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PRIVACY NOTICE

I. General Provisions

The protection and the confidentiality of your personal data is of particular importance to us.

Pursuant to article 13 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the “GDPR”), we hereby provide you with information regarding the processing of your personal data provided by you and/or collected via the website www.mbe.bg (the “Website”).

The purpose of this Privacy Notice is to let you know what Personal Data we collect and use about you, the reasons why we use and share such data, how long we store it, and how you may exercise your rights.

The Personal data are processed in accordance with the GDPR, the Personal Data Protection Act and other applicable acts in connection with the protection of the personal data.

II. Personal Data Controller

The Personal Data collected via the Website shall be processed by MBE Bulgaria OOD,  registered in the Commercial Register and the Register of NPLE at the Registry Agency with UIC 206353571, with a registered seat and address of management in Sofia 1766, Vitosha Municipality, 5 Panorama Sofia Street, fl. 3, exclusive licensee for Bulgaria of the brand “Mail Boxes Etc”, in its quality of data controller (hereinafter the “Controller” or “MBE”).

MBE acts as a Data controller in compliance with the Applicable legislation on personal data protection in relation to the Personal Data of users of the Website and in providing services in connection with our core business.

In some cases, the MBE is in the role of Personal Data Processor, but then the MBE has correspondingly concluded contracts with our clients – data controllers, who assign us the processing of Personal Data, and we comply with these contracts. In this case, the data subjects should refer to the privacy notices of those business customers from whom their data originate.

If you have any questions about this Privacy Notice or your Personal Data, please, contact us.

Contact information:

MBE Bulgaria OOD

UIC 206353571

Address: Sofia 1766, Vitosha Municipality, 5 Panorama Sofia Street, fl. 3

E-mail:office@mbe.bg

III. Definitions

“Controller” means MBE Bulgaria OOD, UIC 206353571.

“Personal Data” means any information relating to an identified or identifiable natural person, who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

“Recipient” means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not.

"Applicable legislation" means legislation of the European Union and the Republic of Bulgaria, which is relevant to the protection of personal data, including, but not limited to: GDPR, the Personal Data Protection Act and others.

“Special categories of personal data” means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

“Third party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

IV. What Personal Data of Yours we process

We collect and process your Personal Data on the grounds provided for in the Applicable legislation, to the extent necessary to carry out our activities and to achieve a high standard for our products and services.

We respect the right to privacy of the personal life and we constantly work to keep the data we process minimized and protected as much as possible. However, in order to use our services, we must process some Personal Data. By using one of our services and/or registering an account, you accept and confirm that you have read and understood this Privacy Notice as well as our Cookie Policy.

In cases where the information is not collected for compliance with a legal obligation, for the performance of a contract to which you are a party, or for taking steps at your request before concluding a contract, in connection with the legitimate interest of MBE or to protect your vital interests, you may be required to consent to the provision and the processing of your personal data. Without consent, it may be impossible to receive some of the services, including receiving notifications of upcoming events and special terms and conditions, or communication with you may be difficult and delayed.

The following Personal Data provided by you may be processed via the Website: the IP address; navigation data on the Website; information on the browser and on the device; information collected through cookies, pixel tags, provided by you and without disclosing your specific identity; demographic information and other information provided by you and without disclosing your specific identity; information that has been aggregated in such a way as to no longer reveal your specific identity.

Moreover, the following Personal Data provided by you may be processed if you decide to interact with the Website:

  1. Name, surname, email address, telephone number and company, if you send messages to a specific MBE center through our forms;
  2. Only the email address if you wish to receive the MBE newsletter;
  3. Name and email if you use the chat box;
  4. Name, surname, email, address, company, telephone number, VAT number, your login account details and all the information related to the service you intend to purchase (e.g. size of the package, price, information on the relevant addressee) if you create an account and use our services;
  5. Your physical position, if you ask the Website for the MBE centers closer to your position;
  6. Name, surname, email, telephone number, city, CV, if you ask to be contacted in order to obtain information on how to commence your business with MBE;
  7. Name, surname, email, telephone number, address and CV if you ask to register to our seminars, workshops, webinars and events.

We do not collect Personal Data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning a natural person's sex life or sexual orientation.

V. For what purposes and on what grounds we process your Personal Data

The Personal Data we collect from you shall only be used for the purposes for which it has been declared that it is collected and/or in accordance with the requirements of the Applicable legislation.

The Controller shall process your Personal Data for the following purposes:

  1. To provide you with the services you request, and more in details: to establish, maintain and service commercial relations, to conclude contracts with you and execute the concluded contracts to which you are a party; to create your personal account; to find the MBE centers closer to your current position; to reserve your products delivery services in a specific MBE center selected by you, and to process payments direct to the specific MBE center above. Processing here is on grounds of Article 6, para 1, letter (b) from the GDPR – for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Any refusal to provide the Personal Data for the purposes set out here shall make it impossible to use and enjoy the services;
  2. To be contacted by the MBE staff in order to obtain the relevant information on how to commence your business with MBE; to register to our seminars, workshops, webinars and events. Processing here is on grounds of Article 6, para 1, letter (b) from the GDPR – for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Any refusal to provide the Personal Data for the purposes set out here will make it impossible to use and enjoy the services;
  3. To answer a question, inquiry, request, notification and similar regarding products, services, cooperation, activities of MBE. Processing here is on grounds of Article 6, para 1, letter (a) from the GDPR – the consent of the User. Any refusal to provide the consent and the Personal Data for the purposes set out here will make it impossible for us to answer the question, inquiry, request, notification and similar;
  4. To allow you to benefit from the features offered by the Website, and more in detail: to allow you to communicate with the specific MBE center selected by you and obtain the information you request through the contact forms on the Website and to chat with/send a message to MBE through the forms on the website. Depending on the exact situation Processing here is carried out either on grounds of Article 6, para 1, letter (a) from the GDPR – the consent of the User, in case of a question, inquiry, request, or on grounds of Article 6, para 1, letter (b) from the GDPR – for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. Any refusal to provide the Personal Data for the purposes set out above will make it impossible to send your contact request to the Controller and/or the selected MBE center;
  5. To improve the functioning of our Website. Processing here is on grounds of Article 6, para 1, letter (a) from the GDPR – the consent of the User. Any refusal to provide the consent and the Personal Data for the purposes set out here will make it impossible for us to improve the functioning of our Website;
  6. To handle complaints and for security and safety. Processing here is on grounds of Article 6, para 1, letter (e) from the GDPR – for the purposes of the legitimate interests pursued by the Controller. Any refusal to provide the Personal Data for the purposes set out here shall make it impossible to use and enjoy the services;
  7. To administer our activity, including reporting and analysis in MBE. Processing here is on grounds of Article 6, para 1, letter (e) from the GDPR – for the purposes of the legitimate interests pursued by the Controller. Any refusal to provide the Personal Data for the purposes set out here shall make it impossible to use and enjoy the services;
  8. To send you, by any means of communication (fax, e-mail, text message, multimedia messaging service, paper-based mail, operator-assisted phone calls), advertising material and literature of a promotional nature or in any case involving commercial solicitation pertaining to services, products or discounts offered by the Controller, as well as for conducting studies and surveys of the market, and elaborating related statistics. Processing here is on grounds of Article 6, para 1, letter (a) from the GDPR – the consent of the User. Any refusal to provide the Personal Data for the purposes set out here will have the sole consequence of making it impossible for the Controller and/or the selected MBE center to send you advertising and promotional messages, to conduct studies and surveys of the market, and elaborating related statistics.

Telephone calls to or from representatives of services involving Personal Data may be recorded in order to ensure quality and/or to fulfill a contractual or legitimate obligation, about which recording MBE shall inform you in advance.

In the event that MBE intends to use and perform additional Processing of your Personal Data for purposes other than the purpose for which they were originally collected or which was subsequently authorized by you, MBE shall inform you about this and shall offer you the opportunity to choose whether you allow your Personal Data to be used for purposes other than the purpose for which they were originally collected or which were subsequently authorized by you.

If the Processing of the Personal Data is on grounds of your consent, given by you, you can at any time withdraw your consent for the Processing of Personal Data by writing to us in any way convenient for you: by a letter to: 5 Panorama Sofia Street, fl. 3, Sofia 1766, at the e-mail address: office@mbe.bg or by submitting an application on place. Your Personal Data will be deleted from MBE systems within one month as of the date of receiving your request for withdrawing your consent. The withdrawal of the consent does not affect the lawfulness of the Processing based on a given consent prior to its withdrawal. Giving consent is voluntary, but you should keep in mind that it is necessary and that in the absence of your consent in the above cases, the MBE shall not be able to provide the activities and services related to the given consent.

By using the Website, you agree to receive marketing materials that are an integral part of it. An integral element of the Website are, for example, advertising banners on which MBE can promote its services and products or other advertising content. You have the option to opt out of these marketing communications at any time. Upon withdrawal of your consent, MBE shall not be able to send you marketing messages and provide you with offers, proposals, products, services, invitations to events. The withdrawal of the consent does not affect the lawfulness of the Processing based on a given consent prior to its withdrawal.

VI. Method of Data collection

MBE collects Personal Data, both from you and from third parties who have provided information related to you, including, but not limited to, when accessing and using our services and our Website, registering, placing an order, completing an application, filling out a form for feedback, posting a review, subscribing to our publications or entering information such as a comment or otherwise on our site. We also collect Personal Data through e-mail communication or through a service at our physical address.

VII. Who has access to your information

Access to your Personal Data in the structure of MBE have only the relevant employees of MBE, who are assigned to Process Personal Data according to their position and job function.

Your Personal Data may be disclosed to certain Third Parties, including:

  1. Partners, service providers and subcontractors for the purpose of performing a concluded contract, such as: persons providing and maintaining the telecommunication and information systems of MBE such as common infrastructure, e-mail, information systems; hosting service providers; companies that assist MBE in the implementation and maintenance of its current activities;
  2. Other data controllers who provide us with relevant services – banks, accounting firms, auditors, lawyers, professional consultants and insurers, event organizers and others – when it is necessary for our legitimate interest to provide us with a particular service and to the extent to which this information is necessary for the performance of the functions assigned to them;
  3. Public authorities which require us to declare processing activities, as well as law enforcement authorities, state authorities and other bodies of public administration, national and European regulatory authorities, if required by the Applicable legislation – in the cases provided by law, in connection with the performance of legal obligations or in connection with legal proceedings, as well as for the protection of the property of MBE and for the prevention of fraud and crime.

MBE may disclose your Personal Data to third parties who are Personal Data Processors or joint administrators, subject to the compliance with the legal requirements or upon your given consent.

VIII. Security measures

We have taken a wide range of technical and organizational measures to protect your Personal Data against loss or other forms of unlawful Processing. The Personal Data is available only to those persons who need access to perform their work in connection with the provision of our services.

MBE protects the personal information against risks such as loss or theft, unauthorized access, disclosure, copying, use, alteration or destruction through appropriate security measures. MBE protects the information regardless of the form in which it is stored.

If you have questions about the security of your Personal Data, you can contact us by e-mail: office@mbe.bg

IX. Transmission and transfer of Personal Data outside the European Economic Area (EEA)

We do not transfer your Personal Data to third countries and do not transfer it outside the EU or the EEA.

X. Terms of storage of Personal Data

We Process and store your Personal Data for a certain period of time, which is determined by:

  • the periods required for the compliance with the Bulgarian and the European legislation;
  • another period in respect of our operational requirements, with a view to protecting our legitimate rights and interests.

MBE shall not store your data longer than necessary for the purpose for which we have Processed your data.

Personal Data with dropped out grounds for Processing shall be destroyed or anonymized in the respective order after the occurrence of this event.

XI. What are your rights regarding your Personal Data and how can you exercise them?

According to the data protection legislation, you have the following rights regarding your Personal Data:

Right of access: the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to receive access to your Personal Data, including information on the data source, the purposes of the Processing and its provision to Third parties, and to receive a copy of this Personal Data.

Right to rectification: when you believe that your Personal Data is inaccurate or incomplete, you may request from us the correction of this inaccurate personal data related to you, the completion of incomplete personal data related to you, taking into account the purposes of the Processing.

Right to erasure: You may request the erasure of your Personal Data when the conditions for doing so are met, to the extent permitted by law.

Right to restriction of Processing: you may request the restriction of the Processing of your personal data, to the extent permitted by law, and in the cases provided for in the Applicable legislation.

Right to object: you may object to the Processing of your Personal Data on grounds related to your particular situation. You have the absolute right to object to the Processing of your Personal Data for the purposes of direct marketing, which includes profiling related to such direct marketing.

Right to withdraw the consent: when you have given your consent for the Processing of your Personal Data, you have the right to withdraw it at any time, which withdrawal will have effect with regard to the Processing of Data in the future.

Right to data portability: to request that the data collected by us on grounds of given consent or on the basis of a contract be provided in a structured, commonly used and machine-readable format, insofar as they have been processed automatically.

You can exercise your rights by sending a written application or an application signed with a handwritten or electronic signature to the following address: Sofia 1766, Vitosha Municipality, 5 Panorama Sofia Street, fl. 3, or to the following e-mail: office@mbe.bg. You will receive a response to your request within 30 days, unless the request is excessive. In the latter case, we can extend the processing time of the application by up to two months. MBE will inform you of any such extension within one month of receiving the request, stating the reasons for the delay.

You will not pay a fee for the access to your Personal Data, nor for exercising of any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, recurring, or excessive.

As a security measure, we may have to ask you for specific information to help us verify your identity and guarantee your rights.

Right to lodge a complaint with a supervisory authority: you also have the right to lodge a complaint with the Commission for Personal Data Protection.

Contact with the Commission for Personal Data Protection

Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592

Tel: 02/91-53-518

E-mail: kzld@cpdp.bg

Website: www.cpdp.bg

We would be grateful if you would contact us first, in case of a complaint, in order to try to help you.

XII. Use of the Website by children

Our Website is not intended for persons under 18 years of age. If you are under the age of 18, you can use the site only with the consent of a parent or a guardian. In the event that a person under the age of 18 has provided his/her Personal Data without the consent of his/her parents and/or guardians, the latter should inform the MBE immediately. The site is not responsible if a person under the age of 18 has registered, hiding this fact.

XIII. Contact with us

If this Privacy Notice does not answer your questions or you need other information, or you have an inquiry, you can contact us directly at: Sofia 1766, Vitosha Municipality, 5 Panorama Sofia Street, fl. 3, e-mail: office@mbe.bg

XIV. Changes to this Privacy Notice

You must review this Privacy Notice from time to time, as MBE reserves the right to change it in whole or in part by posting a new version on our Website.

 

COOKIES POLICY

The purpose of this Cookies Policy is to inform the users about the use of so-called “cookies” on the website www.mbe.bg (the "Website").

I. What are cookies?

“Cookies” are small text files from a website that are stored by the browser on the hard disk of your computer, mobile phone or other device, hereinafter referred to as the "End Device", and which allow to store the flow of information between the Website and the browser. Cookies perform a number of functions that affect the convenience of browsing websites. Cookies generally contain information that is associated with the name of the website, from which they originated, with your web browser, information such as website preferences,  their storage time on the End Device and a unique number. This information enables the online services to recognise you as you interact with or revisit the Website.

II. What are cookies used for?

We use cookies when you interact with the services for a variety of reasons, as described herein below. The data provided by the user, or collected automatically, are used: 

  1. For system administration, to monitor traffic and prevent fraudulent activity;
  2. To provide normal and quality access to the services of the Website with all their functionalities, as well as of the basic functionality of the services such as creating and logging into your account and utilising essential features of the services;
  3. To improve the security of the services
  4. To check the availability of scripts, software applications and settings of the End Device of the user, necessary for the normal access and use of the services of the Website, and to inform you about the lack of such;
  5. To tell us whether you have visited the Website before and to make the services easier to use, including remembering your preferences and settings;
  6. To assess the performance of the services, to count visitors of the Website, and to monitor how users navigate and use the services, in order to improve the performance of, and content, offered through the services;
  7. For analysis, statistics, research and audit of the Website;
  8. For information about the devices accessing the Website: device type (e.g. smartphone, tablet, computer), operating system (e.g. Android, iOS), Internet browser, browser language settings, etc.
  9. We may use cookies to deliver customised content and marketing (marketing from MBE) based on how you interact with our services. We may also use cookies to record your use of our services, the pages you have visited and the links you have followed. We will use this information to make our services and the advertising displayed on them more relevant to your interests;

III. What type of cookies are used?

The website uses the following types of cookies as part of the services:

  1. Necessary – they help to make the Website usable by enabling basic functions like page navigation and access to secure areas of the Website. The Website cannot function properly without these cookies;
  2. Preferences – they enable the Website to remember information that changes the way the Website behaves or looks, like your preferred language or the region that you are in;
  3. Statistics – they help website owners to understand how visitors interact with websites by collecting and reporting information anonymously;
  4. Marketing – they are used to track visitors across websites. The intention is to display advertisements that are relevant for the individual user and thereby more valuable for publishers and third party advertisers;
  5. Session – they work only when you browse the pages of the Website, thus enabling their proper functioning, and are deleted from the memory of the End Device at the end of the session;
  6. Permanent – they remain on the End Device after visiting the Website, which means that the Website can remember the settings of the user when visiting the Website. This makes the Website easier for the user to navigate and remembers your preferences. These file types are stored in the user's End Device for the time specified in the cookie file parameters or until they are deleted by the user. Permanent cookies can be deleted through browser settings;

IV. How to deactivate or block cookies?

By default, the software used to browse websites allows you to store cookies on the End Device. Website users can change their cookies settings at any time. In order to block the automatic processing of cookies in the settings of the web browser or to inform about each of their transfer to the device of the user, appropriate changes must be made in the settings of the web browser. Detailed information about the possibilities and ways of working with cookies is available in the software settings (web browser). You can use the "Help" button on the menu of your browser for more details. You may revoke at any time the authorization granted and oppose to the use of cookies by selecting the appropriate settings on the your browser. Please, note that changing your browser settings, however, may cause limitations in the operation of the Website and the use of certain of its resources and functionalities.

V. What else do you need to know?

When using the Website by the user, part of the user’s data is collected automatically. This data includes: IP address, domain name, browser type, operating system type. This data may be collected through cookies on the Website and cookies for the following providers: Google Analytics, Facebook and may be stored in the server logs.

VI. By using the Website you agree to the placement of cookies on your computer/other End Device for the purposes set out in this Cookies Policy.

VII. If you have any questions regarding this Cookies Policy, please contact us on the following e-mail: office@mbe.bg

VIII. This Cookies Policy has been adopted and is effective from 29.05.2021.

  1. MBE Bulgaria OOD reserves the right to amend this Cookies Policy by publishing a new version on the Website. If you do not agree with the amendments which have been made, you should stop using the Website.