Data administrator

DOBROGLED 8 OOD is a company registered in the Commercial Register of the Registry Agency with UIC 175460145, with registered office and address of management: Varna, 3 Yanko Karagyaurov Str., Tel: +359 896 802864; email: [email protected]

Information for contacts with DOBROGLED 8 Ltd. regarding the protection of the personal data of our clients, contractors and partners:


3 Yanko Karagyaurov Street

[email protected]

tel: +359 896 802864

Data protection officer:

  1. Zhekov

This policy explains our privacy practices for (which we will call the “Site”), the goods and services we provide (which we will call the “Services”).

It is extremely important that the information we store for you is accurate and up to date. Please let us know if there is a change in your personal information at any time in order to update your personal information in your profile.

The Terms of Use require all account holders to be 18 years of age or older. Minors under the age of 18 and at least 16 can use the services of only if they have the appropriate permission and direct supervision from the account owner. Children under the age of 16 are not allowed to use or our Services. You are responsible for any account activity performed by a minor in your account.

Please note – by providing your personal data, you confirm that you are at least 18 years old. If this is not the case, you should contact us immediately to take action to delete them.

By using the Services, you confirm that will use your information in Bulgaria and any other country where operates or could operate. Please note that privacy laws and standards in some countries, including the rights of authorities to have access to your personal information, may differ from those applicable in your country of residence. We will only transfer personal information to those countries where we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information continues to enjoy adequate protection.

 Our main aspiration when working with personal data


It is important that you read this privacy statement together with any other privacy notice or fair processing of personal data that may provide on specific occasions when collecting or processing personal data about you, so that you are fully aware of how and why we use your data? This privacy notice complements the Terms and Conditions and is not intended to override them. processes your personal data in order to provide you with better, better services and solutions related to the General Regulation on Personal Data Protection in the European Union (GDPR) and information security. In view of this goal, has built a network of strategic partnerships, which strives to meet all your needs when using our services.

The security of the data you entrust to us is very important to us. It is very important for the success of our business and for our public image. That is why we protect your data by applying all appropriate technical and organizational means at our disposal to prevent unauthorized access, unauthorized or malicious use, loss or premature deletion of information.

We collect and process personal data only in compliance with the requirements of local and European legislation. We are aware that the processing of your data is for a specific reason and cannot be performed without restriction.

This Privacy Policy is intended to explain to you how and why we process your personal data.

If you do not wish to collect or process your personal information in the ways described in this policy, you must not use our Services.

We are not responsible for the content or privacy policies or practices of our suppliers (their policies are described on their respective pages, such as Providers of Goods or Services), third party websites or third-party applications.

What data we collect, how and why we use your personal data

In the process of providing our services, we collect or receive your personal information in several different ways. You often choose what information to provide, but sometimes we require certain information that we need to provide you with our Services.

To perform a contract or in the context of a pre-contractual relationship (Registration, Account Setup, Services)

We process your identification data and other personal data in order to provide the products and services that you have requested and that you use with us, as well as to fulfill our contractual commitments both to you and to third parties (customer-platform-supplier; provider- client platform).

The processing is performed in order to:

  • establishing the identity of the client through all trade channels;
  • management and execution of your requests for products or services, execution of contracts for products and services;
  • prepared on a proposal for concluding a contract;
  • preparing and sending an invoice for the products and / or services you use with us;
  • to provide you with the necessary comprehensive service, as well as to collect the amounts due for the used products and services;
  • with a view to providing and providing quality services, as agreed;
  • notification of everything related to the products and services you use with us, sending various notifications, notification of problems, errors or to respond to your requests, complaints, suggestions;
  • preparation of aggregate statistical information about our sales and services, which we can provide to third parties, etc.;
  • analysis of the customer history and preparation of a user profile in order to determine a suitable offer for you;
  • protect and ensure the security and integrity of you and our employees;
  • identify and / or prevent illegal actions or actions contrary to our terms of service;
  • processing by the data processor at the conclusion of a contract, assignment, reporting, acceptance, payment;

As a provider of, may request information such as the full name of the company and its representative, address, identification number and / or tax number, date of birth, bank account information, photo, credit information card and / or other proof of identification to verify your identity in order to provide this service to you and to comply with applicable law.

We may need to store credit card information (or arrange for it to be stored) and use it for both billing and payment purposes. Depending on your local jurisdiction, you may choose to allow us to retain your credit card information to facilitate the process of future purchases. may contact individual suppliers confidentially to request more information about their items listed through the Services, or to ensure compliance with our policies and applicable laws.

To use certain Services in, you may need to fill out an application; The information you submit through the application process will not be publicly displayed and will only be used by internally, unless otherwise stated, you may also choose to allow us to retain your credit card information to facilitate the payment process for future purchases.

The name associated with your account, which you can view and change in your account settings, is displayed publicly and is associated with your activity. Other users can see the date you joined; ratings, reviews and related photos for goods you have bought or sold; information about your account; items you have specified for sale; the pages and rules of your store; your loved ones, followers and those you follow; lists of items sold and number of items sold; comments that you post in our spaces; and information you choose to share through social media.

Information for non-member visitors: may receive or receive information (eg email address or IP address) about a person who is not yet a registered member of (“non-member”) in connection with certain features, for example when a non-member chooses to subscribe to the newsletter, a member invites a non-member to visit the Site, no member a participant in a transaction when making a purchase through any of the Services. The information we obtain from a non-member is used only for the purposes for which the non-member has decided to use the Site, as well as for the purposes necessary for the operation of the services of or when has a legitimate interest, such as disclosed in the relevant section below.

 To fulfil regulatory obligations

We process your identification data and other personal data in order to comply with obligations stipulated in a regulatory act, such as:

  • fulfilment of obligations in connection with the distance selling, the sale outside the commercial site, provided for in the Consumer Protection Act;
  • providing information to the Consumer Protection Commission or third parties provided for in the Consumer Protection Act;
  • providing information to the Commission for Personal Data Protection in connection with obligations provided for in the legislation on personal data protection – Personal Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016, etc.;
  • obligations provided for in the Accounting Act and the Tax and Social Security Procedure Code and other related regulations in connection with the maintenance of proper and lawful accounting;
  • providing information to the court and third parties, within the proceedings before a court, in accordance with the requirements of the procedural and substantive legal regulations applicable to the proceedings;

 After your consent

In some cases, we process your personal data only with your prior written consent. Consent is a separate basis for the processing of your personal data and the purpose of the processing is stated in it, and is not covered by the purposes listed in this policy. If you give us the relevant consent and until its withdrawal or termination of any contractual relationship with you:

  • we prepare suitable for you offers for products / services of com, performing detailed analyses of your basic personal and company data;
  • Proposals for products / services are prepared for you by the company’s partners, as we process your basic personal and company data.
  • Basic personal data include names, PIN number, gender and age group, telephone number, address (permanent address)
  • Company data include company name, company email address (es), telephone number, company address.

Detailed analysis is a method of performing analysis that allows the processing of large volumes of data using statistical models and algorithms and others, which include the use of network and personal data, as well as processes of pseudonymization and anonymization of the same, in order to extract information about trends and various statistical indicators.

Partners are companies with which has concluded partnership agreements and which provide a variety of products and services.

Concessions granted may be withdrawn at any time.


Withdrawal of consent does not affect the performance of’s contractual obligations. If you withdraw your consent to the processing of personal data in any or all of the ways described above, will not use your personal data and information for the purposes set out above. Withdrawal of consent shall be without prejudice to the lawfulness of the processing based on a consent prior to its withdrawal.

We have a large portfolio of products and services. When you give us consent to data processing, that consent applies to all products and services you use.

To withdraw your consent, you only need to use our site or just our contact information.

We know that members value control over their own information, so gives you the choice to provide, edit or remove certain information, as well as your choice of how to contact you. You can change or adjust your account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request the deletion of personal information in your account. Click here to learn how to close your account.

Many of the changes you make to your account settings are updated immediately, but for some it may take several days for them to take effect, especially those that affect email or marketing preferences. Some basic requests, such as changes to billing information or deleting account data, may require authentication before they can be processed. may need to contact you during its normal operation. Basically, these messages are delivered by email, including for marketing, transactions and service updates. If you no longer wish to receive notifications, you can disable them at the device level. You can opt out of receiving marketing communications via email or by following the unsubscribe link in any marketing email you receive. To ensure proper notifications, we will need to collect certain information about your device, such as operating system information and user identification. Each account is required to maintain a valid email address in their account in order to receive these messages. may also contact you by telephone to provide the necessary support or upon your request related to a transaction for the Services you wish to use. With your consent, may send you an SMS (or similar) message to provide you with guaranteed customer contract support or to provide you with information about products and Services that you may find interesting. You can update your contact preferences in your account settings.

Some messages from are related to the service and are necessary for users. You agree that may send you non-marketing emails, calls or messages, such as those related to transactions, your account, security or changes to products and Services. Examples of service-related messages include a confirmation email / welcome greeting when you register your account, order notification, service availability, change of key features, retransmission of conversations with buyers / suppliers, and correspondence with support.

In view of our legitimate interest


We use your identification data (excluding PIN) to perform a basic analysis of your data in order to adapt the services we offer to your individual needs and to offer you new services to meet them.


Processing of anonymized data


We process your data for static purposes, i.e., for analyses in which the results are only summary and therefore the data is anonymous – for example, to represent the movement of large groups of people. It is not possible to identify a specific person or company from this information.


What data we process


identification data:

  • Identity data includes name, surname, username or similar identifier, title, date of birth
  • Contact details include billing address, delivery address, email address and phone numbers.
  • Financial data includes bank account and payment card details.
  • Transaction details include details of payments to and from you and other details of products and services you have purchased from us.
  • Technical data includes [Internet Protocol (IP) address, login information, browser type and version, time zone and location setting, browser types and versions, operating system and platform, and other technologies of the devices you use to access our site].
  • Account information includes your username and password, as well as your purchases or orders.
  • Marketing and communications data includes your preferences for receiving marketing from us and third parties and your preferences for communication.

Other data:

information on the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including:

  • e-mail, letters, information about your requests for troubleshooting, complaints, requests, grievances;
  • other feedback we receive from you;
  • personal contact details – contact address, telephone number and contact information (email, telephone number), gender, age group;
  • preferences for the services we provide to you;

other information such as:

  • customer number, code or other identifier created by com to identify companies and users;
  • data provided through the company’s website;
  • other personal data provided by you or by a third party at the time of concluding or during the validity of a contract with com, in particular: the three names, a unique civil number or a personal number of a foreigner, a permanent address of a proxy specified in a document, in who you have authorized him to represent them; social network profile data, contact details, contact person; username, data provided when participating in games, raffles and / or other seasonal or promotional campaigns organized by, including through social networks.

When we process your basic personal data, and the other data described for the purposes of providing products and services, for their payment, for the fulfilment of your requests for services, as well as in order to fulfil our regulatory obligations, this processing is mandatory for the fulfilment of these goals. Without this data, we would not be able to provide the relevant services. If you do not provide us with credentials, we will not be able to enter into a product or service agreement with you.

We respect your privacy. will not disclose your name, email address or other personal information to third parties without your consent, except as provided in this policy.


Confidential data

We do not collect any confidential information about you. Confidential are data related to your race or ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political views, trade union membership, information about your health, genetic and biometric data. We do not collect information on criminal convictions and crimes.

Please note – when we are required to collect personal data by law or under the terms of the contract between us and you do not provide this data upon request, we may be unable to perform the contract (for example, to supply you with goods or services). If you do not provide us with the requested information, we may need to cancel the product you ordered, but if we do, we will notify you in a timely manner.

We will use your personal data only for the purpose for which it was collected or, if necessary, for a purpose close in meaning to the main one. In the event that we need to use your data for an unrelated new purpose, we will notify you, setting out the legal reasons for our actions.

We may process your personal data without your knowledge or consent, but only to the extent permitted by law. We do not perform automated decision making or automated profiling.


Why and how we use automated algorithms

For the processing of your personal data, we use partially automated algorithms and methods in order to constantly improve our products and services, to make it more personal to you, to adapt our products and services to your needs in the best possible way or to calculation. This process is called profiling.


How is your personal data collected?

We use a variety of methods to collect data from and about you, including through:

Direct interactions. You can give us your Identity, Contact and Financial Data by filling out forms or by sending us by mail, telephone, email or otherwise. This includes personal information that you provide when:

  • request our products or services;
  • contact us by phone, through our website or otherwise;
  • create an account on our site;
  • subscribe to our services or publications;
  • request to be included in our marketing newsletter;
  • send us feedback on our products.


Automated technologies or interactions

While interacting with our site, we may automatically collect Technical Data on your equipment, actions and browsing patterns. We collect this personal information using cookies, server logs and other similar technologies. We may also obtain Technical Data for you if you visit other websites using our cookies. Please see our cookie policy for more details.


Third parties or publicly available sources

We may obtain personal information about you from various third parties as set out below:

Technical data from the following countries:

  • analytics service providers such as Google and Facebook;
  • advertising networks; and
  • providers of search information.
  • Contact details, financial and transactions from technical, payment and delivery service providers

We rely on consent (which may be withdrawn at any time) to send marketing messages and to share third-party advertising. As part of this, we may work with advertising partners such as Facebook or Google, and we may use analytics data aggregated from usage information, including, for example, search keywords, favourites, browsing history, and purchase history. In addition to consent, as noted above, we also rely on our legitimate interest in sending you marketing communications for advertising programs. must also engage third parties and companies (such as payment processors, consumer behaviour analysis companies, analysts and information security professionals) to enable us to operate, provide and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are required by not to disclose or use your information for other purposes. It is often necessary to fulfil our contractual commitment to provide you with the Services you have paid for, to use the Services of third parties, service providers, especially in cases where such companies play an important role such as payment processing and delivery of shipments. and help us maintain and protect our Service. In some other cases, we do not strictly need these service providers to provide the Services, but they help us to improve them by helping us to conduct research that helps us to improve the service to our customers. In these latter cases, we have a legitimate interest in working with service providers to improve our Services.

Business reorganization: In some cases, may choose to buy or sell assets. Such transactions may also be necessary in our legitimate interests, in particular our interest in making decisions that enable our business to grow in the long run. In these types of transactions (such as the sale, merger, liquidation, acquisition or transfer of all or substantially all of’s assets), consumer information is usually one of the transferred business assets. If intends to transfer information about you, will notify you by email or by posting a prominent notice on the site and application and you will be given the opportunity to opt out before the information about you becomes subject to another privacy policy.


Third party plugins may also collect information about your use of the Site. For example, when you load a page on that has a social plugin from a third-party site or service, such as a Like or Submit button, you also load content from that third-party site. This site may request cookies directly from your browser. These interactions are subject to the privacy policy of the third-party site. In addition, certain cookies and other similar technologies on the Site are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognize your computer or mobile device each time you use the Services. Please note that when you use third party sites or services, their own terms and privacy policies will govern the use of those sites or services. selects and manages these third-party technologies placed on its sites and applications. However, these are third party technologies and are subject to that third party’s privacy policy. For more information, see our Cookie Policy. We rely on your consent to allow and accept these cookies when they are not technically necessary or when they are not required for any other purpose, such as a legitimate interest.

This policy does not apply to the practices of third parties (such as Providers who sell through the Services) that does not own or control, or persons that does not use or manage, unless otherwise provided in the General Terms and Conditions. Conditions or as required by law. If you provide your information to such third parties in connection with the use of the Services, different practices may apply to the use or disclosure of the information you provide to them. Although requires these third parties to comply with the privacy and security requirements of, does not control the privacy or security policies of such third parties. To the fullest extent applicable in your jurisdiction, is not responsible for the privacy or security practices of such vendors or other websites on the Internet, even those related to or from the Services. We encourage you to read the privacy policy and ask questions of third parties before disclosing your personal information about them. For the purposes of European law, these vendors, third party providers and API users are independent data controllers, which means that they are responsible for providing and complying with their own policies related to any personal information they receive in connection with the Services.

How we use your personal information


We will only use your personal data when the law allows it. We will most often use your personal data in the following circumstances:

  • Where we have to fulfil the contract that we are about to enter into or we have concluded with you.
  • Where necessary for our legitimate interests (or the interests of a third party) and your interests and fundamental rights do not disregard those interests.
  • Where we have to fulfil a legal or regulatory obligation.

In general, we do not rely on consent as a legal basis for the processing of your personal data, except in connection with sending a third direct marketing communication to you via email or text message. You have the right to withdraw your marketing consent at any time by contacting us.


Purposes for which we will use your personal data

Below we have provided, in tabular form, a description of all the ways in which we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Purpose/Activity Type of data Legal basis for processing, including grounds for legitimate interest
To register you as a new client а) Identity
б) Contact
Execution of a contract with you
To process and deliver your order, including:
(a) Management of payments, fees and charges
(b) Collection and refund of money due to us
(a) Identity
(b) Contact
(c) Financial
(d) Transactions
(e) Marketing and communications
(a) Execution of a contract with you
(b) Necessary for our legitimate interests (to recover our debts)
To manage our relationship with you, which will include:
(a) Notification of changes to our terms or privacy policy
(b) Sending a review or conducting a study
a) Identity
b) Contact
in profile
d) Marketing and communications
(a) Execution of a contract with you
(b) It is necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our documents up to date and to investigate how customers use our products / services)
Administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, data maintenance, reporting and hosting) a) Identity
b) Contact
c) Technically
a) Necessary for our legitimate interests (for the conduct of our business, the provision of administrative and IT services, network security, fraud prevention and in the context of business reorganization or group restructuring)
(b) Necessary to comply with a legal obligation
To provide you with relevant content and ads on the website and to measure or understand the effectiveness of the ad we offer you (a) Identity
(b) Contact
(in profile
(d) Use
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to develop our business and to inform our marketing strategy)
Use data analytics to improve our site, products / services, marketing, customer relations and experience a) Technically
b) Use
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our site up-to-date and up-to-date, to develop our business and to inform about our marketing strategy)
Make suggestions and recommendations for goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technically
(d) Use
(e) Profile
Necessary for our legitimate interests (to develop our products / services and to develop our business)

Please note that we may process your personal data on more than one legal basis depending on the specific purpose for which we use your data. Please contact us if you need details of the specific legal basis, we rely on to process your personal data when more than one reason is listed in the table below.

How we protect your personal data


To ensure adequate data protection of the company and its customers, we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act, as well as best practices of international standards (ISO 27001: 2013, etc.).

The company has established processes to prevent abuse and security breaches. In order to ensure maximum security in the processing, transmission and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc. encrypts certain information (such as credit card numbers) using TLS (Transport Layer Security). follows generally accepted industry standards to protect the personal information provided to us both during and after transmission. Unfortunately, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, as long as we strive to protect your personal information, we cannot guarantee its absolute security. offers advanced additional security features and settings for members, such as two-factor authentication for logging in and logging in to history and notifications; you can see more information in your account settings.

 When we delete your personal data


As a rule, we terminate the use of your personal data for contractual purposes after the termination of the contract, but we do not delete them before the expiration of one year from the termination of the contract or until the final settlement of all financial obligations and expiration of statutory obligations. for data storage, such as obligations under the Accounting Act for storage and processing of accounting data (50 years), expiration of the statute of limitations for filing claims (10 years) specified in the Obligations and Contracts Act, obligations for providing information to the court , competent state authorities, etc. grounds provided for in the current legislation (10 years). Please note that we will not delete or anonymize your personal data if it is necessary for pending court, administrative or pending proceedings before us.

Your data can also be anonymized. Anonymization is an alternative to deleting data. Upon anonymization, all personally identifiable items that allow you to identify yourself are permanently deleted. There is no legal obligation for anonymized data to be deleted, as they do not constitute personal data.


Your rights in connection with the processing of your personal data:


  1. Right to information You have the right to request:
  • information on whether data relating to you are processed, information on the purposes of such processing, on the categories of data and on the recipients or categories of recipients to whom the data are disclosed;
  • a message in an understandable form containing your personal data that is being processed, as well as any available information about their source;
  • information on the logic of any automated processing of personal data concerning you, at least in the case of automated decisions.
  1. Right of access:
  • The right of access, commonly referred to as “access to the topic”, entitles individuals to receive a copy of their personal data as well as other additional information. It helps people understand how and why you use your data and check if you are doing it legally.
  1. Right of correction:

In the event that we process incomplete or erroneous / erroneous data, you have the right, at any time, to request:

  • to delete, correct or block your personal data, the processing of which does not meet the requirements of the law;
  • notify third parties to whom his personal data have been disclosed of any deletion, correction or blocking, except where this is not possible or involves excessive effort.
  1. Right of deletion:
  • According to Article 17 of the GDPR, individuals have the right to delete their personal data. This is also known as the “right to be forgotten”. The law is not absolute and applies only in certain circumstances.
  1. Right of objection:

At any time you have the right to:

  • objections to the processing of your personal data if there is a legal basis for it; where the objection is justified, the personal data of the natural person concerned may no longer be processed;
  • object to the processing of your personal data for direct marketing purposes.
  1. Right to limit processing:

You can request a restriction on the personalized data being processed if:

  • you dispute the accuracy of the data, for the period in which we have to check their accuracy; or
  • the processing of the data has no legal basis, but instead of deleting it, you want its limited processing; or
  • we no longer need this data (for the specified purpose), but you need it to establish, exercise or defend legal claims; or
  • You have objected to the processing of the data, pending verification that the controller’s grounds are lawful.
  1. Right to data portability:

You can ask us to provide the personal data you have entrusted to our care in an organized, orderly, structured, generally accepted electronic format if:

  • we process the data according to the contract and based on the declaration of consent, which can be withdrawn or on a contractual obligation and the processing is performed automatically
  1. Rights in relation to automated decision making and profiling:
  • Article 22 of the GDPR has additional rules for the protection of individuals if you only make automated decision-making that has a legal or similar significant impact on them.

Your responsibilities


If you sell through our Services (you are registered as a Provider), you may receive and determine for yourself what to do with certain personal information. Your responsibilities for confidentiality, including when you act as an independent data controller (someone who decides what personal data to collect and the purpose for which it uses the data), are set out in’s Reseller Policy.


Right to appeal


In case you believe that we are violating the applicable regulations, please contact us to clarify the issue. Of course, you have the right to lodge a complaint with the Data Protection Commission. From 25 May 2018, you can also lodge a complaint with a regulatory body within the EU.

Applications for access to information or for correction are submitted personally or by a person expressly authorized by you, through a notarized power of attorney. An application may also be submitted electronically, in accordance with the Electronic Document and Electronic Signature Act.

We will rule on your request within 14 days of its submission. In case of an objectively necessary longer term – in order to collect all the requested data and this seriously complicates our activity, this term can be extended up to 30 days. With our decision we give or deny access and / or the information requested by the applicant, but we always motivate our answer.


Third party relations


This website may include links to other third-party websites, plugins and applications. Clicking on or activating these links may allow third parties to collect or share information about you. We do not control these websites and are therefore not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of each website you visit.




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Relevance and policy changes


In order to implement the most up-to-date protection measures and in order to comply with the current legislation, we will regularly update this Privacy Policy. If the changes we make are significant, we may post a notice of the changes on our website. We invite you to regularly review the current version of this Privacy Policy, to be constantly informed about how we take care of the protection of personal data that we collect.

This Privacy Policy was last updated on September 10, 2019.


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