I. General information

This privacy policy has been drawn up and is applied by „Nest Basket Platform BV“ (hereinafter referred to as “Next Basket Trading” or “Administrator”) in accordance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as “Regulation (EU) 2016/679”), in effect since 25.05.2018, and in accordance with the Personal Data Protection Act.

As a personal data processor, Next Basket Trading meets all legal requirements, incl. of the new regulation, collecting personal data to the extent necessary for the provision of the service, and stores it responsibly and lawfully.

This policy aims to provide information to users about every aspect of the processing of personal data by the processor, as well as the rights arising from this processing.

II. Details of the data processor and data protection officer

Personal data processor

„Nest Basket Platform BV“

Headquarters and management address: Fascinatio Boulevard 216-219 Rotterdam 3065 WB, Netherlands

Email: [email protected]

www.nextbasket.com

Personal data protection officer

„Nest Basket Platform BV“

Address: Fascinatio Boulevard 216-219 Rotterdam 3065 WB, Netherlands

Email: [email protected]

Official: Nikoleta Petrova

III. Purposes, principles, and grounds for collecting, processing, and storing personal data

Next Basket Trading is a platform for creating and operating online stores. Considering the activity of the processor, in order to provide its services, it collects and processes personal data, adhering to the requirements of Regulation (EU) 2016/679.

Next Basket Trading collects and processes personal data for the following purposes:

    Creating an affiliate profile and providing access to the processor’s affiliate platform, incl. identification;

    Creating a partner’s online store and providing certain functionalities;

    When performing the offered services;

    Accounting purposes;

    Sending informational messages, notifications about changes to the service, recommendations to improve the use of the service and more;

    Improving and personalizing the service.

When processing personal data, Next Basket Trading observes the following principles:

Legality, good faith, and transparency;

Limitation of processing purposes;

Relevance to the purposes of the processing and minimization of the data collected;

Accuracy and up-to-date status of data;

Limitation of storage in order to achieve the objectives;

Integrity and confidentiality of processing and ensuring an appropriate level of security of personal data.

When processing and storing personal data, the processor processes and stores personal data in order to protect its legitimate interests, such as fulfilling its obligations to the National Revenue Agency, the Ministry of the Interior, and other state and municipal institutions.

IV. What types of personal data does the processor collect, process, and store

Next Basket Trading performs operations with personal data for the following purposes:

    Registration of a partner at the processor’s platform and creation of a partner profile (e.g. three names, PIN, phone, email, address, etc.);

    Sending information messages and establishing a connection – for a service performed, an invoice issued;

    Other personal data, provided personally or by a third party, necessary in connection with and during the performance of the services.

Next Basket Trading processes your personal data pursuant to Art. 6, b. a) of the Regulation (EU) 2016/679, which regulates cases where the user gives their consent to the processing of their personal data for one or more specific purposes.

In addition to the above, Next Basket Trading processes your personal data pursuant to Art. 6, b. b) of the Regulation (EU) 2016/679, which regulates the cases where “the processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject prior to the conclusion of a contract”.

Bearing in mind the legal requirements towards the processor, they process data relating to a legal obligation and legitimate interest to the National Revenue Agency, etc., which processing purpose is regulated by Art. 6, b. c) and b. f) of the Regulation (EU) 2016/679.

By accepting the general conditions, registering, and creating a partner profile on the Next Basket Trading platform, as well as by providing personal data and other documents, a contractual relationship is created between the partner and the processor based on which your personal data is processed.

Each of the actions described above gives grounds and consent to the processing of any additional information provided by the user voluntarily, as well as when using the Next Basket Trading platform, the partner agrees to the collection of data, such as IP address, for the purpose of security improvement.

The persons who process personal data on behalf of Next Basket Trading are persons who are employed under a civil or employment contract, or another type of contract, and perform various stages of the overall management, execution, and delivery of the service provided. Next Basket Trading requires all employees/workers/persons engaged under a civil contract to be trained and to accept the relevant contractual clauses/declarations/rules for compliance with organizational and technical measures for access before being engaged in processing personal data provided by Next Basket Trading and before being granted access to information of any kind.

All employees/workers/persons engaged in a civil contract who process your personal data are responsible for ensuring the security of the storage of the data for which they are responsible and which Next Basket Trading processes.

Next Basket Trading does not perform automated data decision making.

V. Period of storage of personal data

Next Basket Trading stores personal data for a period not longer than the existence of the partner profile on the platform.

Next Basket Trading stores the personal data that it is required to maintain under the applicable law for the relevant stipulated period, which may exceed the period of existence of your registration.

VI. Transfer of personal data for processing

Next Basket Trading may, at their own discretion, transfer part or all of the personal data to personal data processors for the fulfillment of the purposes of processing in compliance with the requirements of Regulation (EU) 2016/679.

Next Basket Trading notifies you in the event of a need to transfer part or all of your personal data to third parties and/or state/international organizations.

VII. Your rights in the collection, processing, and storage of your personal data

1. Withdrawal of consent to the processing of your personal data

In the event that you do not wish all or part of your personal data to continue to be processed by the administrator for specific or all processing purposes, you can withdraw your consent to processing at any time, by request by email or through your affiliate profile.

Upon withdrawal of your consent to the processing of personal data, which is mandatory for the creation and maintenance of your registration to use the services, your account will be canceled.

2. Right of access

Every user has the right to request and receive confirmation from Next Basket Trading as to whether personal data related to them is being processed.

Every user has the right to obtain access to the data related to them, as well as to the information related to the collection, processing, and storage of their personal data.

Next Basket Trading provides, upon request, a copy of the processed personal data related to you, in electronic or other appropriate form.

3. Right to rectification or completion

Any user can rectify or complete inaccurate or incomplete personal data related to them directly through their affiliate profile.

4. Right to erasure (“to be forgotten”)

Each user has the right to request from Next Basket Trading the erasure of the personal data related to them, and the administrator has the obligation to delete them without undue delay when any of the following grounds are present:

the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

the user withdraws the consent on which the processing of the data is based and there is no other legal basis for the processing;

personal data should be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the processor.

Next Basket Trading is not obliged to delete personal data if it stores and processes it as follows:

    to exercise the right to freedom of expression and the right to information;

    to comply with a legal obligation that requires processing provided for in EU or Member State law applicable to the controller or for the performance of a task in the public interest or in the exercise of official powers conferred on it;

    for reasons of public interest in the field of public health;

    for the establishment, exercise, or defense of legal claims.

To exercise your right to be “forgotten” you should submit a request through the option in your partner profile or a written request sent to the processor, as well as certify your identity and identity with the data subject by presenting your ID card on site for identification purposes and, if necessary, enter your login details in the data subject’s profile at the attendance of a representative of the processor.

The processor does not delete the data that they have a legal obligation to store, incl. for defense in connection with legal claims made against them or to prove their rights.

5. Right to limitation

Every user has the right to request the processor to limit the processing of the data related to them when they:

    dispute the accuracy of the personal data, for a period that allows the processor to verify the accuracy of the personal data;

    the processor no longer needs the personal data for the purposes of processing, but you require them to establish, exercise, or defend your legal claims;

    object to processing pending verification of whether the processor’s legal grounds prevail over the user’s interests.

6. Right of portability

Each user has the right at any time to download the data that is stored and processed for them in connection with the use of the processor’s services, by request by email or through the partner platform.

Each user has the right to request the administrator to directly transfer personal data to an administrator indicated by them, when this is technically feasible.

7. Right to receive information

Each user has the right to request from the processor to be informed about all recipients to whom the personal data for which correction, deletion or restriction of processing is requested, has been disclosed. The processor may refuse to provide this information if it would be impossible or would require a disproportionate effort.

8. Right to object

Every user has the right to object at any time to the processing of personal data by the processor that pertains to him, incl. if processed for profiling or direct marketing purposes.

9. Your rights in the event of a breach of the security of your personal data

In the event that Next Basket Trading detects a violation of the security of your personal data, which may pose a high risk to your rights and freedoms, they will notify you without undue delay of the violation, as well as of the measures that have been taken or are about to be taken.

Next Basket Trading is not obliged to notify you if:

appropriate technical and organizational protection measures have been taken with respect to the data affected by the security breach;

measures have subsequently been taken to ensure that the breach will not result in a high risk to your rights;

notification would require a disproportionate effort.

VIII. Competent authority for personal data protection

In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to log a complaint with the Personal Data Protection Commission:

Personal Data Protection Commission

Headquarters and management address: City of Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.;

Phone: + 359 2 915 3 518

Email: kzld (at) cpdp.bg

www.cpdp.bg

IX. Policy changes and updates

Next Basket Trading reserves the right to change this policy in order to keep it up-to-date in compliance with current legislation.