Privacy policy and terms

Eco Partners Bulgaria AD (hereinafter referred to as “Eco Partners”) is a company registered with the Commercial Register of the Registry Agency under UIC 204295072, having its seat and registered office at: Sofia, 35-37 Klokotnitsa Street, Entrance 3, 6th Floor, Apartment 47

Eco Partners is a controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter referred to as the “Regulation”),because it processes strictly defined categories of personal data.

The security of your information is one of our top priorities and this Policy aims to inform you of all aspects of the processing of personal data, which is your legitimate interest.

Contacting the controller

You may contact the Controller in any of the following ways:

• Via the toll-free phone number: 0800 20 015
• Via e-mail at: office@ecopartners.bg
• In writing to: Sofia, 45 Bulgaria Boulevard, 2nd floor, Office 5

I. Collection, processing and use of personal data

1. Users are not required to provide personal data in order to use Eco Partners App.

2. We collect information from mobile phones or tablets on which users use Eco Partners
App to allow the accurate operation of the service. However, the information we collect
from the devices is not classified as personal data and includes the following:

• GPS location – information is received through user-activated device settings

3. In some cases, the users can provide us with a certain category of personal data, as
follows:

• Data collected through an email form

a. If a user would like to participate in a campaign/game organized by Eco Partners
App, he would have to provide an email address, so that he can receive a prize
from the campaign/game.

II. Purposes of processing and legal bases

1. We process the data from the GPS location for the following purpose:

• We use users’ geolocation for the use of some funciotns of the app:
  • We use users’ geolocation to navigate and help them find where Eco Partners’
    yellow and green container sets are located in different Municipalities.
• We do not store any user’s geolocation information.

2. We process users’ personal data for the following purpose:

• Running our campaigns/games in accordance with their intended terms and conditions.

3. The decision to provide your personal data through our app is entirely voluntary.

4. Period of storage of personal data

• Eco Partners shall ensure the lawful processing of users’ personal data, including in
  relation to their storage period. This period is the minimum necessary to achieve the
  purposes for which the data are processed.

III. Your rights in relation to the processing of personal data

You have multiple rights to protect your interests in relation to the processing of your personal
data by Eco Partners. You can exercise all the rights listed below by submitting a request to Eco
Partners. Eco Partners shall make every effort to comply with your request without undue delay.

• Right of access

You have the fundamental right to obtain at any time from Eco Partners confirmation as to whether
your personal data are being processed, as well as access to processed personal data and
information on the purposes of the processing, the categories of personal data being processed,
the recipients of your personal data, the processing period, the existence of automated decisionmaking effected,

and your rights in relation to the processing. This is how you may exercise your right of access to your personal data processed by us.

• Right to erasure

As a data subject whose personal data are processed by Eco Partners, you have the right to obtain
from the Controller their erasure where one of the following applies:

a) the personal data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed.

b) you withdraw the consent on which the processing of your personal data is based.

c) your personal data have been unlawfully processed.

d) you have objected to the processing of your personal data and there are no overriding legitimate
grounds for the processing.

e) the personal data must be erased for compliance with a legal obligation in Union or Bulgarian
law.

• Right to restriction of processing

Another right you have in relation to the processing of your personal data by Eco Partners is to
request, insofar as the legal requirements have been met, that Eco Partners restrict the processing
of your personal data where one of the following applies:

a) you contest the accuracy of the personal data, for a period enabling Eco Partners to verify the
accuracy of your personal data.

b) the processing is unlawful, and you oppose the erasure of the personal data and request the
restriction of their use instead.

c) Eco Partners no longer needs your personal data for the purposes of the processing, but they are
required by you for the establishment, exercise, or defense of legal claims.

• Right to object to processing of personal data

Insofar as your personal data are subject to processing by Eco Partners, you have the right to object
at any time to such processing. In this case, Eco Partners shall no longer process your personal data
unless it demonstrates compelling legitimate grounds for the processing, such as compliance with
legal obligations or other justifiable reasons for further processing, which override your interests,
rights, and freedoms or for the establishment, exercise, or defense of legal claims.

• Right to withdraw your consent

Where processing of your personal data by Eco Partners is based on your explicit consent, it shall
cease upon the withdrawal of your consent. This right of yours has immediate effect without
prejudice to the lawfulness of any processing based on consent before its withdrawal.

• Right to data portability

You have the right to receive a copy of the personal data you have provided to Eco Partners,
including, where possible, in electronic form. Right to lodge a complaint with a supervisory
authority:

If you consider that your personal data are processed unlawfully or your rights in relation to them
have been infringed, you have the right to lodge a complaint with the competent Bulgarian
supervisory authority – the Commission for Personal Data Protection (CPDP). You can contact CPDP
using the following contact details:

Address: Sofia 1592, 2 Professor Tsvetan Lazarov Boulevard

Telephone: 02/91-53-518

E-mail: kzld@cpdp.bg

• Changes to the Privacy Policy

Eco Partners strives to ensure at all times maximum protection of the personal data of our
website’s visitors. In view of this, Eco Partners takes measures in accordance with all modern
means of protection and reserves the right to change the security and data protection measures,
if necessary. Eco Partners reserves the right to amend this Policy in such cases.

• Contacts

For further questions regarding the collection, processing and use of your personal data, you may
contact Eco Partners in any of the ways listed in the Contacting the Controller section. Eco Partners
shall do everything in its power to answer your questions or comply with your requests without
undue delay.