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Privacy policy




1. Data processor

We would like to present you with information regarding the way in which we collect and process your personal data, for the website seewinesspirit.com

Data processor for the Site (referred to as Us or We below) is Seewines Spirit Jsc., with UIC 203328730, with seat in Sofia and management address in Vitosha region, 106 Bulgaria blvd, entr. D 

Contact us at Seewines Spirit Jsc., with UIC 203328730, with seat in Sofia and management address in Vitosha region, 106 Bulgaria blvd, entr. D telephone +359 884308778, e-mail: [email protected]

It is of utmost importance the data we collect concerning you to be accurate and current. Please inform us should your personal information change at any time, so that you may update the personal data in your profile.

Bear in mind that with providing your personal data, you confirm that you are 18 years or older. If this is not so, please contact us so that we may take up measures to erase them.


2. What information do we collect, on what grounds and for what goals?

Personal data is any information which may be used to identify a person. Anonymous data is not included. We process the following personal data:

Type of data

What does the data consist of?

For what goals do we use the data?

On what grounds we process the data?

2.1. Client information

Include data, regarding purchases of goods or services, such as name, address for invoice and delivery, e-mail, other contact information, purchase statistics, etc.

We collect this information to deliver the goods or services you have purchased, to keep track of such deals.

The legal grounds is the execution of the contract concluded between Us and you as well as the steps leading up to this contract. 

2.2. Communication data 

They include any message which you send us, regardless via communication form, e-mail, direct message, social media publication etc. 

We process this data, for the purpose of communicating with you, to keep files, to track performance as well as to protect against legal claims.

The legal grounds for this processing is the legitimate interest, as they will help us communicating with you, to keep files, to track performance as well as to protect against legal claims.

2.3. Technical data

Include date, regarding the use of our website, online services, your IP address, entry data, browser details, length of visit, browsed pages, navigation routes, information of visits, time-zone settings, other technologies of the devices you use to access our site. The source of this data is our analysis tracking system.

We process this data so as to analyze the use of our website and other online services, to administrate and protect our business, to provide appropriate content and understand the effectiveness of our ads. 

The legal grounds for this processing is the legitimate interest, as they will help us administrate our website, to develop our business and to set our marketing strategy.

2.4. Marketing data

Data regarding your preferences for receiving marketing information from us, and third parties, as well as the preferred communication means.

We process this data to include you in our promotions, such as games, rewards, gifts to provide you with adequate content and advertisement and to help us understand their effectiveness.

The legal grounds for this processing is the legitimate interest, as they will help us research how clients use our services, to develop them and our business and to set our marketing strategy. 






3. Confidential information and other data

We do not collect any confidential data about you whatsoever. Confidential is the data related to your race, ethnicity, religious or philosophical beliefs, sexual life, sexual orientation, political views, membership in syndical organizations, health information, genetic or biometric data. We do not collect information for criminal verdicts or crimes.

Please keep in mind – whenever we are required by law or by the contract concluded between us and you, to collect personal data, and you do not provide us with such data on demand, we may not be able to execute the contract (deliver goods or services). If you do not provide us with the requested data, we may cancel the goods you ordered, for which you will be notified duly.

We shall use your personal data for the purpose for which they are collected or if necessary for a goal close to it. In the event we require to use the data for a new goal, we shall notify you, stating our legal reasoning.

We may process data without your knowledge or consent, only insofar it is permitted by law. We do not perform automatic decision making or profiling..


4. Means of gathering personal data from you:

• You provide them to us (by filling forms on our website, or sending e-mails)

• Automatic collection of certain data, which you provide when using our website, by using cookies and similar technologies. Please see our cookies policy

• We may receive data from third parties: analysis providers (Google), ad networks (Facebook),  search information providers (Google), based outside the US, technical, payment or other service providers, information brokers.

• Our legal reasoning for processing your data for the purposes of marketing communication is your consent or our legitimate interest (to extend our business)

According to legislation in data protection and electronic messages, we may send you marketing messages if:

A you purchase goods or services, register on the website, or address an inquiry or;

B you have provided consent to receive marketing messages, where in both cases you have not expressly rejected to receive such messages. According to applicable law, if you are a legal entitiy we may send you marketing e-mails without your consent. In this case you may again opt out of receiving marketing e-mails from us at any time.

We require your explicit consent prior to providing your data to third parties for marketing goals.

You may request that we cease sending marketing messages to you at any time, by accessing the website and your account, and filling the desired settings, so as to change your preferences.

If you opt out of receiving marketing messages, this does not affect personal data provided as a result of other transactions such as purchases, warranties, etc.


5. Sharing your personal data

We may share your personal data with the following parties:

IT or system administration service providers;

Professional consultants – attorneys, bankers, auditors, accountants and insurance companies;

Government authorities when requesting our reports for data processing procedures.

We demand from all parties we transfer your personal data to keep the security of your personal data and abide the law. Third parties may process personal data only for strictly approved purposes and in accordance with our instructions.


6. Data security

We have implemented security means so as to prevent accidental loss, use, change, discovery, or access to your personal data, without permission. We provide access to your personal data only to these employees or partners, which need to use such data. They have been instructed to process your data accordingly and to abide to the rules for confidentiality.

We have a procedure in place to take care in case of suspicion for leak of personal data, and shall inform you as well as the regulatory authorities, regarding such infraction if and when necessary. 


7. Data keeping

We shall keep your data for as long as necessary to perform the goals for which they have been gathered, or to satisfy other legal, accounting or auditory requirements.

Whenever we decide the term for data keeping, we consider their quantity, nature and sensitivity, risk of malicious use or discovery and the goals of the processing, as well as whether these goals can be achieved by other means.

Keep in mind that tax laws require we keep basic information for our clients – contact info, identity, financial data, transaction data), up to ten years after you cease being our client.

In certain circumstances we may turn your personal data into anonymous data, for the purpose of research or statistics, and in such cases we may unlimitedly use this information, without notifying you.


8. Term

Personal data is collected for the terms we require to achieve the goals for which they were collected. After this we will delete them immediately.

We undertake all necessary technical and organizational means to destroy the data we no longer need, except when we have legal grounds to process them longer; in the event you request restriction, as established below, or regards a similar to the initial processing goal, for which you will be duly notified.

We keep the collected date for the following terms:

a) Whenever data is collected on contractual grounds for distance purchase contracts – for a 5 year term, following the date of termination of the distant purchase contract.

b) whenever data is collected based on consent provided – until the explicit withdrawal of said consent 

в) whenever data is processed to protect or guard rights and interests of the company, which have prevalence over natural persons interests – until the right is extinguished or the interest is lost.

After expiration of the terms, unless other grounds are applicable, the data will be deleted. For the purpose of gathering and analyzing information related to the products and services you use, as well as to improve our services, the company may opt to delete the data only partially. In this case it will be kept in such a manner so as not to allow natural entities to be identified.


9. Third party links

This website may include links to other thirdparty websites, plugins, and apps. Clicking or activating them may allow third parties to collect or share your data.

We do not control these websites and we cannot be held liable for their privacy policies. When you leave our website, we recommend you read the privacy policy of the website you visit. 


10. Cookies

You may set up your browser to reject some or all cookies and to warn you in case websites have access to set up cookies. Keep in mind that if you deactivate or refuse cookies some parts of the website may stop functioning as intended, for more information regarding cookies we use, see our Cookies policy.



As a data subject of personal data we process, you have rights, as exhaustively established hereto:

You should keep in mind that providing of personal data is mandatory to conclude a contract with Us. If We do not receive such data, the company may no provide some goods or services.

We satisfy your requests without delay within up to 30 calendar days, following the date you send them. With our decision, we grant or deny access or the information request with a motivated answer. For this purpose the Site has a visible link to the current Policy.

The filing of claims regarding exercising your rights are:

Filed personally or by another party with notary certified authorization, to the management address of the company.

By electronic means, via e-mail to [email protected]

Via telephone call +359 884308778

Exercising of these rights is free and extends towards all structured and unstructured data, as well as databases, maintained by the company.

Exemptions on the term and the free-of-charge principle are possible in the event where the same client has filed requests more than three times in one year, which demand mobilization of exhaustive administrative resources by Us. In this case we may implement a reasonable fee for the administrative expenses.

Whenever the data subject files an electronic request the information is provided by electronic means unless otherwise specified.

Whenever a company has reasonable concerns regarding the identity of a person who has filed a request to exercise the rights hereto, the responsible party must contact the data protection officer to conduct client identification.

Withdraw of consent you have provided does not affect the processing of data, provided before the withdraw. In spite of withdrawn consent, the personal data may be processed by us, on different legal grounds as per this Policy.


You have the following rights:

1. Right to information

As a data subject you may receive information on important characteristics of the processing of your personal data, including but not limited to its purpose, term and justification, the recipients and their categories, etc.

According to the applicable legislation in data protection, you may exercise the rights below, and we must respond to any of your demands within a 1-month term following the receipt of a request, free of charge. In case of difficulty to satisfy your request, the term may be extended by an additional 2 months, for which you will be notified, within 1 month of receiving your request.


2. Right to access

You may demand information regarding which of your personal data we process, if any. You may request access to such data. We shall provide an excerpt of the data we currently process. For additional excerpts we may request a reasonable fee, based on the administrative expenses. When filing a request with electronic means, we shall provide the information in a widely-used electronic format, unless otherwise requested.


3.  Right to rectification

You have the right to rectify and complete or request from us to rectify inaccurate or incomplete Personal Data, which is related to you.


4.  Right to erasure

You may request erasure of your personal data when:

They are no longer needed for the aims for which they have been gathered or otherwise processed;

You withdraw your consent, on which processing is based and there is no other legal basis for processing;

You deem that your personal data has been processed unlawfully;

Keep in mind that the immediate erasure may be prevent by different reasons, such as lawfully established requirements to store the data, pending legal procedures, legal claims, etc.


5.  Right to restrict processing

You may request restriction in the processing if

you object to the accuracy of the personal date for a term which allows us to examine the accuracy;

the processing is unlawful, but you wish to only restrict their use;

we no longer need your personal data for the purpose of processing but you request them so as to identify, exercise or protect legal claims;

you have objected against the processing pending an examination whether the legal grounds for processing of your data will prevail over your interests;

Whenever you have requested the restriction of processing we shall notify you prior to the removal of the limitation of processing.


6.  Right to transfer

You may request from us to provide you with your personal data we process in a computer readable format, so as to be transferred to another data controller. This is used only when

processing of your data is done based on your consent for the conclusion or execution of distance sale of goods and also when

processing is done automatically.


7. Right to withdraw consent

Whenever we process your Personal Data on the basis of your consent, you may at any point withdraw your consent. This may happen online, by contacting us via e-mail, or on the address provided below. The withdrawal of your consent shall in no way affect the lawfulness of the processing performed prior to the withdrawal


8. Right to complaint before the authority body

If you believe that your rights in relation to Personal Data protection and their security have been violated, please contact us, alternatively you have the right to contact the Bulgarian commission for Personal Data protection.: Sofia, 2 Prof. Tsvetan Lazarov blvd. +3592/91-53-518, e-mail: [email protected].

Any demands, as well as clarifications and information, regarding exercising your rights, may be stated directly to us, through the provided channels for contact.

This Policy was accepted on 10.05.2024г.