PRIVACY POLICY

Personal Data Protection Policy – VERNE


“MS Studio” Ltd., UIC 204154880 (under the trademark “VERNE”, and mentioned as “the Company” or “We”) accepts its obligations under the General Data Protection Regulation (Regulation (EU) 2016/679) and the Bulgarian legislation and strives to comply with the highest applicable standards and best practices for personal data processing.


DEFINITIONS


Personal Data Administrator: the Organization or the Individual, who determines the purpose and methods of personal data processing. 

Personal Data Processor: the Organization or the individual processing personal data on behalf of the administrator. 

Data Entity: the identified Individual. 

Personal Data: any information regarding the identified individual (“data entity”); an entity is an individual who can be identified (directly or indirectly) via information such as name, identification number, location information, one or any number of factors regarding the physical, physiological, genetic, economic, cultural or social identity of the individual.

Special Category Personal Data: personal data, specifying racial or ethnic origin, political views, religious or philosophical beliefs or membership in trade-unions; the processing of genetic data, biometric data for the sole purpose of identifying the individual, health data or data on the sexual life or sexual orientation of the individual.

Processing: Any action or set of actions performed with the personal data, whether by automatic or any other means of collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing, sharing or any other means by which the data becomes available, stacked and combined, limited, deleted or destroyed.

Third party is an individual or a legal person, a public authority, an agency or another entity that is different than the data entity, the administrator, the personal data processor or any other individuals who under the direct authority of the administrator and the processor have the right to process the personal data.

Personal data breach is an action / circumstance that causes accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to the personal data that is transmitted, stored or processed.


Personal Data Protection

From the 25th of May, 2018, the General Data Protection Regulation ("GDPR") is applied in the Member States of the European Union. VERNE complies with the GDPR and the principles for the processing of personal data enclosed in the European and National legislation.


VERNE ensures that the personal data it processes will be: 

processed in a lawful, conscientious and transparent manner in respect of the individuals

appropriate, related and limited to what is necessary in regards to the purposes for which the data is being processed 

necessary to be processed for abiding by the law

accurate and, if necessary, up-to-date 

stored in a form that allows the data entity  to be identified for a period no longer than is necessary for the purposes for which the personal data is processed

 processed in a way that ensures a sufficient level of protection of personal data.


The individuals – data entities, have the following rights in respect to their personal data:

the right to information (this is achieved by providing a clear and easily understandable privacy policy that gives information on how and for what purposes we use your personal data and what your rights are related to the personal data being processed)

the right to access the processed personal data and any information about how it is being processed

the right to fix and update the personal data when inaccurate or incomplete

 the right to limit the scope of data processing under the conditions set out in the acting legislation 

the right to delete personal data where there is no legal basis for continuation of the data processing 

the right to transfer your data between different administrators (e.g., between different service providers) 

the right to object to certain data processing practices, such as direct marketing

 the right not to be the subject to decisions with significant influence on you, taken only by automated systems

 the right to consent to the personal data processing 

the right to raise a complaint with the competent supervisory authority


VERNE will process the data on the basis of any of the following grounds: 

the data entity has given his/ her  informed consent to the processing of personal data for a particular purpose 

data processing is necessary in order to enter into or execute a contract with the data entity 

data processing is necessary to comply with the statutory law


Personal data used by VERNE


The personal data used and processed by VERNE can be divided into five categories: 

Visitors to the VERNE website and to the official social networking sites such as Facebook and Instagram 

Participants in games / raffles / campaigns organized by VERNE on our website, on VERNE official social networking sites (Facebook and Instagram) or through partners - marketing agencies 

Visitors to stores owned or leased by VERNE

 Staff and employees of VERNE, jobseekers and former employees;

Individuals (for example, lawyers, auditors, other independent consultants) and agents, persons of contact, employees of VERNE customers, partners and suppliers of goods / services with which VERNE has or is considering entering into a contractual or factual relationships (for example legal entities, transport and forwarding providers, telecommunication service providers, software and / or hardware solutions and infrastructure).

Visitors to the VERNE website - by filling in the contact form on our website, your information is being collected by us. Typically, this information helps us to satisfy your product or other requests. Based on the information you have filled in, it is possible for us to use it for determining and exercising rights in connection to potential or actual disputes with you arising out of claims or complaints made. We also collect information about your IP address and your consent to cookies.

When you register on  the VERNE website, you provide us with your e-mail address and names. You can also add additional information such as: mobile phone number, landline telephone number, date of birth, delivery address, additional e-mail address, bank card details, etc. 

When you place an order, you provide us with the following information: first and last name, shipping address, billing details, payment method, phone number, bank card details, etc.

On our website, we may store and collect information through cookies and similar instruments under the Cookie Policy.


Participants in games - When you register to participate in our games, you provide us with your personal information. We process it on the grounds of your unambiguous consent expressed through voluntary completion of the registration form for participation in the game / raffle / campaign (this also includes posting a comment on our official Facebook and Instagram pages).


Staff and employees of VERNE, jobseekers – VERNE processes your personal data, including special categories of personal data related to employment or civil relationships, or other job application data. Generally, "VERNE" processes this data for the purpose of preparation and execution of employment or other contracts, as well as for the fullfilment of its statutory duties as an employer.

Representatives, persons of contact and employees of VERNE customers, partners and suppliers - we normally receive your personal information from your employer or from you personally when we need to prepare, conclude or execute a contract or enter into a commercial relationship. For example, you may be referred to as a legal representative or person of contact in a contract or commercial correspondence in connection to the signing, performing or terminating a contract; making an offer; resolving commercial disputes and other similar issues.


Personal Data Disclosure 


By default, VERNE keeps your personal data in complete confidentiality and does not disclose it to third parties.

In some cases, VERNE may disclose personal data with its employees or with representatives of its clients, partners, couriers, carriers, contractors or suppliers, with government bodies and other physical or legal entities such as software and / or hardware vendors and / or infrastructure, external consultants for the purpose of establishing or exercising rights, on the basis of a legal obligation or in view of their legitimate interest according to the particular case.

Such disclosure only occurs when there is a good enough reason to do so and when a sufficient level of protection is ensured, including through written agreements with third parties disclosing personal data, where applicable.


Special Category Personal Data

VERNE does not process clients’ sensitive personal data – the clients are but are not limited to individuals or employees / representatives of customers, partners and vendors, visitors of the website and the social networking sites. 



Personal Data Storage

VERNE stores the various types of personal data in electronic and paper format in numerous documents for a strictly defined period of time. Fixed storage times are always in line with the purposes for which personal data is processed. These periods of time are governed by VERNE's Storage and Destruction Policy.


Exercising Your Rights to Your Personal Data

In the case of a requests for the exercise of the individuals’ rights to their personal data, VERNE communicates with the individual in a clear, transparent, comprehensible and easily accessible manner, in plain and simple language, especially for individuals under 18 years old. 

When dealing with a request for the exercise of rights to personal data, VERNE has an obligation to properly identify the individual in order to prevent the risk of unauthorized access to personal data.

Information about VERNE's actions taken in response to a request for the exercise of rights to personal data shall be made available to the individual without undue delay and generally within one month of receipt of the request.

Any information in the exercise of the data entity’s rights to personal data is provided by VERNE free of charge, except when the claims are deemed as unfounded or excessive. 

Personal Data Protection

VERNE takes measures to protect your personal data from accidental loss and unauthorized access, use, modification or disclosure. There are policies and procedures designed to protect information from loss, misuse and unlawful disclosure. We also take additional protection measures, including access control, strict physical protection and reliable practices for collecting, storing and processing information.

Moreover, we apply technical measures such as encryption, pseudonymisation and anonymisation of the collected personal data. 

Additional Information 

VERNE will promptly update, amend and add to this Policy at any time in the future when legal requirements or other circumstances demand it. 

If you wish to receive more information regarding the processing of personal data by VERNE or have any questions or complaints about the current privacy policy or the ways and purposes for which we use your personal information, please contact us using the following contact details: 

For "VERNE": Bulgaria, Sofia, Suhata River, No 7 Neofit Bozveli Str., bl. 7, ent. 1, floor 1, apt. 7, Email: atelier.verne@gmail.com