Privacy policy

PERSONAL DATA PROTECTION POLICY OF SEEWINES LOGISTICS LTD

 

 For us, "Seewines Logistics" EOOD, the protection of your personal data is a priority. In this regard, we inform you about the legal grounds, purposes, timeframes, and methods by which we process your personal data when you visit our website or use our products and services.

We process your personal data in accordance with applicable legislation, including General Regulation (EU) 2016/679 ("GDPR"). In this policy, you will find information regarding the purposes and methods of data processing, as well as your rights and how to exercise them.

I. Introduction

In this Privacy and Personal Data Protection Policy, "we", "us", or "our" means "Seewines Logistics" EOOD, and "you", "your", and "user" means visitors to our website – www.seewines.com or users of our products and services.

This Personal Data Protection Policy explains and governs:

• how and when we collect your personal data and what information we collect;
• how and why we use your personal data; and
• your rights to control your personal data.

Please read this Personal Data Protection Policy carefully. By accessing and using our website and services, you confirm that you have had the opportunity to read this Policy, that you understand it, and that you agree to be bound by it.

We may occasionally amend the Policy to comply with applicable laws and regulations or to respond to changing business requirements. We encourage you to periodically review this page for the latest information on our privacy practices and amendments to our Personal Data Protection Policy. Every time we make a change to the Policy, we will notify you of the possible effects of the change without delay via a summary on our website www.seewines.com.

II. General Information

1. Certain definitions important for a better understanding of this policy:

• "Personal data" – means any information relating to an individual who, alone or in combination with other information, can be identified or is identified.
• "Data subject" – living individuals who are identified or identifiable through the processed personal data.
• "Processing of personal data" – means any action we perform or can perform with your personal data, including, but not limited to, its collection, analysis, or destruction.
• "Data controller" – regarding the personal data it administers, this is Seewines Logistics. We determine the purpose of processing your data based on one of the grounds provided by law; essentially, we also determine the means by which this processing is carried out – for example, the technical infrastructure and applications used for processing. The obligations regarding the security and protection of your personal data lie with us.
• "Data processor" – means a third party that processes your personal data on our behalf, where Seewines Logistics has strictly defined the purpose of the processing, the means by which it occurs, and has verified that the person meets GDPR requirements. Such a processor could be, for example, an agency responsible for a Seewines Logistics marketing campaign on a social network that generates reports on its performance.
• "Group of companies within Management Financial Group" ("MFG Group") – all companies directly or indirectly controlled by "Management Financial Group" AD, which are registered and operate both within the territory of the Republic of Bulgaria and abroad, performing financial and non-financial activities. An up-to-date list of all companies part of the MFG Group, as well as information about their activities, is available here.
• "Non-financial companies within the MFG Group" - companies from the MFG Group that offer non-financial products and services (e.g., in the fields of winemaking, gastronomy, hotel management, equestrian sports, etc.).
• "Joint controllers" – two or more controllers who jointly determine the purposes and means of processing personal data, based on an agreement for the processing and protection of personal data between joint controllers.
• "Digital assets" – the website www.seewines.com and all landing pages maintained by the Company, as well as web, native, and mobile applications available to clients.

2. Who are we?

"Seewines Logistics" EOOD is a company whose scope of activity includes distribution, logistics, foreign, domestic, and online trade in wine, alcoholic and non-alcoholic beverages, and other goods and items in their original, processed, or reprocessed form; commission, forwarding, warehousing, transport activities; commercial representation, mediation, and agency of Bulgarian and foreign persons, as well as any other activity not prohibited by law, provided that activities requiring a permit or license will be performed after obtaining the proper documentation.

3. How can you contact us?

"Seewines Logistics" EOOD has its registered office and management address at Sofia, Vitosha district, Manastirski Livadi residential area, 106 Bulgaria Blvd., Entr. D, Ap. 9, contact phone 0700 20 202. You can contact us by visiting the stated address of the Company, as well as on our website www.seewines.com.

4. Contact regarding data protection matters

You can contact us regarding data protection matters at: [email protected], contact phone – 0700 20 202.
 

5. Type, purpose and grounds of processing of personal data collected by Seewines Logistics LTD:

Personal Data	Purpose	Grounds
First and last name, phone, address, email	• Establishing contact with the client regarding an order placed on the Company's website at www.seewines.com • Shipping goods ordered on the Company's website at www.seewines.com • Performance of obligations under a distance contract for goods ordered on the Company's website at www.seewines.com • Providing customer service and responding to inquiries, signals, complaints, troubleshooting, and other feedback regarding the services used and goods purchased	Conclusion/performance of a contract and taking steps prior to entering into a contract
E-mail (e-mail)   Phone number	Registration of a user account on the Company's website (www.seewines.com); • Contacting the client regarding an order placed; • Processing and delivery of ordered goods; • Performance of obligations under a distance sales contract.	Conclusion/performance of a contract and/or taking steps at the request of the data subject prior to entering into a contract
	Sending marketing and advertising messages (incl. product and service offers of "Seewines Logistics" EOOD) via SMS and messaging applications (e.g., Viber)	Consent
User profile data	Creation of a personalized profile	Performance of a contract
Identification and contact data; Data on reservations, purchases, and preferences; Marketing and behavioral data; Demographic data (e.g., age and sex)	Personalizing services and offers and sending marketing messages from the Company and other MFG Group companies, including through data sharing for cross-brand marketing and loyalty programs, based on the analysis of behavior, preferences, and selected interests, incl. via SMS and messaging applications (e.g., Viber)	Consent
Date of birth	Sending greetings	Consent

 

Your personal data will be processed by "Seewines Logistics" EOOD in accordance with the applicable data protection regulations. When corresponding with us, please provide accurate and up-to-date data.

You may withdraw your consent at any time and stop receiving marketing messages via the opt-out link in any message or by contacting us at [email protected].

Furthermore, where applicable, you can manage your preferences, including:

• choosing the methods by which you receive information (e.g., email, SMS, etc.);
• specifying from which companies of the MFG Group you wish to receive messages;
• restricting the use of your data for the personalization of offers;
• if such an option is available – indicating categories of interests based on which content is personalized,

through the available preference management tools (e.g., opt-out links, preference management page (opt-in / opt-out mechanisms), or by contacting us).

If you have given consent to receive messages from other companies within the MFG Group, withdrawing it from us does not automatically unsubscribe you from their messages. You can unsubscribe from those messages via the opt-out link contained in each message sent by the respective company, or by contacting them directly through their published contact details.

6. How long will my personal data be stored?

Personal data is stored for the period necessary to achieve the purposes for which it was collected, as well as follows:

• a) when data is processed based on a concluded contract for an order of goods or services – for a period of 5 (five) years from the date of termination of the contract, unless applicable legislation requires a longer period;
• b) when data is processed based on received consent – until its withdrawal or until the achievement of the purpose for which it was collected;
• c) when data is processed based on a legitimate interest of the Company – until the respective interest ceases or until the expiration of the applicable statutory limitation periods for filing legal claims.

Upon expiration of the specified periods, personal data is deleted or anonymized, unless there is another valid legal ground for its further processing.

For the purpose of analysis and improvement of services, the Company may store anonymized data that does not allow the identification of individuals.

7. Will my personal data be accessible to third parties?

Access to your personal data may be granted to the following categories of persons who, based on contracts concluded with the Company, may act as processors, joint controllers, or Third Parties[^1], namely:

• persons who maintain the information systems of the Company located in the Republic of Bulgaria, as well as, if necessary, customer service centers in the Republic of Bulgaria;
• persons entrusted with activities involving the creation, printing, packaging, and delivery (incl. via SMS messages or electronically) of written correspondence sent by the Company to its clients;
• logistics and courier partners;
• marketing agencies acting as data processors.

Based on your consent, the Company may exchange personal data with other companies from the MFG Group for direct marketing purposes, including offering products and services (incl. financial ones) through personalized offers. Data may be provided to these companies, which process them as independent controllers, as well as to external marketing service providers. In separate cases, joint controllership is possible when companies jointly determine the purposes and means of processing.

The Company is obliged to provide personal data of its clients to competent authorities and institutions by virtue of applicable legislation and in the event that such information is requested on a lawful basis.

Personal data may be provided to joint controllers and/or data processors, including cloud service providers, to ensure the functioning of the services.

Within these processes, personal data may be transferred to countries outside the European Union ("third countries"). In such cases, "Seewines Logistics" EOOD applies appropriate safeguards for personal data protection in accordance with the General Data Protection Regulation (GDPR), including entering into standard contractual clauses approved by the European Commission or applying other permissible transfer mechanisms.

If necessary, data subjects can obtain additional information regarding the applicable safeguards by submitting an inquiry to the Company.

[^1]: "Third party" means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data (Art. 4, item 10 of the GDPR).

8. Automated Processing and Profiling

Subject to your consent, automated processing and profiling of your personal data may be carried out for the purpose of providing personalized offers from the Company and other MFG Group companies. This includes analyzing the history of purchases, services, reservations, client experiences, and visits, as well as your preferences and behavior, including, where available, interest categories selected by you and demographic characteristics such as age and sex.

Automated profiling allows the provision of personalized products, services, and integrated offers from the Company and other MFG Group companies, the selection of appropriate marketing and advertising messages, and participation in joint loyalty programs. This profiling does not lead to automated decisions with legal consequences for you.

9. How do we protect your personal data?

To ensure adequate data protection for the Company and its clients, we apply all necessary organizational and technical measures provided for in the Personal Data Protection Act and the General Data Protection Regulation. The Company has established structures to prevent misuse and security breaches of your data. In order to maximize security during the processing, transmission, and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.

III. Your Rights

As a data subject whose data is processed by "Seewines Logistics" EOOD, you have rights, the content of which is exhaustively described below.

You should bear in mind that providing personal data is voluntary – it is necessary for entering into a contract with the Company. In the event that data is not provided, the Company will not be able to provide a product or service.

"Seewines Logistics" EOOD satisfies your requests without delay, within 30 calendar days of their submission. With our decision, we grant or deny access and/or the information requested by the applicant, but we always justify our response. For this purpose, a link to this Policy is placed in a clearly visible position on the Company's website.

Applications concerning the exercise of your rights shall be submitted:

• personally or by a person explicitly authorized by you via a notarized power of attorney at the management address of the Company in Sofia, Vitosha district, Manastirski Livadi residential area, 106 Bulgaria Blvd., Entr. D, Ap. 9.
• electronically by sending an email to: [email protected].
• by calling the phone number: 0700 20 202 863.

The exercise of rights is free of charge and covers all structured and unstructured data, as well as all databases maintained by the Company.

Exceptions to the deadline for satisfying rights and the free-of-charge principle are allowed for requests from the same client with a frequency greater than 3 times a year and requiring the mobilization of significant administrative resources on the part of the Company. In this case, we may charge a reasonable fee in view of the administrative costs incurred.

When the data subject submits a request by electronic means, the information shall be provided by electronic means where possible, unless the data subject has requested otherwise.

When the Company has reasonable doubts concerning the identity of the individual making the request to exercise their rights under this section, the directly responsible person must immediately consult the Data Protection Officer to perform client identification.

You should also keep in mind that the withdrawal of given consents does not affect the lawfulness of the processing of your personal data prior to the withdrawal. Despite a withdrawn consent, your personal data may be processed by the Company if another ground for data processing specified in item 5 is present.

You have the following rights:

a. Right to information

As a personal data subject, you have the right to receive information regarding the processing of your personal data, including the purposes of processing, the legal basis, storage periods, categories of recipients, and other relevant information under applicable legislation.

b. Right of access

You have the right to obtain confirmation as to whether or not we process your personal data and, if so, to gain access to it. We will provide you with a copy of the personal data undergoing processing. For additional copies, a reasonable fee based on administrative costs may be charged. When you submit a request electronically, the information will be provided in a commonly used electronic form, unless you have requested otherwise.

c. Right to rectification

You have the right to request the rectification of inaccurate or the completion of incomplete personal data concerning you.

d. Right to erasure ("right to be forgotten")

You have the right to request the erasure of your personal data when one of the following grounds applies:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• you withdraw your consent and there is no other legal ground for the processing;
• you object to the processing and there are no overriding legitimate grounds;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation.

Please note that this right may be limited when processing is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

e. Right to restriction of processing

You have the right to request restriction of the processing of your personal data when:

• you contest the accuracy of the data – for a period enabling verification;
• the processing is unlawful, but you do not oppose erasure;
• the data are no longer needed, but you require them for legal claims;
• you have objected to processing pending verification whether the legitimate grounds of "Seewines Logistics" EOOD override yours.

When restriction of processing is requested, we will inform you before the restriction of processing is lifted.

f. Right to data portability

You can request to receive the personal data we process about you in a structured, commonly used, and machine-readable format, as well as request its transfer to another controller where technically feasible. This applies only when:

• the processing of specific data is based on your consent or a contract; and
• the processing is carried out by automated means.

g. Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data based on legitimate interest. When your personal data are processed for direct marketing purposes, you have the right to object at any time to this processing without needing to state any reasons.

h. Right to lodge a complaint

If you believe that the processing of your personal data violates applicable legislation, you have the right to lodge a complaint with the supervisory authority – the Commission for Personal Data Protection, which is the supervisory body in the field of personal data protection at the address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., tel. 02/91-53-518, email: [email protected].

You can also contact us for assistance and additional information.

Exercising Rights

All requests, as well as additional clarifications and information related to the exercise of your rights, can be declared directly to "Seewines Logistics" EOOD by contacting us using the contact details provided in item 4 above.

We will respond to each request without undue delay and in any case within 1 month of its receipt. If necessary, this period may be extended by up to another 2 months, and you will be notified in due time.

The exercise of rights is free of charge, except in cases of manifestly unfounded or excessive requests.

This section applies to the processing of personal data by "Seewines Logistics" EOOD.

Last updated: June 16, 2026