I. Introduction
GERTOM Ltd. with manager Gergana Hristova, management address Sofia, Druzhba District, Block 280, Entrance A, object address Laser Esthetic Center IRIDA: Sofia, Druzhba District, Block 285, Entrance A, Office 5.2, contact phone 0878856671, email: info@iridacenter.bg – respects the privacy of its clients and guarantees the maximum protection of their personal data. This Privacy Policy is drafted and based on the current Bulgarian and European legislation on the protection of personal data.
This Privacy Policy regulates the processing of personal data of individuals or representatives of legal entities of our clients or potential clients, as well as users of our website: www.iridacenter.bg (“the Website”), in relation to the provided services, including those available on the Website.
This Privacy Policy sets out the rules we follow when processing personal data that we collect from you or for you, or that you provide to us. This Privacy Policy does not affect, limit, or revoke your rights under the Personal Data Protection Act ("PDPA") or other applicable legislation.
If you have any questions or comments regarding this Privacy Policy, please contact us at: info@iridacenter.bg
Please read this Privacy Policy carefully before using the Website or providing your personal data, whether electronically via the Website or on paper, as by providing your personal data, you agree to its terms. If you do not wish us to process your personal data as described in this Privacy Policy, please do not provide it. Providing personal data is voluntary, in order to use certain services provided by us and to access the Website. Please note that in some cases, we will not be able to provide you with the service and/or sell the product you requested if you do not provide us with the necessary information.
Please also note that in certain cases, your consent for processing personal data may not be required if we have another legal basis, such as compliance with statutory obligations.
II. Who processes and is responsible for your personal data?
GERTOM Ltd. is a commercial company registered in the Commercial Register with the Agency for Registration, with UIC 208148217, which collects, processes, and stores your personal data in accordance with this Privacy Policy.
You can contact us using the following details:
Management address: Sofia, Druzhba District, Block 280, Entrance A,
Phone: 0878856671
Email: info@iridacenter.bg
Data Protection Officer: Gergana Hristova
III. Categories of personal data processed
1. Laser Esthetic Center IRIDA may process publicly available personal data and/or personal data provided by you. The main types of personal data processed are:
(a) Personal identification information (including name, email address, communication language, and others);
(b) Contact data (including email addresses, phone numbers of you or a person you specify as a contact, and others);
(c) Financial information (bank account, etc.);
(d) Representative information (legal representative or proxy of a corporate client);
(e) Profile data from the Website (including name, postal and email addresses, phone number, date of birth, etc.);
(f) Data for concluding contracts for sales, dealership, wholesale sales, deferred payments, etc. with natural or legal persons (such as names, PIN, etc.).
2. Laser Esthetic Center IRIDA may process data created and generated by the Laser Esthetic Center IRIDA during the provision of services:
(a) Data on the used electronic device, type of device, operating system, IP address, location;
(b) Data on preferred goods and services;
(c) Data from communication between us and you, habits, preferences, satisfaction with our services (activity in using the services, complaints, inquiries, etc.);
(d) Information about visits to the Website and use of the Website, including operations and usage history;
(e) Data obtained when fulfilling obligations arising from statutory provisions (i.e., data from inquiries, regulations, investigative authorities, notary, tax authorities, court, bailiff);
(f) Video recording when visiting stores or the central office;
(g) Video recording or photography made in accordance with previously announced terms for participation in games and/or other promotional campaigns organized by Laser Esthetic Center IRIDA.
3. In order to ensure the proper performance of services and the fulfillment of obligations under client contracts, Laser Esthetic Center IRIDA has the right to process any information available in public registers (including public databases and information published on the internet) as well as information received from third parties regarding clients.
4. Laser Esthetic Center IRIDA has the right and the obligation to verify the accuracy of the personal data stored in the database and, for this purpose, may require you to verify and, if necessary, correct or confirm the accuracy of your data.
5. Different types of personal data may be processed independently or in combination with each other.
IV. Purposes and legal grounds for processing personal data
1. Processing of personal data necessary for the conclusion or execution of contracts with us or in connection with preparation for entering into contracts with us.
Laser Esthetic Center IRIDA processes your data for the following purposes:
(a) Identifying a client when: entering into a new or amending an existing contract with us; clarifications about the services used; performance of a concluded contract.
(b) Preparing proposals for entering into contracts, sending pre-contractual information and a draft contract; managing pre-sale activities;
(c) Data received from you in the performance of obligations arising from contracts with you or a company you represent, exercising rights, and ensuring the performance of contracts by our clients;
(d) Administration and response to customer complaints/inquiries/claims/complaints; returning sums and goods; replacement of a product or service;
(e) Technical assistance for access to our Website.
(f) Identification and validation of the legal age;
(g) Payment of obligations, deferral of due amounts; management of debt collection;
(h) Updating offers to dealers; sharing important information regarding changes in our policies and other administrative information;
(i) Management and administration of activities, management of payments.
2. In fulfillment of its statutory obligations, Laser Esthetic Center IRIDA processes your data for the following purposes:
(a) Issuing invoices;
(b) For tax and insurance control by the relevant competent authorities;
(c) Fulfillment of obligations related to distance sales, off-premises sales, as provided in the Consumer Protection Act;
(d) Providing information to the Personal Data Protection Commission in connection with obligations under the personal data protection legislation – Personal Data Protection Act, Regulation (EU) 2016/679 of April 27, 2016, and others;
(e) Obligations under the Accounting Act and the Tax and Insurance Procedure Code and other related regulations in connection with the proper and lawful bookkeeping.
3. Laser Esthetic Center IRIDA processes the relevant data provided with explicit consent from the client for their processing for the following purposes:
(a) Direct marketing of products and services;
(b) Participation and management of surveys, games with prizes, promotional campaigns;
4. Processing necessary for the legitimate interests of Laser Esthetic Center IRIDA.
(a) For the protection and security of the property, interests, and safety of Laser Esthetic Center IRIDA, its visitors, and employees, Laser Esthetic Center IRIDA uses video surveillance equipment.
(b) Evaluation and establishment of user satisfaction, as well as the effectiveness of advertising offered to you and others, and to meet your expectations by presenting relevant advertising;
(c) Analysis of data on purchasing history, preferences, and customer behavior;
(d) Ensuring quality customer service;
(e) Information on the performed procedures and results, booking appointments for procedures, and requirements for them.
(f) Preventing health problems such as allergies or other health issues that could be negatively affected by the procedures performed.
V. Categories of third parties who have access to and process your personal data
(a) Transport/courier companies, postal operators for the fulfillment of our contractual obligations, sending correspondence and communications, in relation to the contract between us, sending purchased goods;
(b) Persons who, on behalf of Laser Esthetic Center IRIDA, maintain the equipment and software used to process your personal data;
(c) Debt collection service providers, notary, lawyer, bailiff, or other third party, if the client has breached an obligation arising from a contract with us;
(d) Banks processing payments made by and to you;
(e) Our external legal advisors.
VI. Your rights regarding the processing of your personal data
According to the current legislation, you have the following rights regarding the processing of your personal data:
1. Right to access – You have the right to request confirmation as to whether your personal data is processed by us and to receive information regarding the personal data we store.
2. Right to correct – You have the right to request correction of inaccurate or incomplete personal data.
3. Right to deletion – You have the right to request the deletion of your personal data when there are no legal grounds for processing them.
4. Right to restriction of processing – You have the right to request restriction of processing of your personal data.
5. Right to object – You have the right to object to the processing of your personal data based on legitimate interests.
6. Right to portability – You have the right to request to transfer your personal data to another controller.
7. Right to withdraw consent – If the processing of personal data is based on your consent, you have the right to withdraw it at any time.
In case you wish to exercise any of these rights, please contact us at the contact details listed above.
VII. Security of your personal data
Laser Esthetic Center IRIDA takes appropriate technical and organizational measures to ensure the protection of your personal data from unauthorized access, loss, misuse, alteration, or disclosure.
VIII. Retention period for personal data
Your personal data will be kept for a period not longer than necessary for the purposes for which they are processed or as long as required by applicable laws.
IX. Changes to the Privacy Policy
This Privacy Policy may be updated or amended at any time in accordance with applicable legislation. You will be informed of any changes through a notice on the Website or through other communication channels.