Privacy Policy

This Privacy Policy is an integral part of the General Terms and Conditions for the use of the website www.ludaconcept.bg (the website) and applies to visits and use of the website, as well as during the product ordering process.

The website www.ludaconcept.bg is administered by LUDA STYLE LTD (the Company). In carrying out its activities, we act as a personal data controller and perform actions for collecting, processing, and storing personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation or GDPR) and applicable national and European legislation.

To use the services of the Website, including to access the online product ordering platform and related services, our information system requires certain information about you, through which you can be identified directly or indirectly.

1. Information voluntarily provided by the User:

In cases where a specific service on the Website requires it, we may ask you to provide us with the following personal data:

• full names
• valid email address
• phone number
• physical delivery address
• possible preferences or comments
• additional data (user content and/or inquiry);

The specified categories of personal data may also be requested in case of an inquiry to us regarding the exercise of your rights described below.

2. Information the Website collects from the User

To perform certain functionalities of our website and the services you access through it, our information system collects information from your electronic device during standard operations for normal WEB functioning. In this way, the following additional categories of personal data may be collected:

• IP address
• browser used
• preferred language settings
• type of device used to load the site
• information about your device's operating system
• user behavior and user characteristics data.

We collect data about the source from which you accessed the Website. In any case, we do not collect your publicly available information, including if the link to our site is from a social network.

When you visit the Website, our social media profiles, and/or use the functionalities and services available on the Website, including for creating a user profile and shopping, certain personal data may be collected and processed through the installation of small text files - so-called Cookies - on your device.

Your data may be used by us for traffic analysis, advertising purposes, market research and profiling of user groups, system reports on Website activity and for retrieving consumption information, to improve the functionality of the website and its analysis, including, but not limited to, for:

actions for creating and administering user profiles

• actions for identification and establishment of the legally prescribed age for online shopping
• direct marketing of products and services
• evaluation of advertising effectiveness
• management and administration of online shopping activities
• analysis of purchase history, preferences, and behavior
• prevention of payment fraud
• inquiry management.

Cookies can also be created, accessed, read, and manipulated by third parties (our advertising partners, social networks, analytics partners). To learn more about the conditions under which these third parties use cookies, as well as about the data they collect, for how long they do so, for what purposes they collect it, and how you can prevent or confirm this, you can visit their respective cookie policies.

More information about the Cookies we use and the general terms of use of the website can be found in our General Terms and Conditions for Website Use and Cookie Policy.

3. Children's personal data. How do we treat them?

The services of the Website are not aimed at individuals under 18 years of age. The Company does not intend and does not wish to collect personal data of children in connection with the services provided through the Website.

However, if the Company receives information about a minor in connection with the services of the Website, we will not process it and will delete it, unless a legal act obliges us to process this data in another specifically established manner.

In carrying out our activities, we apply the following basic principles:

• data is processed lawfully, fairly, and transparently;
• data is collected only for explicit, specified, and legitimate purposes;
• processed data is minimized to what is necessary in relation to the stated purposes;
• data is kept up-to-date and for no longer than necessary;
• processing is carried out in a manner that ensures an appropriate level of security, protection against unauthorized or unlawful processing, loss, destruction, or damage;
• access to data by third parties is provided only for purposes essential to the provision of the requested service;
• maximum assistance is provided in exercising data subjects' rights.

In connection with the purposes listed below, the Website collects information from its visitors, including end-users – data subjects.

Personal information processed through the site may be collected in the following ways, jointly and severally:

1. Provided personally and voluntarily by the visitor;
2. Through the use of "cookies" and other similar solutions for optimizing website performance, analysis, and sending commercial messages.

We use the information described above for various purposes, based on the relevant legal grounds under Art. 1, para. 1 of the GDPR for the following purposes:

• To provide you with the information you request about our products.
• To register you as a user of our website.
• To ensure the correct processing of your order, should you purchase any of our products.

LUD/A uses its social networks to advertise its products. In this way, when you share your data on our social networks, you explicitly agree and authorize us to reproduce and publicly communicate on these networks, for the purposes indicated above.

You can withdraw this consent at any time by sending an email to the following address: luda.style@yahoo.com

If you do not wish for your data to be processed through LUD/A's social networks under the conditions mentioned above, please refrain from sharing images.

Should we need to process your data for purposes other than those mentioned above, we will request your consent, which can be unilaterally withdrawn by you at any time.

In accordance with applicable legislation, we maintain appropriate, necessary, and proportionate technical and organizational measures for the protection of user data, including to prevent unauthorized access to it and/or its improper use.

The protection of your personal data and information security are among our top priorities. We implement and apply appropriate technical and organizational measures to ensure the security of your personal data. Every work process is carried out ensuring the security, reliability, confidentiality, and availability of information. Our employees are familiar with current legislation and internal policies related to the protection and processing of personal data, adhering to high standards of ethics and confidentiality. We review and evaluate the implemented technical and organizational measures to ensure the security of personal data at all times.

Your personal data will be stored for as long as necessary to fulfill the purposes for which it was collected. After this time, LUD/A will continue to remove it from its systems, without excluding the possibility of retaining it, limiting its processing to the exercise and defense of claims, within the periods provided for by applicable law.

Subject to applicable legislation, in certain situations we may share your personal information with third parties in accordance with Art. 6, para. 1 of the GDPR:

• Contractors – financial institutions, couriers, insurers, accountants, lawyers, information security consultants, marketing agencies, and others – if necessary for: fulfilling legal or contractual obligations; assisting in managing work processes; protecting legitimate interests.
• Public authorities – tax administration, supervisory and control bodies, local authorities, and others – for fulfilling legal obligations.
• Google Analytics, Google Tag Manager, and other partners providing technical platforms for customer contact – for optimizing and managing commercial and marketing processes.
• Judicial authorities, arbitration courts, lawyers, notaries, state and private bailiffs, mediators, collection agencies, and other intermediaries for debt collection – for the purpose of protecting legitimate interests, including in exercising or defending legal claims, collecting debts, filing/responding to complaints, signals, lawsuits, and others to competent state and judicial authorities.
• Special authorities – administrative, judicial, and/or executive authorities – when necessary and obliged to disclose trade secrets; in connection with resolving legal disputes before a competent court and/or arbitration; sharing information with law enforcement agencies and financial institutions when required by law or strictly necessary to prevent, detect, or prosecute criminal activity or fraud.
• Accounting and control – for fulfilling obligations under accounting law or established international accounting standards.

• You can always check your rights with us by sending an email to luda.style@yahoo.com.
• You can also access your personal data, request correction of inaccurate data, or, if applicable, request the deletion of data when, among other reasons, they are no longer necessary for the purposes for which they were collected.
• Under certain circumstances, to object to the processing of your data.
• Request the portability of your data.
• Revoke the consent you have given for the processing of your data by LUD/A.
• You can report to the Bulgarian Commission for Personal Data Protection.

If you want to learn more about your rights, how to exercise them, and the relevant procedures, you can visit the information website of the European Data Protection Supervisor, the Commission for Personal Data Protection or the relevant authority in your country.

Version 12.2023