlenarium Limited to limit the processing of your related data when:

  • The right to transfer the accuracy of the personal data for a period that allows Puzzlenarium Ltd. to verify the accuracy of the personal data;...
  • processing is illegal, but you do not want your personal data to be erased, but only to limit their use;
  • Puzzlenarium Ltd. no longer requires personal data for the purpose of processing, but you require them to establish, exercise or protect your legal claims;
  • You have objected to the treatment pending verification that the legal grounds of Puzzlenarium Ltd. have an advantage over your interests.

Right of portability

Art. 11. (1) You may at any time download the data that is stored and processed for you in connection with the use of Puzzlenarium Ltd. services by email request.

Right to receive information

Art. 12. You may request Puzzlenarium to inform you of all recipients to whom personal data for which a correction, erasure, or limitation of the processing has been requested has been disclosed. Puzzlenarium Ltd may refuse to provide this information if this would be impossible or would require disproportionate effort.

Right of objection

Art. 13. You may object at any time to the processing of personal data from Puzzlenarium Ltd. that apply to you, including whether processed for profiling or direct marketing purposes.

Your rights in violation of the security of your personal data

Art. 14. (1) If Puzzlenarium Ltd. establishes a breach of security of your personal information that may pose a high risk to your rights and freedoms, we shall notify you without undue delay of the violation and of the measures taken or to be taken.

(2) Puzzlenarium Ltd. is not obliged to notify you if:

  • has taken appropriate technical and organizational safeguards in respect of the data affected by the security breach;
  • has subsequently taken measures to ensure that the violation will not lead to a high risk for your rights;
  • notification would require disproportionate efforts.

Individuals to whom your personal information is provided

Art. 15. For translation and legalization services, your personal data is processed by translators and editors who have been accredited to the MVP.

Other provisions

Art. 17. In case of violation of your rights under the above or applicable data protection laws, you have the right to file a complaint with the Personal Data Protection Commission as follows:

  1. Name: Commission for Personal Data Protection
  2. Headquarters and address of management: Sofia 1592, "Prof. 2 Tsvetan Lazarov
  3. Correspondence data: Sofia 1592, "Prof. 2 Tsvetan Lazarov
  4. Contact phone: 02 915 3 518
  5. Email: kzld@government.bg, kzld@cpdp.bg
  6. Website: www.cpdp.bg

Art. 18(1). When assigning Puzzlenarium Ltd. to process personal data to a third party for the purpose of using the service, Puzzlenarium Ltd. acts as a personal data processor.

(2). In the cases under para. 1, Puzzlenarium Ltd. acts solely on your instruction as the user of the service and only to the extent that it may have control over the personal data you are processing.