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Privacy Policy

“Eleven Trading” Ltd. strictly complies with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and the Personal Data Protection Act (PDPA) and has appointed data protection officers within the company.

All our employees have signed declarations committing to comply with regulatory requirements and internal rules for the protection, security, and confidentiality of personal data.

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Controller Details

“Eleven Trading” Ltd., UIC: 207532965, is a company engaged in import, export, wholesale and retail trade, including e-commerce, of charging stations for electric vehicles and related equipment in Bulgaria and the EU.

Contact Details:

  • Registered Office: Plovdiv, 8 Naycho Tsanov Blvd., fl. 4, office 10
  • Email address: contact@11kwh.com
  • Phone: +359(89) 660 7777

Data Protection Officer:

You can contact our Data Protection Officer by email at: contact@11kwh.com

Personal Data We Collect and Process

The personal data we collect and process from you are:

Category of personal data:

1. Individuals, customers of the physical store: Names, Address, email, Phone number

2. Individuals, customers of the online store: Names, Address, email, Phone number, IP address, cookies (in accordance with the cookie policy).

3. Company employees/workers

Identification: names; PIN (date of birth), permanent and/or current address, phone, ID card or passport details;
Education and professional qualification; data related to education, work experience, professional and personal qualifications and skills;
Special categories of data we process for employees/workers: health status data (in connection with the administration of our labor/civil legal relations with you).

Source

The data is obtained from the data subject. We declare that the personal data we collect will be used solely for the following purposes:

Legal Basis

The legal basis that gives us the right to process your data is:

“Eleven Trading” Ltd. may process your personal data for various reasons, depending on the relationship between us and based on the relevant applicable legal grounds under privacy laws, such as: legitimate business purposes of “Eleven Trading” Ltd., for the conclusion and/or performance of a contract concluded with you, for compliance with legal obligations by “Eleven Trading” Ltd., as well as with your freely given, specific, informed, and unambiguous consent for the processing of your data. Some of the main points in the processing of personal data are:

Legal GroundsActivities, Actions, Interests
Legitimate business purposes of “Eleven Trading” Ltd.Business activity of “Eleven Trading” Ltd.
Conclusion and/or performance of a contractLawful occurrence, implementation, and termination of commercial, labor, and civil legal relations. Ensuring compliance with health and safety procedures
Compliance with legal obligationsFulfillment of obligations of “Eleven Trading” Ltd. under current labor, civil, tax, insurance, and other legislation; Ensuring safety and security conditions for its employees and property; Prevention and/or investigation of incidents, violations, and criminal offenses;
Your consent receivedTo register on our site; To respond to your request to exercise a right, etc.

Access to Personal Data

The following organizations/persons will receive your personal data:

Customers of the physical and online store: Recipients of your data may be courier companies in connection with the delivery of goods and credit institutions in connection with your request for a purchase on credit.

Employees and workers: Recipients of your data may be an accounting firm in its capacity as a personal data processor and state authorities to whom we provide them under specific and clear legal obligations

Third parties who may receive your data are obliged to keep your data secure and use it only to fulfill the obligations undertaken to us. When they no longer need your data to fulfill these obligations, they will have detailed instructions for its destruction in accordance with the procedures established by “Eleven Trading” Ltd.

Consent

By consenting to accept this Privacy Policy (notice for confidential treatment of personal data), you give us permission to process your personal data only for the purposes specified by us.

Consent is necessary for us to process both types (ordinary and special) of personal data, but it must be explicit.

In cases where we request consent for special (sensitive) personal data, we will always justify why and how this information will be used.

You can withdraw your consent at any time with a standard Data Subject Consent Withdrawal Form.

Data Retention Period

“Eleven Trading” Ltd. will store your personal data for no longer than the period provided for by the legal relationship, the contract, or the validity period of the offer; in the event of a submitted complaint – until the final completion of the complaint procedure;

Regardless of this, data is stored until the expiration of the relevant legally defined periods, if any, and the data will be stored in the ways detailed in the Personal Data Protection Policy adopted by “Eleven Trading” Ltd., which you can review at the physical store of “Eleven Trading” Ltd. or online at the websites of “Eleven Trading” Ltd. – 11kwh.com and in accordance with the Schedule for Collection and Destruction of Data Categories approved by “Eleven Trading” Ltd.

Rights as a Data Subject

Your rights as a data subject are as follows:

Refusal of Erasure

We may refuse to erase your personal data for the following reasons:

Right to Lodge a Complaint

You have the right to lodge a complaint with the supervisory authority:

You have the right to lodge a complaint directly with the supervisory authority, the competent body being: Commission for Personal Data Protection, address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd. (www.cpdp.bg).

In case you wish to lodge a complaint regarding the processing of your personal data through “Eleven Trading” Ltd., you can do so at the provided contact details of “Eleven Trading” Ltd.

You can read more about how and why we use your data below.

According to the General Data Protection Regulation, personal data is defined as:

“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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;”.

In order to provide you with the products and services we offer, it is necessary to collect personal data of the categories and for the purposes detailed above.
We guarantee that the information we collect and use is essential for this purpose and is not intended to invade your privacy.
For the purposes of communication with advertising and marketing intentions, “Eleven Trading” Ltd. will request additional consent from you.

In this privacy notice above, we detail the purposes and reasons for collecting and processing your personal data.

We will not sell your data to third parties, nor will we transfer it for the purpose of gaining any benefit.

“Eleven Trading” Ltd. may transfer your personal data to our service sub-suppliers who have entered into a contract with us.

All third parties who may receive your data are obliged to keep your data secure and use it only to fulfill the obligations undertaken to us. When they no longer need your data to fulfill these obligations, they will have detailed instructions for its destruction in accordance with the procedures established by “Eleven Trading” Ltd.

When we intend to transfer special (sensitive) personal data to a third party, we will do so only after we have received your consent (an exception will only exist if we are legally obliged to do otherwise).

“Eleven Trading” Ltd. processes (collects, stores, and uses) the information provided by you in a manner compatible with the requirements of the General Data Protection Regulation (GDPR). We will strive to keep the information accurate and up to date.

We will not store information about you longer than reasonably necessary to fulfill the specific purposes for which it was collected and of which you are notified here.

Some of the retention periods for information depend on legal obligations to keep documents and information for certain minimum periods

We will take all foreseeable technical and organizational measures to ensure the protection of your data from unauthorized access.

  • Data is stored in premises protected by a security alarm system;
  • Access to the administrative premises of “Eleven Trading” Ltd. is restricted – a controlled access system has been established; outsiders are admitted only after identification and with an escort from “Eleven Trading” Ltd.;
  • There is an active video surveillance system on the territory of the administrative and commercial premises of “Eleven Trading” Ltd.
  • Access to data in electronic form is stored in specialized software programs, with access granted only to the relevant responsible persons for whom separate accounts with a separate username and password have been created, known only to the respective responsible person;
  • Frequent changes of access passwords have been established to achieve a higher level of data protection;
  • Various procedures have been approved to guarantee security during the processing, storage, and destruction of data;
  • Antivirus software and firewalls are installed on all computer devices; in case of inactivity of software programs containing data, access to them is automatically deactivated; every employee who works with a computer device enters a username and password to use it;
  • Data on paper is stored in a locked cabinet, access to which is only available to the relevant responsible person;
  • Data in online stores is protected by an SSL certificate (Secure Sockets Layer (SSL) is a protocol for enabling data encryption on the internet or intranet and for helping web page users confirm the owner of the website.)

“Eleven Trading” Ltd., at your request, is obliged to answer what information we store about you and how it is processed.

In case we have your personal data, you can request the following information:

  • Contact details of the organization that processes or on whose behalf your data is processed. (In some cases, this may be a representative in the EU).
  • The purposes of the processing;
  • The legal basis for the processing;
  • The relevant categories of personal data being processed;
  • The recipients or categories of recipients to whom they have been or will be disclosed;
  • Recipients in third countries or international organizations if there is a transfer of personal data to such, as well as guarantees that data security with them will be at least at the EU level;
  • If the processing is based on the legitimate interests of “Eleven Trading” Ltd. or a third party, information about those interests.
  • The intended period for which the personal data will be stored;
  • Details of your rights to request rectification or erasure of personal data or restriction of processing of personal data, as well as to object to such processing;
  • Information about your right to withdraw your consent at any time;
  • Details of your right to lodge a complaint with a supervisory authority;
  • Information on whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failure to provide such data.
  • The source from which your personal data was collected, in cases where it was not collected directly from you.
  • All details and information about the existence of automated decision-making, such as profiling, and any meaningful information about the logic involved in these operations, as well as the significance and expected consequences of such processing.

Access to my data

How do I get access to my data that is being processed?

Registered users in the online store can exercise their rights through the personal data management tools in their profile.

For all other data subjects in this declaration, it is necessary to fill out an access request, which you can obtain here or at the physical store of “Eleven Trading” Ltd. To verify your identity, it is necessary to present an identification document.

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