PRIVACY AND DATA PROTECTION NOTICE
Thank you for taking an interest in our work as a visitor to the site, as well as the protection of personal data. This is an important aspect of modern life and we wish to inform you as accurately as possible about the personal data we process and what rights you have in relation to it.
All our employees are obliged not to disclose information, including personal data, which has come to their knowledge during and on the occasion of their work and have signed a declaration to this effect.
This Notice provides you with information in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR, GDPR, the Regulation, or the GDPR), as well as the Personal Data Protection Act (Personal Data Protection Act, or PDPA). Privacy Act), about how Web Devolution 7 Ltd. and the site you have visited and is owned by Web Devolution 7 Ltd. ( abbr. “we,” “us,” “us,” “the site,” “Web Devolution 7 Ltd.”) use and process information that may contain personal data.
We regularly review the content of this Notice and update, modify or supplement it as necessary.
First of all, it is good to know that any information by which it is possible to identify you as an individual subject constitutes personal data and falls under the protection of the GDPR and the DPA.
When do we process personal data?
І. Contact forms
- When you contact us by sending an email to one of the email addresses (e-mails) listed on our website or another one that we have personally designated for you.
- When you contact us by calling or texting us at one of the phone numbers listed on the site or another provided to you.
- When you contact us via the contact form on the site, which appears via the site menus “contact” and “request a quote.”
You have the choice to communicate with us in any of these ways you see fit.
In each of these cases, you voluntarily provide information such as contact details (email and/or phone number), a name that you provide to us, and any information that you see fit.
Limitation of purposes and processing
We process the information you provide, including personal data, only for the purpose of being able to respond to you appropriately according to your needs.
If we need more information and personal data in order to respond to your enquiry or message, we will ask you to provide it to us, voluntarily.
If we record your phone call, you will be notified before the call starts.
Who has access to your personal data?
Your messages and calls will reach the employees of Web Development 7 Ltd to whom they are addressed or who are competent to respond appropriately or provide you with the offer you need. Where data needs to be provided to third parties in order to respond to you appropriately, this will be anonymised where possible depending on the nature of your enquiry. In very rare cases, data will be provided to the relevant authorities or institutions who have a legal obligation to obtain it.
Purposes and legal basis for processing personal data
- Performance of a contractual obligation (Article 6(1)(b) of the GDPR)
In this case, the processing of personal data is based on the performance of pre-contractual relations that precede contractual relations, as well as on the performance of obligations under a concluded contract. In this case, it will also now be necessary to provide your exact data, in which case consent to processing is not required and accordingly cannot be withdrawn.
- Performance of a legal obligation (Article 6(1)(c) GDPR)
Sometimes the processing of personal data is based on legal obligations, such as – for example – requests from various authorities and institutions within their competence, to which we are obliged to respond. When they do not need personal data, it will not be provided to them, only other types of information.
- Pursuit of legitimate interests (Article 6(1)(f) GDPR)
The legitimate interests in this case are: being able to respond to you; selecting suitable business partners; settling legal claims; defending against claims.
Data retention period
Personal data will be stored for 1 year and then deleted. This period is necessary in order to respond to you when you have further or clarifying questions and queries, and in the event of legal disputes.
II. Conclusion of contracts and their execution.
When concluding a contract with us, the subject is obliged to provide the necessary information to be individualized and to make it clear with whom the contract is concluded. Accordingly, for natural persons, a sufficient amount of information is provided, including personal data such as names, personal identification number, address, and any other information necessary for the performance of the contract according to its specifics. The public data provided by the legal entity in the Trade Register (TRRJLC) or the BULSTAT register does not fall under the protection of the GDPR and the DPA.
Limitation of purposes and processing
We process the information provided by you, including personal data, only for the purpose of concluding and performing the contract. Personal data will also be necessary prior to the conclusion of the contract, when the contract is still being processed.
Who has access to your personal data?
The employees of Web Development 7 Ltd. who are responsible for the conclusion and execution of the contract. Where it is necessary to provide data to parties not involved in the contract (such as external accountants, lawyers, etc.) in order for the conclusion and performance of the contract to take place, they will be anonymised where possible depending on the nature of the work. Compliance with data protection rules will be ensured by contract with our subcontractors.
Purposes and legal basis for processing personal data
- Performance of a contractual obligation (Article 6(1)(b) of the GDPR)
In this case, the processing of personal data is based on the performance of pre-contractual relations that precede contractual relations, as well as the performance of obligations under a concluded contract. In this case, it will also now be necessary to provide your exact data, in which case consent to the processing is not required and accordingly cannot be withdrawn.
- Performance of a legal obligation (Article 6(1)(c) GDPR)
Sometimes the processing of personal data is based on legal obligations. These obligations include, e.g., compliance with storage and identification requirements, e.g., in the context of anti-money laundering requirements, tax control and reporting obligations, and processing of data in the context of requests from authorities and institutions within their legal competence to which we are obliged to respond. Where they do not need personal data, it will not be provided to them, only other types of information.
- Pursuit of legitimate interests (Article 6(1)(f) GDPR)
It is necessary for us to process the personal data provided by you beyond the actual performance of the contract. The legitimate interests here are specifically: accounting; the selection of suitable business partners; the settlement of legal claims; the defence against claims; the clarification of possible breaches of regulatory rules, the prevention of crime and the regulation of damage affecting the business relationship; the possible collection of data on your solvency through credit bureaus in order to protect our legitimate interests.
Data retention period
Personal data will be stored for 11 years and then deleted. This period is statutory in tax legislation for the retention of primary accounting documents and includes any limitation periods in the event of legal disputes. If a legal dispute continues beyond these 11 years, the data will be kept until the dispute is resolved.
III. Targeted (targeted or individual) messages, advertisements and offers
We use platforms such as Facebook, Instagram, Google, YouTube to track your behaviour (such as location, time, interests, etc.) when you use them and the data we receive from them helps us to send you personalised or generic targeted ads and offers. To do this, we use platforms and tools such as Google Analytics and Facebook Business Manager through which we exchange information, including personal data.
These platforms try to find a match to your profile in their database and decide when and where (the website you are viewing) is best and optimal to show you our advertising. We also need all this information to be able to analyse our advertising campaigns and their impact on our business. If you do not wish to be tracked for these purposes, then you may also see advertising from Web Devolution 7 Ltd, but it will be accidentally seen.
Categories of personal data
Identity Information
Contact information (if available to us)
Location information
Payment, purchase and transaction data (if available and accessible to us and we need it)
Social media activity and interaction (if available and accessible to us)
Information about browsing the internet
Mobile Device Information
Behaviour and preference information (if available and accessible to us)
Personal opinion
We may use cookies/tags/pixels: we may collect your personal data for this purpose by using technologies such as cookies, pixels and tags to collect information about your device. More information is available in “Collecting information about your device on our website and apps using cookies, pixels, tags and similar technologies”.
You can find out more about how our advertising partners and social media platforms are helping us achieve this goal by visiting their websites:
Google Personalised Advertising: https://support.google.com/adspolicy/answer/143465?hl=en
Google Advertising Policies: https://support.google.com/adspolicy/answer/6020956
Facebook Lookalike Audiences: https://www.facebook.com/business/help/164749007013531
Facebook Custom Audience Terms: https://www.facebook.com/legal/terms/customaudience
Who has access to your personal data?
Employees of our team, and the mentioned partner platforms such as Google and Facebook for the data that is used.
Legal basis for processing personal data
- Consent (Article 6(1)(f) GDPR)
Data retention period
Until consent is withdrawn.
IV. Research and product development
We perform analysis to improve our products and services. This includes asking you questions, participating in surveys, asking you for feedback, asking you to leave feedback and reviews after using or trying our services and products, asking other service providers to conduct market, marketing and product research for us, trying out new technologies in our product that may collect personal data to stay ahead of the competition. We hold this information on the basis of our “legitimate interest”, so by taking part in any of these activities, you are agreeing that this is our legitimate interest. Where possible for the specific occasion, or if you object to this legitimate interest, we will remove any identity, contact or mobile device information so that the information cannot be used to identify you and will no longer constitute your personal data, and will be considered “anonymised.”
CATEGORIES OF PERSONAL DATA
Measurements (only if required by the project)
Identity information (only if required by the project)
Contact information (only if required by the project)
Location information (only if required by the project)
Payment, purchase and transaction data (if available and accessible to us and we need it)
Social media interaction and activity (only if required by the project)
Web browsing information (only if required by the project)
Mobile device information (only if required by the project)
Correspondence (only if required by the project)
Behaviour and preference information (only if required by the project)
Legal basis for processing personal data
- Pursuit of legitimate interests (Article 6(1)(f) GDPR)
Data retention period
The duration of the project and the legal retention period specified to protect our intellectual property rights
- Collecting information about your device on our website using cookies, pixels, tags and similar technologies
Using the so-called “Facebook pixel”, cookies are set on our website with your consent (see cookies with the provider or designation “Facebook” below in our list of cookies used). In addition to us, Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (Facebook) is jointly responsible for the processing of data relating to the pixel in accordance with Article 26 GDPR. The agreement on which the cooperation with Facebook is based can be found here – https://www.facebook.com/legal/controller_addendum. Pixel collects data about your use of our website and compares it with data from Facebook in order to show you tailored advertising on the Facebook website. Facebook also uses the data for its own advertising purposes as well as for third-party advertising purposes in accordance with Facebook’s privacy policy – https://www.facebook.com/policy.php. There you will also find further information on how you can exercise your rights with Facebook as a data subject with regard to your data processed by Facebook.
We also use Google Remarketing to deliver personalised ads via the Floodlight tag. In the performance of the service, in cooperation with us, the responsibility for the protection of personal data in accordance with Article 26 GDPR rests with Google Ireland Limited (registration number: 368047) with its registered office and registered address at 1st and 2nd Floor, Gordon House, Barrow Street, Dublin 4, Ireland (Google). The agreement on which the cooperation with Google is based can be found here – https://business.safety.google/intl/en_uk/adsservices/. “Google Remarketing” collects data about your use of our website and compares it with data from Google’s search engine in order to show you advertising tailored to your preferences. Google’s privacy policy can be found here – https://policies.google.com/privacy?gl=BG&hl=bg. Should you wish to have your Google information deleted- https://policies.google.com/privacy?gl=BG&hl=bg#infodelete.
To make your visit to our website as functional as possible, we use cookies. These include data processing for the technical purpose of ensuring optimal website performance, as well as other tools to achieve convenient settings for you, to create anonymous statistics and personalized (advertising) content. In the “Detailed selection” section you can allow or refuse the use of the tools.
“Cookies are small text files that websites can use to make the user experience more efficient.
Cookies are small text files that are stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not cause any damage to your end device and do not contain viruses, trojans or other malware. The information is stored in the cookie, resulting in a link to the specific device used. However, this does not mean that we immediately know your identity.
The law states that we may store cookies on your device if they are absolutely necessary for the operation of this website. For all other types of cookies, your consent is required
This website uses different types of cookies. Some of these are linked to third party services that appear on our pages.
You can change or withdraw your consent from the Cookie Statement on our website at any time.
Depending on the category of the cookie or other technologies for processing consumption data, the use of cookies and other technologies serves the following purposes:
Technically required:
Legal basis:
- Pursuit of legitimate interests (Article 6(1)(f) GDPR)
These are cookies and similar methods without which you cannot use our services (e.g. to display our websites/required features correctly).
User input to save records across multiple subpages (e.g. selecting the preferred store in Lidl’s store finder);
Security events (e.g., browsing security for visitors by preventing tampering with site requests
Multimedia content playback data (e.g. playback of (product) videos selected by the user).
Our website cannot work without these types of cookies, which are:
| Name | Supplier | Objective | Validity | Type |
| ASP.NET_SessionId | lidl.media01.eu | Saves the visitor’s session state in page requests. | Session | HTTP Cookie |
Comfort:
Legal basis:
- Consent (Article 6(1)(f) GDPR)
Using these techniques, we may take into account your actual or perceived preferences for the convenience of using our website. For example, based on your preferences, we may display our website in a language that is appropriate for you. In addition, we avoid displaying offers that may not be available in your region.
These are UI settings that are not associated with a persistent identifier (e.g., active language selection or specific display of search queries or store locator cards).
The cookies used in this category are:
| Name | Supplier | Objective | Validity | Type |
| CookieConsentBulkSetting-# | consentcdn.cookiebot.com | Allows cookie consent across multiple websites | Persistent | HTML Local Storage |
Stats:
Legal basis:
- Consent (Article 6(1)(f) GDPR)
These techniques allow us to compile anonymous statistics on the use of our services in order to design them as needed. This enables us to determine, for example, how to adapt our website even better to users’ habits.
Pseudonymised user profiles with information about the use of our website. These include in particular:
- browser type/version,
- operating system used,
- reference URL (the page visited before),
- Host name of the accessing computer (IP address),
- server request time,
- individual user number and
- Triggered website events (browsing behaviour).
The IP address is regularly anonymised so that it cannot be traced back to you personally.
We combine the user identification number with your other data (e.g. name, email address, etc.) with your explicit consent. We cannot draw any conclusions about you personally based on the user ID itself.
Statistical cookies help site owners learn how visitors interact with their sites by collecting and reporting anonymous information.
| Name | Supplier | Objective | Validity | Type |
| _dc_gtm_UA-# | lidl.bg | Used by Google Tag Manager to control the loading of a Google Analytics tag script. | 1 day | HTTP Cookie |
Marketing:
Legal basis:
- Consent (Article 6(1)(f) GDPR)
This enables us to show you relevant advertising content based on our analysis of your behaviour. Your user behaviour may also be tracked across different websites, browsers or endpoint devices using a user identifier (unique identifier).
Pseudonymised user profiles with information about the use of Our Website. These include in particular:
IP address,
individual user identification number;
potential product interests,
Triggered website events (browsing behaviour).
IP addresses are anonymised on a regular basis, so contact with your identity is completely excluded.
We combine the user identification number with your other data (e.g. name, email address, etc.) with your explicit consent. We cannot draw any conclusions about you personally based on the user ID itself. We share the post-User ID and related profiles for use with third parties, if necessary, through the providers of advertising networks.
Where cookies are used on the basis of your consent, then you may withdraw/correct your consent to any cookies for which consent is required at any time with effect for the future, without prejudice to the lawfulness of processing on the basis of consent until revocation.
The types of cookies we use:
Marketing cookies are used to track visitors between individual sites. Their purpose is to serve ads that are relevant and appealing to the individual user, making them more valuable to ad publishers and third-party advertisers.
| Name | Supplier | Objective | Validity | Type |
| ads/ga-audiences | google.com | Used by Google AdWords to re-engage visitors who are likely to convert into customers based on the visitor’s online behaviour on websites. | Session | Pixel Tracker |