Privacy Policy

In the physical stores of “MUSALA TRADE” (located in Sofia, Bulgaria) and on the online store “MUSALA TRADE” (https://musalatrade.com), personal data of visitors and registered users are processed for the purposes of advertising, sales, and delivery of organic and natural products from around the world, as well as related activities.

The data controller (“Controller”) for the personal data processed by “MUSALA TRADE” stores and the “MUSALA TRADE” online store is DIAS SPORT.

The Data Protection Officer of the Controller will address all your questions regarding the processing and protection of personal data, as well as facilitate the exercise of your rights as a data subject. You can contact the Data Protection Officer directly at the email address: office@musalatrade.com.

Types of personal data we process:
I. We process the following categories of data on a contractual basis:

1. Data related to your profile on the “MUSALA TRADE” online store, created for you when entering into an informal contract with the Controller by accepting the General Terms and Conditions for the use of the website and the “MUSALA TRADE” online store – https://musalatrade.com (“Terms and Conditions”):

• First and last name;
• Email address;
• Password;

2. Data related to in-store orders made by you when purchasing goods from the physical store “MUSALA TRADE”:

• Invoice data – names, phone number, city, country, postal code, address;
• First and last name of the delivery recipient;
• Delivery address – country, city, postal code, address;
• Delivery phone number;
• Delivery method;
• Payment method;
• Payment status;
• Delivery status;

3. Data related to online orders through the “MUSALA TRADE” online store, made by you by entering into an informal distance contract with the Controller in accordance with the Terms and Conditions:• First and last name of the delivery recipient;

• Delivery address – country, city, postal code, address;
• Delivery phone number;
• Invoice data – names, phone number, city, country, postal code, address;
• Delivery method;
• Payment method;
• Order number;
• Payment amount;
• Payment status;
• Delivery status;

4. Data of loyal customers obtained when entering into an informal or formal contract with the Controller for issuing a “Loyal Customer” card, which grants discounts on orders:

• First and last name;
• Email address;
• Contact phone number;

II. We process the following data based on your consent, expressed through deliberate action – entering non-mandatory data and/or freely choosing specific options:

1. Data related to your profile on the “MUSALA TRADE” online store:

• Company name of a legal entity and/or the name of another personalized or non-personalized entity/organization;

2. Contact data and sent messages or published comments provided when filling out the contact form on the “MUSALA TRADE” online store or when sending us an email, conventional mail, telegram, fax, phone call, SMS, posting a comment, and other forms of communication and/or expression:

• First and last name;
• Email address;
• Phone number;
• Fax number;
• Address;
• Website;
• Content of the comment/message;

3. Data related to online orders through the “MUSALA TRADE” online store:

• Order history;

You can withdraw any of the consents provided above through your profile settings or as prescribed in this Privacy Policy. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

III. We process the following data on a legal basis, in accordance with local and union legislation:

1. Data related to your profile on the “MUSALA TRADE” online store:

• First and last name;
  Email address;
  Company name of a legal entity and/or the name of another personalized or non-personalized entity/organization;

2. Data related to online orders through the “MUSALA TRADE” online store:

• Delivery address – country, city, postal code, address;
• Delivery phone number;
• Invoice data – names, phone number, city, country, postal code, address;
• Delivery method;
• Payment method;
• Order number;
• Payment amount;
• Payment status and history;
• Delivery status and history;
• Order history;

3. Data related to in-store orders:

• Invoice data – names, phone number, city, country, postal code, address;
• First and last name of the delivery recipient;
• Delivery address – country, city, postal code, address;
• Delivery phone number;
• Delivery method;
• Payment method;
• Payment status;
• Delivery status;

4. Data of loyal customers:

• First and last name;
• Email address;
• Contact phone number;

5. Surveillance camera footage in physical stores “MUSALA TRADE”:

• Video recordings from cameras in “MUSALA TRADE” stores, server rooms, and the warehouse base;

IV. We process the following data based on legitimate interests:

1. Data related to your profile on the “MUSALA TRADE” online store:

• First and last name;
• Email address;
• Company name of a legal entity and/or the name of another personalized or non-personalized entity/organization;

2. Data related to in-store orders:

• Invoice data – names, phone number, city, country, postal code, address;
• First and last name of the delivery recipient;
• Delivery address – country, city, postal code, address;
• Delivery phone number;
• Delivery method;
• Payment method;
• Payment status;
• Delivery status;
• Video recordings from cameras located in “MUSALA TRADE” physical stores;

3. Data related to online orders through the “MUSALA TRADE” online store:

• Delivery address – country, city, postal code, address;
• Delivery phone number;
• Invoice data – names, phone number, city, country, postal code, address;
• Delivery method;
• Payment method;
• Order number;
• Payment amount;
• Payment status and history;
• Delivery status and history;
• Order history;

4. Data of loyal customers:

• First and last name;
• Email address;
• Contact phone number;

5. Surveillance camera footage in physical stores “MUSALA TRADE”:

• Video recordings from cameras in “MUSALA TRADE” stores, server rooms, and the warehouse base;

Purposes of Personal Data Processing

1. Your profile data in the “MUSALA TRADE” online store are processed for the following purposes:

• Fulfillment of the Administrator’s reporting obligation by recording legally significant certifying data in electronic protocols – technical logs;
• Delivery of ordered products;
• Providing support for technical issues, informing customers by operators in our contact center or in connection with complaints, tracking deliveries, payments, and other related matters;
• Verification through sending an email to ensure the security of access to your profile data and when changing your password;
• Authentication when logging into your profile;
• Sending messages via email and/or push notifications for the purposes of direct marketing and advertising with your explicit consent;
• Compliance with laws, court decisions, legal regulations, and decisions of authorities and regulatory bodies. This includes using your personal data for collecting and verifying accounting data and adhering to accounting reporting rules;

2. Data for on-site orders are processed for the following purposes:

• Delivery of ordered food and products;
• Informing customers by operators in our contact center or in connection with complaints, tracking deliveries, payments, and other related matters;
• Compliance with laws, court decisions, legal regulations, and decisions of authorities and regulatory bodies.
• This includes using your personal data for collecting and verifying accounting data and adhering to accounting reporting rules;
• Prevention of losses, as well as detection and prevention of abuses during order submission, registration, and delivery;

3. Data for online orders through the “MUSALA TRADE” online store are processed for the following purposes:

• Delivery of ordered food and products;
• Providing support for technical issues, informing customers by operators in our contact center or in connection with complaints, tracking deliveries, payments, and other related matters;
• Prevention and investigation of abuses related to online orders and their deliveries, as well as losses and fraud;
• Compliance with laws, court decisions, legal regulations, and decisions of authorities and regulatory bodies. This includes using your personal data for collecting and verifying accounting data and adhering to accounting reporting rules;
• Analysis of statistical data obtained after anonymizing your data;

4. Contact and sent message or published comment data are processed for the following purposes:

• Identifying you as the sender/author of a message or published comment;
• Communicating with you;

5. Data of loyal customers are processed for the following purposes:

• Fulfilling contractual obligations for applying discounts to the price of orders;
• Verifying and identifying the status of a “loyal customer” and the associated rights;

6. Video surveillance data in physical stores of “MUSALA TRADE” are processed for the following purposes:

• Monitoring incidents and violations;
• Preventing and reporting crimes in our stores;

Third parties with access to personal data, in connection with their activities and services provided jointly with “MUSALA TRADE”:

1. We use the following cloud service providers, hosting, reverse proxy, CDN, servers/clusters, and colocation:

• “NS 1” Ltd., with EIK (Company Identification Number): 175018740 – they provide hosting and cloud services for the needs of “MUSALA TRADE”, using the services of subcontractor “TELEPOINT” Ltd., with EIK: 175424163. You can familiarize yourself with their privacy policy at the following address: NS 1 Privacy Policy
• “TELEPOINT” Ltd., with EIK: 175424163 – they perform colocation of servers used by “MUSALA TRADE” and are subcontractors of “NS 1” Ltd., through their data center in Sofia at 122 Ovche Pole Street. You can familiarize yourself with their privacy policy at the following address: TELEPOINT Privacy Policy

2. Consultants and providers in various fields for the purposes of protecting our legitimate interests in maintaining and improving the quality of the services we provide, complying with legal requirements, protecting legal rights and interests in judicial, pre-trial, and administrative proceedings. Those we regularly use include:

• Courier companies for delivery: Econt, Speedy, Rapido, Aramex, DHL, and TNT;

3. State authorities and institutions in connection with checks conducted by them in accordance with legal requirements and restrictions;

• Regarding private entities, we require and monitor the listed third parties to implement all technical and organizational measures to protect this data.

The data is processed for the following periods:

1. Data provided on a contractual basis:

• Profile data – until 5 years after the date of the last online order or, in the absence of an order, until deletion of the profile through the functionalities of the e-store or until 5 years after the date of your last login, whichever is earlier. Profile data is related to and determines the data for online orders, which determines the applicable deadline. In the absence of an order, based on the informal contract for you as a user, there is a legal expectation for the use of the profile, and therefore, we provide you with the functional option to delete your profile at any time before the expiration of the final five-year period.
• Online order data – until 5 years after the date of the specific order. The period is determined based on the statute of limitations for claims.
• Loyalty customer data – until termination of the contract.

2. Data related to the collection and verification of accounting data and compliance with accounting reporting – accounting records and financial reports, including documents for tax control, audit, and subsequent financial inspections, are kept for 10 years, starting from January 1 of the reporting period following the reporting period to which they relate; all other carriers of accounting information – three years, starting from January 1 of the reporting period following the reporting period to which they relate;

3. Data provided on the basis of consent – until its withdrawal, in the manner in which it was provided, including through the functionalities of the e-store or blog, or through deletion, and with regard to the e-store – also until 5 years after the date of your last login, whichever is earlier; Your data on the online store are related to the comments you have published under articles and videos, and therefore represent the exercise of your constitutional right to freedom of expression in the format and content chosen by you. Therefore, a specific deadline is not determined after which their processing is terminated; instead, you are provided with the opportunity to remove the published content by exercising your rights as a data subject in accordance with the prescribed form and method in this Policy. When the content of a specific comment contains offensive words or phrases, defamatory, and/or damaging the reputation of the Administrator’s claims, the Administrator has the right, based on its own or third-party legitimate interests, to remove the comment content from its websites.

4. Video surveillance data in physical stores “MUSALA TRADE” – video recordings are stored for up to 60 days from their creation;

After the specified period expires, the data is deleted and cannot be restored or used further. The data is not deleted but continues to be processed only for the purposes of protecting our legitimate rights and interests or in compliance with our legal obligations, in the event that, at the date of expiration of the specified period, there is pending judicial, administrative, and pre-trial proceedings or ongoing investigations regarding abuses brought to our knowledge, complaints, and potential violations – until their conclusion.

Your Rights Regarding Your Personal Data

1. Right of access, including the right to a copy of the data being processed:

• You have the right to request information about your personal data that we store at any time. You can contact us, and based on a written request and verification of your identity, the data will be provided to you;

2. Right to correct inaccurate personal data:

• You have the right to request the correction of your personal data if they are incorrect, including the addition of incomplete personal data. You can do this through your profile in the mobile application or by contacting us with a written request, after proper verification of your identity;

3. Right to erasure (“Right to be forgotten”) in the following cases:

• No longer necessary for processing;
• Withdrawal of consent when processing is based on consent;
• Illegal data processing;
• Legal obligation to erase;

The right to be forgotten is not an absolute right and may not be respected in cases provided for by law or due to a lack of proper verification of your identity.

4. Right to restrict processing when:

• The accuracy of the data is contested, for the period during which their accuracy is verified; or
• Data processing is without a legal basis, but instead of deleting them, you want their processing to be restricted; or
• When data is needed to establish, exercise, or defend your legal claims; or
• An objection to the processing of data is pending, awaiting verification of the Administrator’s legal grounds.

In case of correction, deletion, or restriction of processing, we will inform each recipient to whom the personal data have been disclosed, unless this is impossible or requires disproportionate effort.

5. Right to data portability, whereby:

• We provide the data directly to you; or
• Upon your request and technical feasibility, the data is provided to another administrator of your choice;

6. Right to object to processing based on legitimate interests:

• You have the right to object to the processing of your personal data based on the legitimate interests of the Administrator or a third party. The Administrator will not continue to process your personal data unless it can demonstrate compelling legal grounds for doing so that override your interests and rights or due to legal disputes and other procedural and non-procedural actions necessitate it.

7. Right to object to direct marketing:

• You have the right to object to receiving marketing messages, including profiling and analysis for the purposes of direct marketing.

8. Right to lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work, or the place of the alleged infringement if you believe that the processing of your personal data violates the provisions of Regulation (EU) 2016/679. In the territory of the Republic of Bulgaria, where the headquarters of the Administrator and the physical stores “MUSALA TRADE” are located, the supervisory authority is the Commission for Personal Data Protection.

The above rights are exercised through a written request in a form determined by the Administrator, which you can obtain at the Administrator’s headquarters or electronically upon request to the Data Protection Officer and by completing the electronic form received with the necessary documents attached. If you have registered with “MUSALA TRADE” you can use the automated form for exercising data subject rights, located on your profile in the e-store.
You will receive a response to your request within one month from the receipt of your written request.

Methods used for automated decision-making, including profiling

We do not use automated algorithms and/or profiling.