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PRIVACY NOTICE ON PERSONAL DATA PROCESSING RELATED TO THE FACEBOOK AND INSTAGRAM PAGES OF THE MALL

This Privacy Notice aims to provide you with information about what personal data AP RETAIL I EOOD (hereinafter “APR”) processes during your visit to the official Facebook page of Shopping Center The Mall (hereinafter “the Shopping Center” or “The Mall”), namely: https://www.facebook.com/themall.bg/ and the Instagram profile of The Mall, as well as how these are used.

If you have any questions, please contact us via e-mail to administration@themall.bg or at: 115z, Tsarigradsko shose blvd., Mladost District, Sofia 1784, Republic of Bulgaria.

Should you wish to confirm whether AP Retail I EOOD processes your personal data, or to access any personal data APR might hold about you, please contact us at administration@themall.bg.

INTRODUCTION

APR is the owner of the Shopping Center The Mall and as such it manages the Facebook and Instagram pages of the Shopping Center.

The Mall is one of the most popular shopping centers in Bulgaria and among the most popular ones in our capital Sofia. With its unique design, architecture and over 200 stores, situated on a total area of over 66,000 sq.m. The Mall offers its customers an unforgettable shopping experience and variety of entertainments.

The Facebook and Instagram pages of The Mall (hereinafter the “Facebook and Instagram Pages”) are created to facilitate the communication between the management of the Shopping Centre and its consumers, for the promotion of games, events and other ongoings, initiatives and campaigns organized in the Shopping Center by APR or its partners including but not limited to its lessees. Our Facebook and Instagram Pages also aim to provide the consumers with the opportunity to share their opinions and assess the quality of the products and services offered at the Shopping Centre.

For the performance of the activities mentioned above APR processes personal data of the following main categories data subjects:

  • VISITORS OF THE FACEBOOK AND INSTAGRAM PAGES OF ТHE MALL
  • INDIVIDUALS PARTICIPATING IN GAMES ORGANIZED BY APR IN FACEBOOK AND INSTAGRAM
  • INDIVIDUALS ATTENDING EVENTS ORGANIZED AT THE PREMISES OF THE MALL

 

HOW, WHY AND WITHIN WHAT TIME LIMITS DO WE PROCESS YOUR PERSONAL DATA

AP RETAIL I EOOD with Unified Identification Code: 20019535, having its seat and management address at: 115z Tsarigradsko shose blvd., Mladost district, 1784, Sofia, Republic of Bulgaria, represented by Veselin Ivanov Glavchev or any other registered manager, in its capacity of Administrator, processes personal data as follows:

 

  • VISITORS OF THE FACEBOOK AND INSTAGRAM PAGES OF ТHE MALL

APR processes the following categories personal data of its Facebook and Instagram pages visitors:

  1. Data contained in their Facebook and/or Instagram profile, namely: first name and family name; gender; date of birth; email address, in case and to the extent that the visitor has shared publicly these data in his/her Facebook and/or Instagram profile and it is visible and accessible through APR’s profiles.
  2. Data published in the Facebook and/or Instagram Pages by visitors, namely: photos, videos, comments, personal messages and all other types of posts made by the visitor in our Facebook and/or Instagram Pages.

 

Purpose of processing, legal basis and processing terms

We use the data above only for the following purposes:

  • administration and management of our Facebook and Instagram Pages;
  • administration of any comments and complaints of our customers made through the Facebook and Instagram Pages.

APR processes these data on the basis of its legitimate interest to popularize and market activities, organized in the Shopping Center.

When you publish information or upload pictures/videos at the Facebook and/or Instagram Pages or post a comment to any of our posts, the information you have published and your Facebook and/or Instagram identification name are highly likely to become publically available. This information could be accessed by anyone who is visiting the Facebook and/or Instagram Pages.

APR is not responsible for the way these third parties use the information you posted on the Facebook and/or Instagram Pages.

When you participate in discussion on our Facebook and/or Instagram Pages (including through personal messages), we strongly recommend that you avoid sharing personal data that can be used to identify yourself directly, such as your name, age, address, and phone.

APR is not responsible for the protection of the information you have posted on the Facebook and/or Instagram Pages.

The processing term for these purposes is until the deletion of the specific article or post.

 

  • INDIVIDUALS PARTICIPATING IN GAMES ORGANIZED BY APR IN FACEBOOK AND INSTAGRAM

APR processes the following categories personal data of individuals who registered themselves to participate in games, organized by the Shopping Center (including such organized by the Shopping Center together with our partners) in the Facebook and Instagram Pages:

  1. for physical identity: first name and family name; gender; email address; telephone number
  2. data related to games’ participation: data contained in photos and/or videos, comments and other social media posts.

 

Purpose of processing, legal basis and processing terms

We may use the data above only for the following purposes:

  • administration of games and events, including contacting the winning participants, awarding prizes, conducting mandatory accounting and taxation if and to the extent that any of the above is applicable;
  • we may also (but not necessary) use the above personal data for direct marketing of any activities, initiatives and campaigns organized by the Shopping Centre and our partners, including but not limited to our lessees. This purpose for processing of your personal data also includes sending newsletters and various advertising messages for our activities.

APR processes these personal data on the basis of its legitimate interest to promote and advertise activities organized in the Shopping Center as well as on the basis of the APR’s contractual obligation to award prizes to the winning participants.

The processing of your personal data for these purposes is limited by the following terms:

  • for the purposes of administering the specific campaign/event your personal data will be processed for a maximum of 7 days after the expiration of the term for receiving the awards, marketing materials, discounts(including in paper form), etc.;
  • for direct marketing purposes, the data are stored in marketing databases and the data storage term is up to 10 years after the end of the marketing campaign in which the data were collected;
  • data contained in documents, necessary for the execution of contracts – up to six years after termination of the respective contract or until closure of dispute related procedures;
  • data contained in accounting registers and financial statements or data contained in documents subject to tax audits and needed for accounting purposes – 11 years.

Information how to exercise your right to object to direct marketing, can be found in the What Are Your Rights section below.

 

  • INDIVIDUALS ATTENDING EVENTS ORGANIZED AT THE PREMISES OF THE MALL

APR processes the following categories personal data of individuals who have attended events, organized at the Shopping Center:

  1. for physical identity: data contained in photos and/or videos

Purpose of processing, legal basis and processing terms

APR can post on its Facebook and Instagram Pages photos of events organized at the Shopping Center.

The processing of your personal data is based on the APR’s legitimate interest to promote the organized events and communicate their conduct and your data are used for this purpose only.

If you do not want photos/videos of you to be published on our Facebook and/or Instagram Pages, you have the right to object to the processing of these data and APR will ensure that the respective posts are removed from the Facebook and/or Instagram Pages.

The term of this processing is until the specific article or post is deleted.

Information on how to exercise your rights, including how to object, can be found in the What Are Your Rights section below.

WHO WE CAN SHARE YOUR DATA WITH

APR tends to organize increasingly interesting and interactive games, and for this purpose, APR may assign any of the above-mentioned activities of personal data processing to marketing agencies and IT service providers (including such providing software and hardware solutions) ensuring data protection and lawful processing. We may also provide personal information to our partners, if this is necessary for the provision of game prizes (including couriers and co-organizers of games).

WHAT ARE YOUR RIGHTS

If you are an individual whose data are processed by APR under any of the above circumstances, you have the following rights with this regard:

  1. You have the right to object to processing of your personal data for the purpose of:
  • promoting events organized by/at the Shopping Centre in our Facebook and/or Instagram Pages; and/or

If you make such an objection to a publication of photos/videos containing your personal data on the Facebook and/or Instagram Pages, we will remove the respective photos/videos and will no longer process these personal data for that purpose.

  • direct marketing, if you are addressee to such messages

If you make such an objection to our direct marketing messages we will no longer process your personal data for this purpose but none of our other services provided to you will be limited anyhow. However, in order to ensure that your objection is regarded, your data will be included in data base of objected data subjects.

 

  1. All data subjects have the following rights:
  • be informed what kind of personal data are processed by APR;
  • access and receive a copy of the processed data;
  • rectification or erasure of their personal data;
  • restrict the processing; and
  • data portability.

You may exercise any of your rights above by submitting a written application in any of the following ways:

  • via e-mail to administration@themall.bg
  • via letter addressed to: AP RETAIL I EOOD, UIC 20019535, Address: 115z , Tsarigradsko shose blvd., Mladost District, Sofia 1784, Republic of Bulgaria
  • you may also object to direct marketing in any other way indicated by APR in the respective direct marketing message – e.g. opt-out link provided in e-mail.

You also have the right to file a complaint concerning the processing of your personal data with the supervisory authority which is the Personal Data Protection Commission for the Republic of Bulgaria.

 

CONTENTS OF YOUR APPLICATION

Please note that your application for exercise of any of your rights should contain at least your names and other identification information, description of your request, preferred way of communication with you, address for correspondence, signature and date of the application.

If the application is signed by a proxy, the respective power of attorney should be attached to the application.

APR may contact you for additional information, if it needs to ensure your identity or further clarify your request.

EXCESSIVE DATA PROVIDED BY/FOR YOU

If we receive any personal data in excesses of what is needed for us to comply with our purposes above, we will delete this information immediately but not later than a month after its receipt.

 

PROTECTION OF YOUR DATA

To help protect the privacy of data and personally identifiable information, we maintain physical, personal, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees and personal data processors who need to know that information to provide benefits, goods or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.

USE OF THE FACEBOOK AND INSTAGRAM PAGES OF THE MALL

Like any Facebook and Instagram page/profile, ours also follows the general rules on personal data protection that Meta provides.

With this regard, we want to remind you that the information you share through your Facebook and Instagram account is automatically owned by Meta Platforms, Inc. or the Irish subsidiary Meta Platforms Ireland Limited. Meta has the right to process and store this information until you delete your account.

At the same time, Meta does not allow companies managing Facebook and Instagram pages to specify storage terms for the information you send them through messages. Thus, sending information via personal message to the Facebook and/or Instagram Pages of The Mall implies higher risks for your personal data as we could not guarantee where and how long your personal data are stored.

For this reason, each data subject has the freedom to provide us with information through alternative means which are under our control, for example by email to: administration@themall.bg

CHANGES AND UPDATES TO THIS PRIVACY NOTICE

As our organization, goods and services change from time to time, this Privacy Notice is expected to change as well. We reserve the right to amend the Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice at this Site. We may e-mail periodic reminders of our notices and terms and conditions and will e-mail our partners and hotel guests of material changes thereto, but you should check our website frequently to see the current Privacy Notice that is in effect and any changes that may have been made to it.

 

The present document represents privacy notice within the meaning of Art. 13 and Art. 14 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, and repealing Directive 95/46/EC (General Data Protection Regulation).