1.1. We are committed to safeguarding the privacy of all customers and visitors of our gallery and online shop (EvitaWorks).
1.2. This policy applies where we are acting as a data controller with respect to the personal data of our customers and visitors; in other words, where we determine the purposes and means of the processing of that personal data.
1.4. In this policy, “we”, “us” and “our” refer to EvitaWorks Art Studio. (For more information, see Section 10.)
2.1. This document was created referring upon GDPR-compliant guidelines published at SEQ Legal.
3. How we use your personal data
3.1. In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2. We monitor and may process visitor’s and customer’s data (“usage data“). The usage data may include many public vectors (e.g. your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of most of the usage data is google analytics.
3.3. We may process your account data (“account data“). The account data may include your name, email and mail address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
3.4. We may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data“). The inquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.
3.5. We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers.
3.6. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your (partial) card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
3.7. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters.
3.8. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.9. The legal basis for the processing of all the above paragraphs of this Section 3 is in our legitimate interests, namely the proper administration of our website and business, the proper protection of our business against risks , and for the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4. Providing your personal data to others
4.1. We may disclose your name, email address and mail address to 3rd party service providers, for the sole purpose of delivering purchased goods to you and to better manage correspondence with you.
4.2. Financial transactions relating to our website and services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.3. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. International transfers of your personal data
5.1. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2. The hosting facilities for our website are currently situated within the boundaries of the European Union. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of the partaking countries.
6. Retaining and deleting personal data
6.1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3. We will retain your personal data as follows:
(a) personal data will be retained for a minimum period of 3 years, and for a maximum period of 5 years following a registration, or purchase.
6.4. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1. We may update this policy from time to time by publishing a new version on our website.
7.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1. In this Section 8, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2. Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
8.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
8.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10. To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13. You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
9. About cookies
9.1. A cookie is a small simple file that is sent along with pages of this website and stored by your browser on the hard drive of your computer or another device. The information stored therein may be returned to our servers or to the servers of the relevant third parties during a subsequent visit. Some (functional) cookies ensure that certain parts of the website work properly and that your user preferences remain known. Other (analytical) cookies are used to improve our services over a given period of time. With these analytical cookies we get insights in the usage of our website.
9.2. Our website has also included buttons for Facebook, Pinterest, Twitter, and others, to aid our visitors in their willingness to share specific web pages on their respective social networks (e.g. “like”, “pin”, “tweet”). These buttons work with code directly managed by these networks, and place (3rd-party) cookies. These social media buttons also can store and process certain information, so a personalized advertisement may be shown to you within their respective networks. Please read the privacy statement of these social networks (which can change regularly) to read what they do with your (personal) data, which they process using these (3rd-party) cookies.
10. Our details
10.1. This website is owned and operated by EvitaWorks – the trade name of Eva & Alex Campbell.
10.2. We are registered in Bulgaria (EU) as freelancers.
10.3. To get in touch with us, please visit our contact page.
11. Data protection officer
11.1. Please write to: moc.skrowative@nimda