In accordance with the principle of transparency and Regulation No 679/2016, Studio Apparel Ltd., as a personal data controller, provides you with information on how we use, share and store your personal data.

Who are we?

Studio Apparel Ltd. is a legal entity registered in the Commercial Register of the Registry Agency with UIC 205573059, seat and management address: 72 Cherkovna Str., entr. B, fl. 2, ap. 15, Sofia, Republic of Bulgaria.

How can you contact us?

You can contact us in a preferred and convenient way for you, namely: by email – customer@enibbana.com or at the following address: 72 Cherkovna Str., entr. B, fl. 2, ap. 15, Sofia, Republic of Bulgaria.

To whom do these Transparency Rules apply?

These Transparency Rules for the processing of personal data apply to:

  • Our clients;
  • Our counterparties;
  • Applicants for work / internship;

Persons who have agreed to the processing of their personal data for marketing purposes

CLIENTS

Client is any person with whom the controller concludes a contract under which the latter is obliged to provide the product or service that is object of the main activity of the data controller.

What data do we collect about our clients?

The data we collect about you is determined by the parameters of the particular inquiry or contract.

How do we collect our clients’ personal data?

The way we collect your personal data is directly from you and the information you provide to us, including when generating a inquiry, order, or requesting a product/service.

Purpose of processing personal data of clients?

If you are a client of ours, you should know that the purpose for which we process your personal data is to conclude a contract or to execute a contract already concluded, as well as to fulfill a legal obligation existing for Studio Apparel Ltd.

By way of exception, we process personal data of clients in order to protect the legitimate interest of Studio Apparel Ltd. or a third party.

On what basis do we process the personal data of our clients?

The basis on which we process personal data of clients is based on existing pre-contractual or contractual relationships.

In certain cases we process personal data of clients in order to fulfill a legal obligation or on the basis of a legitimate interest of Studio Apparel Ltd. or a third party.

To whom do we provide the personal data of our clients?

Studio Apparel Ltd. provides the personal data of its clients to third parties only if it is necessary for the execution of the contract or under the applicable law (couriers, postal operators, etc.).

For the purposes of accounting documents, Studio Apparel Ltd. provides personal data to the accounting firm and in view of the specifics of the service provided - https://www.shopify.com/legal/privacy

It is possible to provide third parties with personal data of clients in connection with their statutory powers - state and/or municipal authorities, as well as private bodies, to which certain rights and/or obligations are ascribed to them by law (including customs, National Revenue Agency, judicial or executive authorities, notaries, lawyers, bailiffs and others).

Studio Apparel Ltd. does not intend to provide the personal data to its clients to third parties or international organizations. If this is necessary for the purposes of executing the contract/or legal obligation, the needed measures will be taken to ensure the protection of your personal data.

How long do we keep our clients' personal data?

The client’s data is being kept after the completion of the execution of the contract /termination/ for a period of 10 years, starting from January 1 of the reporting period, following the reporting period during which the obligation became due. Keeping client’s data is for the purposes of financial-accounting and tax-reporting activity.

All other personal data, the storage of which is not justified in carrying out the financial-accounting and tax-accounting activity, shall be kept for a period of 5 years from the completion of the execution of the contract.

COUNTERPARTIES

The counterparties are subjects with which Studio Apparel Ltd. has contractual relationships that are ancillary to the main activity of the personal data controller.

What type of personal data do we collect?

The data we collect about you as our counterparties is personal data that does not fall into the categories of sensitive data and is only necessary for the conclusion and/or execution of the existing contract between us.

How do we collect the personal data of our counterparties?

The personal data of the counterparties of Studio Apparel LTD. are collected directly by the counterparties. The processing of personal data of counterparties may be based on contracts concluded through online platforms or email correspondence.

For what purpose do we process the personal data of our counterparties?

If you are a counterparty of ours, the purpose for which we process your personal data is to conclude or execute a contract already concluded.

In certain cases, we process personal data of our counterparties in order to fulfill an obligation of ours under the applicable law or in order to protect the legitimate interest of Studio Apparel Ltd. or a third party.

On what basis do we process your personal data?

The reason for processing your personal data is the pre-contractual and contractual relations existing between us.

In certain cases, the basis on which we process your personal data is to fulfill a statutory obligation for Studio Apparel Ltd. or to protect the legitimate interest of Studio Apparel Ltd. or third parties.

To whom do we provide your personal data?

Studio Apparel Ltd. provides the personal data of its counterparties to third parties insofar as it is necessary for the conclusion or execution of a contract already concluded (e.g. a bank, a courier company, etc.), and if the latter is necessary for the fulfillment of a legal obligation (National Revenue Agency, etc.) or the protection of the legitimate interest of Studio Apparel Ltd. (judicial and executive authorities, attorneys, notaries, bailiffs, etc.).

For the purposes of accounting services, in connection with the existing relationships of Studio Apparel Ltd. with the counterparties, the data of the latter is provided to an external accounting firm.

Studio Apparel Ltd. does not intend to provide the personal information of its counterparties to third parties or international organizations. If this is necessary for the purposes of executing the contract/or legal obligation, the needed measures will be taken to ensure the protection of your personal data.

For how long do we store the personal data of our counterparties?

The storage of the data of the counterparties after the end of the contract is for financial-accounting and tax purposes only and it is for a period of 10 years - from 1st January of the reporting period, following the reporting period during which the obligation became due.

CANDIDATES FOR JOB/INTERNSHIP

When applying for a position in Studio Apparel Ltd. documents containing personal data are being submitted. The processing of the latter is carried out in accordance with the Personal Data Protection Act and the General Data Protection Regulation.

What type of your personal data do we process?

The personal data we collect about job/internship applicants are only necessary to determine the applicant's competency and their future involvement in the team.

How do we collect your personal data?

The collection of personal data of job/internship applicants is based on the documents submitted by them - autobiography/CV, cover letter, certificates, diplomas, etc., as well as copies of them.

For what purpose do we process your personal data?

The purpose of processing your personal information is at the discretion of human resources management, financial-accounting activity and is substantiated by our common desire to conclude a contract.

On what basis do we process your personal data?

The basis for the processing of your personal data is the pre-contractual relationship aimed at concluding a contract for employment or internship.

How long do we keep your personal data?

The personal data provided during the recruitment process is being kept for a period of 6 months from the completion of the selection procedure and is not made available to third parties, third countries and/or international organizations.

After the expiry of the period referred to in the previous subparagraph, the data shall be destroyed or erased.

If during the selection procedure, original documents or notarized copies of documents are being presented, certifying the physical and mental fitness of the applicant, the required qualification and length of service for the position held, the data subject may request within 6 months of the final completion of  the selection procedure to receive the submitted documents back.

PERSONS CONSENTED TO THE PROCESSING OF THEIR PERSONAL DATA FOR MARKETING PURPOSES

Persons who have subscribed to receive marketing communications are subjects that, with their explicit consent, have allowed Studio Apparel Ltd. to process their personal data for the purpose of receiving marketing communications with a type of content pre-defined by them.

What type of data do we collect?

The data we collect about you is personal data that does not fall into the categories of sensitive data and is only necessary in order to provide you with the information you specify in the way you choose.

How do we collect your personal data?

Studio Apparel Ltd. collects your personal data directly from you.

For what purpose do we process your personal data?

The purpose for which we process your personal data is to provide the information you specify in the consent to the processing of personal data.

On what basis do we process your personal data?

The reason for processing your personal data is your given consent.

To whom do we provide your personal information?

Studio Apparel Ltd. does not provide your personal information to third parties.

Studio Apparel Ltd. does not intend to transfer your personal data to a third country and/or to an international organization.

For how long do we keep your personal data?

The storage of the data of persons who consent to the processing of personal data is for the duration of the consent.

How to withdraw your consent?

You can withdraw your consent at any time by submitting your application/request in free text at the office at: Sofia, 72 Cherkovna Str., entr. B, fl. 2, ap. 15, as well as via email.

When withdrawing consent, it is important to identify the consent you gave by indicating the purpose for which you gave your consent and for which you withdraw the consent.

THE WEBSITE VISITORS

What personal data do we collect about website visitors?

Studio Apparel Ltd. does not collect personal data from the website visitors. When someone visits the controller’s website, the information that is collected is related to visitors’ behavior patterns. We do this to find the number of visitors to the different parts of the site. This information is only processed in a way that does not identify the subject. We make no attempt to understand the identity of the visitors to our website.

You can get a closer look at the information stored through so-called “cookies” in our Cookies Policy.

RIGHTS OF THE DATA SUBJECTS

With regard to the processing of your personal data, it is important for us to inform you that you have a set of rights that you are free to exercise when you consider it necessary by contacting Studio Apparel Ltd., as your personal data controller, with the relevant request.

THE RIGHT OF ACCESS

What is the right of access to personal data?

Based on the right of access, we inform you whether we process your personal data, what categories of personal data we process and how, on what basis we do it, for what period we will process it, and whether we provide it to others.

Are we always obliged to respond to your request?

You may be denied access if your request is clearly ill-founded.

Access may also be refused if your personal data contain personal data of third parties, unless the third parties have explicitly agreed to provide you with their data.

What will you get in response to your request?

If we consider that your request is justified and its granting would not affect the personal data of third parties (or they have given their consent), you will receive a response that contains information by the above criteria.

If there is a ground for refusal, we will provide you with information about the ground for refusal.

RECTIFICATION OF PERSONAL DATA

What is the right to rectification of personal data?

The right to rectification of personal data makes it possible to correct inaccurate or already outdated data.

You may also exercise this right in cases where you need to supplement your personal data in view of the purposes for which we have been provided with them.

How can you exercise your right to rectification of personal data?

You can exercise your right to rectification of personal data processed by Studio Apparel Ltd. by submitting a request. You can use the format available on the controller’s site or submit a free text application.

In the request to rectify or supplement the data it is necessary to indicate which particular data you consider to be incorrect, how they should be corrected or supplemented, and to attach relevant evidence, if available.

What will you get in response to your request?

If we consider that your request should be granted, we will take the necessary steps to correct your personal data in the manner in which you have stated that this should be done.

If there is a ground for refusal, we will provide you with information about the ground for refusal.

ERASURE OF PERSONAL DATA

What is the right to erasure of personal data?

The right to erasure of personal data, or more commonly known as the right to be forgotten, enables you, once your personal data are no longer needed for the purposes for which Studio Apparel Ltd. collects and processes them, to ask the controller to have them erased.

When can you request an erasure of your personal data?

You may exercise your right to have your personal data erased if:

  • your personal data is processed on the basis of your consent and you decide to withdraw it;
  • you no longer want your data processed for marketing purposes;
  • you believe that processing them is illegal.

Will your request always be granted?

The right to be forgotten is not absolute, therefore Studio Apparel LTD. reserves the right to refuse to grant your request if the processing is:

  • on a legal basis;
  • for the establishment, exercise and defense of legal claims;
  • for the purposes for which they were collected or processed in some other way;
  • for scientific, research and statistical purposes as well as in the public interest.

Also, if your request is clearly ill-founded, we reserve the right to refuse to erase your data.

What will you get in response to your request?

In the event that we refuse to grant your request, you will receive our reasons for that decision.

If the conditions for satisfying your request are present, it will be fulfilled. In addition, if Studio Apparel Ltd. has provided your information to third parties - individuals or legal entities, government institutions, etc., the controller is obliged to take all necessary and reasonable steps to notify third parties of your request.

RESTRICTING THE PROCESSING OF PERSONAL DATA

What is the right to restriction of the processing of personal data?

The right to restriction of the processing of personal data enables the data subject to restrict the way in which their personal data are processed, if they are doubtful about the accuracy of the data or how it is used.

Does the right to restriction prohibit the controller from processing personal data?

The exercise of this right does not affect the right of the controller to process your personal data in any of the following ways:

  • to continue to store your personal data;
  • to use them for the establishment, pursuit and defense of legal claims;
  • to protect the rights of others persons;
  • an important public interest requires this.

What is restriction of processing?

Usually, the restriction of processing of your personal data is temporary, for the following periods:

If you dispute the accuracy of your personal data - the processing of personal data is limited until it is clear whether the request the data to be rectified is justified;

If you object to the processing of your data on grounds of public or legitimate interest - the processing of personal data is restricted for the duration of the review, which will assess whose interest is paramount.

The restriction may not be temporary, but may be in relation to a particular type of processing.

If the restriction is temporary, the controller is obliged to inform you before it is terminated.

Is the data controller always obliged to grant your request?

The controller is obliged to grant your request if:

  • no longer needs your data for the purposes of processing it, but you need it to establish, exercise or defend legal claims;
  • you believe that we are processing your data inappropriately, but still you do not want to erase them;
  • has provided your information to third parties, the controller undertakes, as far as possible and would not cost us a disproportionate effort, to inform them of your request.

If we believe that your request for restriction is clearly ill-founded, we reserve the right to refuse to restrict the processing of your data by informing you for our reasoned refusal.

DATA PORTABILITY

What is the right to data portability?

Studio Apparel Ltd. as a personal data controller gives you the opportunity to exercise your right to data portability when your personal data are processed in an automated manner, based on your consent or processing is necessary to fulfill a contractual obligation. Based on this right, you will be able to obtain your personal data or directly transfer it to another – a personal data controller chosen by your.

You may request that you obtain your personal data in a structured and widely used machine-readable format and transfer it to another controller, or, where technically feasible, to request that we directly transfer it to a designated administrator.

Is the data controller always obliged to grant your request?

The right to data portability is not absolute. The right of data portability is applicable in cases where:

  • the processing is by consent or necessary to fulfill a contractual obligation, and
  • there is an automated processing of personal data.

What happens to my personal data after the data transfer request is granted?

The controller does not erase your personal information, but stops processing it for the purposes for which it was provided.

OBJECTION TO THE PROCESSING OF PERSONAL DATA

What is the right to object to the processing of personal data?

The right of objection allows you to oppose the processing of your personal data for specific purposes.

Can you always object to the processing of your personal data?

You may object to processing only when the controller processes them:

  • on the grounds of legitimate interest, whether it is the legitimate interest of the data controller or a third party;
  • for the purposes of scientific or historical research or for statistical purposes;
  • for direct marketing purposes (including profiling).

EXERCISE OF RIGHTS

How can you exercise the above mentioned rights?

You may exercise any of these rights (including the right to withdraw consent) by submitting a written request to the data controller.

How is a request submitted?

To do so, you can use the request form for the relevant right or submit an application in free text.

Where is the request form located?

The form is available in the office of the controller at the address, 72 Cherkovna, entr. B, fl. 2, ap. 15, Sofia, Republic of Bulgaria as well as a downloadable file.

What should the free text application contain if you would prefer to ask the controller in this way?

Your request should include your name and address, as well as other identifying information, if you consider it necessary, a description of your request, your preferred form of communication, date and signature

If you are acting as an authorized person, you must attach to the application the corresponding power of attorney.

Where is the request submitted?

The request can be submitted at the office of Studio Apparel Ltd. at 72 Cherkovna Str., entr. B, fl. 2, ap. 15, as well as by courier or mail to this address.

You can submit your completed application or request in free text and by email: customer@enibbana.com

How will you know the result of the request?

We will contact you in the way you specified - email or address. If you do not explicitly specify a method of communication - email or address, the controller will contact you in the manner he considers most convenient for performance. If you have provided only an email or only an address, we will contact you through the communication method you have provided.

Can I be asked for additional documents/data?

In order to protect the data subject's rights, you may be asked for additional documents or data to ensure that there is no abuse of right. The requested additional data or documents will not be processed in a way, by means, and for purposes other than identifying the data subject and the claimant.

How long will you wait for an answer?

Studio Apparel Ltd. is a personal data controller with a high level of commitment in the field of personal data protection, which is why we strive to respond to requests as quickly as possible. However, we would like to inform you that the statutory time limit is up to 1 month from the submission of the request.

REMEDY

What should you do if you are not satisfied with the controller’s response or feel that your rights have been violated?

If you believe that your rights under Regulation 2016/679 and under the Personal Data Protection Act have been violated, you have the right to file a complaint to the lead supervisory authority - the Commission for Personal Data Protection of the Republic of Bulgaria.

The Commission will look into your case and inform you of developments in handling the complaint and/or the outcome.

After ruling a decision, the Commission will send you a copy of the decision, which you have the right to appeal in court according to the rules of the Code of Administrative Procedure.

At the same time you have the opportunity to refer to the respective administrative court or the Supreme Administrative Court according to the rules set out in the Administrative Procedure Code of the Republic of Bulgaria.

Pursuant to Bulgarian law, you cannot bring a case to court if there are pending proceedings before the Commission for the same infringement or its decision on the same infringement has been appealed and no court decision has entered into force.