Last updated: June 21, 2025.
1. Introduction
This Privacy Policy describes how CLIMA 777 LTD (hereinafter referred to as "„The company“, „we“, „us“" or "„our“") collects, uses, stores and discloses your personal data when you visit and use the website balkanclima386.bg (hereinafter referred to as "„The site“") and its related online stores and services based on WordPress and WooCommerce. By accessing the Site and/or using our services, you acknowledge that you are aware of and accept the practices described herein.
This Policy has been prepared in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – „GDPR“") and Personal Data Protection Act (LPDP) of the Republic of Bulgaria.
2. Definitions
| Term | Meaning |
|---|---|
| Personal data | Any information relating to an identified or identifiable natural person. |
| Processing | Any operation or set of operations performed on personal data (collection, recording, storage, modification, disclosure, deletion, etc.). |
| Administrator | A natural or legal person who determines the purposes and means of the processing of personal data. |
| Processing | A person who processes personal data on behalf of the Administrator. |
3. Personal data administrator
- Name: CLIMA 777 LTD
- UIC: 207509984
- Headquarters and address of management: reg. Ruse, commune. Ruse, city of Ruse, p.k. 7000, Neofit Rilski St. 48 B
- Email: service@balkanclima386.bg
- Phone: +359 82 595 059
We have not appointed a Data Protection Officer (DPO). For all matters related to personal data, you can contact us using the above contact details.
4. Categories of personal data we process
4.1. Data provided by you
| Category | Examples | Purpose |
|---|---|---|
| Registration/Account Details | Names, email address, password | Create and manage an account |
| Contact details | Phone, delivery address, billing | Order processing and delivery |
| Order data | Ordered products, amounts, date, payment method | Completion of a contractual transaction, accounting purposes |
4.2. Data collected automatically
- IP address and device/browser logs;
- Cookies and similar technologies (detailed in § 8);
- Data about your behavior on the Site, collected through Google Analytics (e.g. pages you visit, session duration, traffic source).
4.3. Data generated by our systems
- Payment status history;
- Internal notes and correspondence related to customer service.
5. Purposes and legal basis for processing
| Purpose | Legal basis (Art. 6 GDPR) |
|---|---|
| Execution of a contract for sale, delivery of goods | b) Contract execution |
| Creating and maintaining a user account | b) |
| Invoicing and accounting records | c) Legal obligation |
| Traffic analysis, Site improvement | f) Legitimate interest (optimization of the service) + Your consent (via cookie banner) |
| Marketing communications and newsletters | a) Consent |
| Customer relationship management through CRM | f) Legitimate interest (improving service) |
6. Data retention period
- Order and invoice data is stored 10 years according to accounting legislation.
- User account data is kept as long as the account is active and 5 years after its closure in the absence of legal disputes.
- Google Analytics data is stored 26 months or according to the setting selected in the service.
- Data for marketing purposes is stored until consent is withdrawn.
7. Sharing of personal data and recipients
| Recipient | Role | Location | Guarantees |
|---|---|---|---|
| Hosting provider (EU-based) | Processing | EU | Confidentiality Agreement |
| Automattic Inc. (WordPress .com, WooCommerce) | Processing | USA | Standard Contractual Clauses (SCC) |
| Google LLC (Google Analytics) | Processing | USA | SCC + IP anonymization |
| Potential CRM platform (e.g. HubSpot/Zoho) | Processing | EU/US | SCC or equivalent mechanisms; will be updated upon selection |
| Courier and payment operators | Joint Controllers/Processors | EU | Contracts |
| State authorities (NRA, CPDP, etc.) | Addressees by law | Bulgaria | Legal jurisdiction |
We no we sell your personal data to third parties.
8. Cookies and analytical technologies
The site uses cookies to provide basic functionalities, analyze traffic and offer you personalized content.
8.1. Necessary cookies
They guarantee basic functions of the Site and cannot be turned off.
8.2. Functional cookies
They allow you to remember your preferences (language, currency, etc.).
8.3. Analytical cookies (Google Analytics 4)
They collect aggregated traffic data. IP addresses are masked before storage.
8.4. Marketing cookies
They are used with your consent to display personalized advertising.
Cookie management
On your first visit, you will see a banner asking you to accept or decline optional cookies. You can change your choice later in the Privacy Settings menu or through your browser settings.
9. Your rights
You have the following rights under GDPR:
- Right of access to your personal data;
- Right to rectification of inaccurate or incomplete data;
- Right to erasure ("right to be forgotten"), where the conditions of Article 17 GDPR are met;
- Right to restriction of processing;
- Right to portability of the data;
- Right to object against processing based on legitimate interest or for direct marketing;
- Right to withdraw consent at any time, without affecting the lawfulness of the processing up to the moment of withdrawal;
- Right to appeal to the Commission for Personal Data Protection (CPDP) – Sofia, 2 Prof. Tsvetan Lazarov Blvd., www.cpdp.bg.
To exercise your rights, please send a written request to the specified e-mail or by post to our address. We will respond to you without undue delay and at the latest within one month of receiving the request.
10. Security measures
- TLS encryption of the connection to the Site;
- Limited access to data on a need-to-know basis;
- Regular updates to WordPress, WooCommerce and plugins;
- Two-factor for administrator access;
- Malicious traffic detection systems and firewall (WAF);
- Backups stored in encrypted form.
11. Changes to the Policy
We may update this Policy periodically to reflect changes in the law or our services. In the event of significant changes, we will post a notice on the Site and/or notify you by email at least 7 days before they take effect.
12. Contacts
If you have any questions about this Policy or the way we process your personal data, please contact us:
- Email: service@balkanclima386.bg
- Phone: +359 82 595 059
- Postal address: 48 B Neofit Rilski Street, 7000 Ruse, Bulgaria
13. Entry into force
This Privacy Policy is effective from June 21, 2025. and replaces all previous versions.
