Last updated: 25th May 2018.
A. INTRODUCTION
A.1. What is a privacy policy?
The privacy policy is divided into four parts:
Part A – Introductory Information;
Part B – Information on how your personal data is processed.
Part C – Information about your rights in relation to the processing of your personal data;
Part D – Information on the use of so-called cookie files.
Vision Care respects all data provided both actively and passively by the persons visiting the website, that is, website users (“Users”) and customers, and ensures that the data is properly protected.
A.2. Contacting us
You can contact Vision Care using the Contact form or by using the following contact details:
Email: visioncare.varna@gmail.com
Phone: 052-636-653
Traditional mail or personal transmission of written documents at 51, Vladislav Varnenchik Blvd. Varna 9000 with the note “PERSONAL DATA”
A.3. Changes to the privacy policy
Vision Care may make changes to this privacy policy at any time by informing users and customers. This is by publishing the updated version of the website’s privacy policy, informing customers by sending the updated version of the privacy policy to their emails, or publishing relevant information directly to customer profiles if customers have such.
In this regard, we encourage customers and users to regularly check the current version of the privacy policy. If the user / client does not accept the changes to the privacy policy, he / she must stop using the website.
A.4. Definitions
The terms used in this privacy policy should be understood as follows:
Personal Information – These are all information concerning the identified individual or the ability to identify it.
Identifiable person – This is a person whose identity can be determined directly or indirectly, eg. by an identification number or a factor defining its physical, physiological, mental, economic, cultural or societal characteristics.
Processing of personal data – This is any operation with personal data, incl. collection, storage, processing, modification, assignment, deletion, copying.
Personal Data Administrator – It is an entity that defines the purposes and means of processing personal data and is responsible for its processing in accordance with the law.
Concepts such as a client, a salon, a visit, an Internet platform, and others used in this privacy policy are defined in the rules.
A.5. Legal Provisions Regarding Confidentiality
The manner in which your personal data is processed – in addition to the policies and policies adopted by Vision Care – is also determined by legal provisions, such as Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation), the so called- GDPR (General Data Protection Regulation)
These rules regulate your rights relating to personal data and Vision Care’s legal obligations relating to the processing of your personal data.
B. YOUR PERSONAL DATA
B.1 Who is the administrator of your personal information
Vision CARE LTD, with headquarters in Varna, Podvis Street 32 ent. C is the administrator of your personal data collected through this website or in connection with services provided under the rules.
B.2. What data is being processed?
Vision Care collects and processes personal data on:
Website users and customers; and to those customers who order products or services, e.g. visit (for the purposes of this policy, such persons are perceived as clients).
Vision Care can collect and process data incl. and during:
Booking visits to our optics;
Sending a message via the site’s contact form
Sending feedback about our services via the form on the reviews page;
Submitting complaints or inquiries about products and services provided by Vision Care.
To the personal data collected and processed by Vision Care are attributed:
Contact details – name, surname, email address, mobile phone number;
Address data – place of residence address;
Age verification credentials (e.g., in a written post)
Visiting data – the date, time and place of the visit;
B.3. Is it obligatory to provide your personal data?
Providing data is voluntary, however, if data are not provided that are needed, for example, to book a time for a visit or to provide answers to inquiries and complaints, this may hinder or block Vision Care’s actions or fail to meet the expectations of the client or user.
B.4. For what purpose and on what basis are my data processed?
Your data will be processed in accordance with the following legal bases:
| Legal grounds for processing [General Data Protection Regulation] | Purpose of the processing | Description of the legal grounds for the processing |
| Implementation of the contract [Art. 6.1 (b) General Data Protection Regulation] |
Customer personal data can be processed by Vision Care to provide Vision Care services ordered by the customer in accordance with the rules, such as creating an individual account, ordering products and services via the internet platform, and booking visits. For the above-mentioned purpose, Vision Care can send to the customer’s email address and telephone number, for example, information about the next stages of ordering on the Internet platform, reminders of dates of visits to saloons, etc. |
Data processing for the purpose of rendering services provided by Vision Care ordered by the customer in accordance with the rules is legal, as it is necessary for the execution of the contract with the client, such as the provision of a service.
As part of the features available in the account, the customer may have access, for example, to research history, prescriptions, purchases, and medical examinations. |
| Legal duties Vision Care [Art. 6.1 (c) General Data Protection Regulation] |
Customers and users’ personal data can be processed to respond to complaints about the website, the internet platform, and the products. | Data processing is legal as it is necessary for purposes arising from the applicable legal provisions (eg the Consumer Rights Act or the Civil Code). |
| a legally regulated interest of Vision Care [Art. 6.1 (f) General Data Protection Regulation] |
The user’s personal data (for example, if they have purchased a newsletter) and customers can be processed by Vision Care and for marketing of Vision Care products and services.
Customers and Users’ personal data can also be processed to respond to queries, complaints and doubts about the website, the internet platform, and the products. |
The processing of data for these purposes is lawful, as it is necessary for the legitimate interests pursued by Vision Care.
Legitimate interest in Vision Care is the processing of customer and user data to market Vision Care products and services. Legitimate interest of Vision Care is also the need to respond to customer and user inquiries and to investigate complaints. |
| your agreement [Art. 6.1 (a) General Data Protection Regulation] |
The user (e.g., through the website) and the customer (e.g., during the registration of an individual account) may agree to receive commercial information via e-mail, e.g. newsletter and direct phone marketing. | Consent is not a prerequisite for the use of Vision Care services.
Consent can be withdrawn at any time, for example through account settings in the account panel or by clicking on the link contained in the email you received and containing the marketing content. Withdrawal of consent does not affect the processing (or compliance of this processing with the law) before withdrawal of consent (for example, provision of commercial information and telephone marketing made prior to its withdrawal). |
B.5. How long are my data stored?
Your data will be stored for the following periods:
| Legal basis for processing | Period of processing of personal data |
| performance of the contract | Customer and user personal data will be retained as long as it is necessary to use it for the operation of the individual account, to provide services and to prepare a response to a query or claim but no longer than: (i) the time to delete the account or(ii) examination of the claim or(iii) the submission of complaints. |
| legal duties of Vision Care | In some cases, legal provisions impose an obligation to retain personal data for a longer period (e.g., tax law provisions). In this case, your personal data will be stored for this period in accordance with the law. |
| your agreement | Your data will be processed until you voluntarily withdraw your consent. |
| a legally regulated interest of Vision Care | Your data will be processed until you clearly object to processing. |
B.6. Where are my data being processed?
Customer and consumer personal data are processed and stored in the European Economic Area.
B.7. To whom is my data being provided?
In order to provide services ordered in accordance with the Regulations, personal data of customers may be transferred to third parties executing orders, such as courier companies, as well as entities that cooperate with Vision Care, for example, performing medical examinations, prescriptions and other services , ordered by the customer.
B.8. Are automatically made decisions that concern me directly based on my personal data?
Customer personal data is not used for decision-making that is based solely on automated processing, including profiling, has legal effects on customers, or directly affects them.
C. YOUR RIGHTS
When the legal provisions provide for this, the customer and the user have certain personal data rights described in detail below.
C.1. How can I exercise my rights?
You can address a specific application to us by using the contact details in the Contact form. Once your application has been accepted and after a possible verification of your identity, we will take appropriate action related to it.
According to the rules, you will receive a response from us as soon as possible but (as a general rule) no later than one month. In a situation where your application is extremely complex or your desire to do many tasks at the same time, this deadline may be extended for a maximum of two months. In this case, you will be informed of this extension of the response time.
The answers to your questions and the communication with you and our activities related to your applications are (in principle) free of charge.
C.2. Right of access
You have access to your personal data. You can contact Vision Care with questions about:
confirmation that we process your personal data;
the purposes of processing your personal information;
the category of your personal data;
information about recipients of your personal data;
information about the planned storage period of your personal data (or the criteria for its determination);
information about your rights relating to your personal information;
information on the sources of your personal data in situations where it was not personally taken by you;
information on automated decision-making based on the processing of your personal data, including their profiling.
You may also ask us for a copy of the processed personal data. Issuance of subsequent copies of the status of personal data may be paid.
C.3. Rights related to data processing
In relation to the processing of your personal data you have the following rights:
| Your rights | Description of your rights |
| right to correct the data | You have the right to ask for your personal data to be corrected if they are incorrect or incomplete. In case of incomplete data, you have the right to request their completion and you can provide Vision Care with the relevant application. |
| right to restrict the processing | You may request “blocking” your personal data in some cases, including in the event that:
“Blocking” your data is that Vision Care will continue to store your personal data, but we will not be able to process it in any other way except in special situations (for example, when there is an important public need). |
| right to transfer data | You have the right to request your personal data from Vision Care in a structured, commonly used format accessible for machine readability. You may send this data to another data administrator. You also have the right to ask Vision Care to transfer this data to another data administrator if technically possible.
The right to transfer personal data only applies to situations where it is processed:
|
| right to delete data (the so-called right to be forgotten) |
You may request the deletion of your personal data in some cases, including when:
Your right to ask for the deletion of your personal data may be limited in some cases, including when processing is necessary to meet Vision Care’s legal obligations (eg in line with accounting obligations). |
C.4. Right of withdrawal
You have the right to withdraw your consent at any time by clicking on the link in the email you received and which has commercial content. To withdraw your consent, you can also contact us through our contact details on the Contact tab.
Attention! Withdrawal of consent may result in Vision Care being unable to provide you with services based on your consent.
Withdrawal of consent does not affect the lawfulness of the processing that was carried out before its withdrawal.
C.5. Right of objection
You have a right to object to the processing of your personal data if such processing is based on the legitimate interest of Vision Care (more information on the notion of legitimate interest in point B.4.))
You can raise objections for reasons specific to the situation. In the event of a statement of objection concerning:
the processing of personal data for direct marketing purposes – Vision Care will not be able to process your personal data;
the processing of personal data for other purposes – Vision Care will not be able to process your personal data unless there are legitimate and lawful grounds for processing that dominate your interests, rights and freedoms or reasons for formulating, investigating or protecting your claims.
The right to raise objections concerns only the processing of personal data based on the legitimate interest of Vision Care and does not affect the processing of your personal data on the basis of performance of the contract, your consent or any other legal basis (more information on the legal grounds for processing in point B.4.).
C.6. Right to lodge a complaint
You have the right to lodge a complaint to the supervisory authority.
At present (May 2018) a new law on personal data protection is being worked out. The bill provides for the replacement with a new supervisory body – chairman of the Office for Personal Data Protection. In this case, you will be able to exercise your right to file a complaint with the President of the Personal Data Protection Service (if such a body is established).
D. Cookie Files
D.1. What are cookies?
Cookies are electronic (IT) data, especially text files, which are stored on the website end user’s device and client and are designed to facilitate the use of the relevant elements of the website. Cookies usually contain the name of the website they come from, the storage time on the end device and a unique number.
The website uses two basic types of cookies: session cookies and persistent cookies. Session cookies are temporary files that are stored on the user’s device until leaving the website, or shutting down the software (browser). Permanent cookies are stored on the end user and client device for the time specified in the cookie file parameters or until they are deleted by the user and the customer.
D.2. For what purpose does the website use cookies?
Vision Care uses cookies for the following purposes:
Adapt the content of website pages to user and customer preferences and optimize the use of websites; in particular, these files allow the device of the user and the customer to be recognized and the website be properly displayed, tailored to its individual needs;
Creating statistics that help understand how website users and customers use websites to improve their structure and content;
D.3. What cookies does the website use?
Vision Care uses the following cookies:
1 WordPress Stats (Automattic Inc.) – Wordpress Stats is an analytics service provided by Automattic Inc. Personal Data collected: Cookies and Usage Data.
Place of processing: Privacy Policy.
2 Google Analytics (Google Inc.) – Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Vision Care, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data Place of processing: Privacy Policy – Opt Out.
3 Yandex Metrica – By default, Yandex.Metrica collects information about all users who visit a site.
Collecting data about individual users can be blocked with the Yandex. Metrica opt-out browser add-on that is available for the most popular desktop browsers.
4 Google Tag Management – This type of service helps the Owner to manage the tags or scripts needed on Vision Care in a centralized fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data collected: Cookies and Usage Data.
Place of processing: – Privacy Policy.
D.4. How can I manage my consent to using cookies?
The software used to browse webpages (browser), by default, allows the storage of cookies on the user and customer device. Website users and customers can change their cookie settings at any time. These settings can be changed in such a way as to block automatic cookie handling in browser settings or to keep track of each entry in the device on the website and the customer. Detailed information on how cookies work and how they work can be found in the software settings (browser).
Attention! Withdrawing your consent to the use of cookies may mean limiting some of the features of the website.