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Privacy Policy

General Provisions
Changes from March 2024

We have updated our Privacy Policy. These changes are intended to provide greater clarity regarding how we use your personal information and to consolidate previously separate notices for the EU and the rest of the world into one document.

Data Controller Information:
Culligan Bulgaria EOOD, with UIC 201622594, headquartered at 3 Sarantsi St., Sofia 1517, represented by Managing Director Kamelia Yordanova Toneva.

This Privacy Policy governs the relationship between the Company and the data subjects regarding the personal data processing activities described herein.

Contact Information:
Email: info@purewater.bg
Phone: 028741046

In this Privacy Policy, you will find detailed information about the activities we perform in processing your personal data.

DEFINITIONS

"Site" means https://www.purewater.bg and all its subpages and subdomains.

This notice defines the basis on which we will process all personal data we collect from you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will handle it. It is important that the personal data we hold about you is accurate and up-to-date. Please inform us if your personal data (e.g., name or address) changes during your relationship with us so that we can update our records.

This Privacy Notice explains:

  • Who we are;
  • Your rights;
  • What personal information we collect;
  • How we use your personal information;
  • With whom we share your information and why;
  • How we protect your information;
  • How long we retain your information; and
  • How to contact us.

In this document, "We," "Us," and "Our" refer to Culligan Bulgaria EOOD, with UIC 201622594, headquartered at 3 Sarantsi St., Sofia 1517, represented by Managing Director Kamelia Yordanova Toneva.

1. Who We Are

For the purposes of data protection laws, we are a data controller and a proud member of the Culligan International Group ("Culligan"). Culligan is a global leader in providing cleaner and softer water through innovative, sustainable solutions and unparalleled service across all sectors.

With over 13,000 team members and 1,000 dealers in 90 countries, Culligan's 35+ brands serve more than 50 million customers annually, sharing the mission to provide better water to consumers everywhere they need it—at home, at work, or on the go.

This Privacy Notice covers all structures within the Culligan Group. However, these companies may have their own privacy notices, which may supplement this document. If you are an EU resident (or from a country that has adopted local law implementing or adopting the GDPR), this includes the European General Data Protection Regulation (GDPR) or applicable local law implementing the GDPR.

We have also implemented an intra-company agreement that includes standard contractual clauses approved by the European Commission to ensure that all personal data transfers to any Culligan entity are protected at the same level required by European data protection law.

2. Your Legal Rights

You have the right to ask us:

  • Whether we process your personal information and for what purposes (the right to be informed) – this is done through "fair processing information" such as this Privacy Notice;
  • For a copy of the personal information we hold about you (right of access);
  • To update or correct your personal information (right of rectification);
  • To delete your information (right of erasure); and
  • To restrict the processing of your personal information where appropriate (right to restrict processing).

In certain circumstances, you also have the right:

  • To object to the processing of your personal information (right to object);
  • To object to automated decision-making and profiling (right not to be subject to automated decision-making, including profiling); and
  • To request your information be provided to a third party in a commonly used, machine-readable format (right to data portability).

Exercising Your Rights
For information regarding your individual rights, including how to correct, restrict, delete, or make changes to your personal information, or if you wish to request a copy of the personal information we hold about you, please contact us here.

Fees
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). We may charge a reasonable fee if your access request is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request under these circumstances.

What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to a person who has no right to receive it. If you are not satisfied with our response or for more information about your data protection rights, you can visit the website of your local data protection authority.

3. What Personal Information We Collect

"Personal data" means any information about an individual by which that person can be identified, directly or indirectly. We will collect personal data related to you that you provide when applying for a job. This information includes personal data such as your full name, email address, phone number, job title, department, preferences, and our communications with you.

Information You Provide
We will collect personal data related to you that you provide when:

  • Filling out the contact form on our website;
  • Contacting us for products and/or services;
  • Subscribing to any of our services;
  • Signing up for a free trial;
  • Logging into our portal and/or any of our applications;
  • Responding to a survey;
  • Requesting to download guides or other resources from our website;
  • Attending product events;
  • Contacting us through our social media channels;
  • Opting-in (consenting) to receive marketing communications from us; and/or
  • Applying for a job.

This information includes personal data such as your full name, email address, phone number, job title, department, preferences, and our communications with you.

Information We Collect About You
The type of personal information we collect depends on the purpose for which it is collected and may include:

  • Information to help identify and manage your relationship with Culligan (e.g., name, address, email address(es), postal code, phone number(s), title, gender);
  • Account information with us (e.g., account number, customer ID, previous engagements with us, personal preferences, order history, etc.);
  • Copies of documents (e.g., statements, letters, invoices, correspondence);
  • Economic and financial information (e.g., payment card numbers, bank details, payment history, loan-related information such as pay slips, proof of address, etc.);
  • Audio and visual information when we record our interaction with you or when you visit any of our premises (e.g., call recordings or CCTV);
  • Marketing/communication data (e.g., information related to marketing and external communications, such as marketing campaigns, opt-in preferences);
  • Lifestyle information (e.g., water consumption, mineral/vitamin supplements, information needed to choose appropriate equipment for your home, such as the number of people living in the home, tap water consumption, electricity consumption);
  • Information about your website visit, IP address used to connect your computer to the internet, login information, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform; including full clickstream data to, through, and from our website (including date and time), products viewed or searched for, page response times, download errors, visit duration to certain pages, interaction page information (such as scrolling, clicks, and mouse movements), and phone numbers used to contact our customer service number;
  • Employment and education information (e.g., employer details, relevant professional qualifications, etc.).

We may also collect information about you from other sources, such as:

  • Other companies within the Culligan Group;
  • External third parties (e.g., credit agencies for verifying your identity and financial stability, event coordinators where we have a presence); and
  • Cookies (Cookies are small text files placed on your computer by websites you visit. They are widely used to make websites work more efficiently and to provide information to website owners).

4. How We Use Your Personal Information

We will only use your personal data when the law allows us to and for the purposes stated in this notice. These purposes include:

  • When you provide your consent;
  • When necessary for the performance of a contract we have or are entering into with you;
  • When necessary to comply with a legal or regulatory obligation;
  • For our legitimate interests or those of a third party, provided that your interests and fundamental rights and freedoms do not override these interests.

We may use your personal data to provide and administer the services you have requested and/or to respond to your inquiries. When you do not provide certain information, we may not be able to process your order.

 

We may also use your personal data to fulfill our legal obligations, handle complaints, and enforce our terms and conditions.
We may use your personal data for our legitimate business interests, which include security, improving our Website, enhancing our solutions and services, general marketing purposes, and internal monitoring and reporting. However, we will not do this if our interests outweigh your rights and freedoms.
We process your information for the following purposes:

Below, we’ve outlined the ways in which we plan to use your personal data:
To fulfill our contract with you and maintain our relationship. This includes the following:

  • To register you as a potential or new client;
  • To process and deliver your order, including managing payments, fees, and charges, and collecting and recovering any money owed to us;
  • Recording specific needs or settings that you may have or may need from time to time, such as text-to-speech, large fonts, or medical reasons, to help you better understand our products and services;
  • As part of our recruitment activities.

To comply with legal and regulatory requirements. These include:

  • Verifying your identity for regulatory purposes;
  • Detecting and preventing fraud;
  • To fulfill our data protection obligations.

For specific business purposes, to provide you with appropriate products and services and a secure experience. Our business purposes include:

  • Managing our relationship with you, including notifying you of changes to our terms or Privacy Notice, or requesting feedback or participation in surveys;
  • Sending newsletters, informing you about new products or services, recommending other goods or services that may interest you, and inviting you to our events;
  • Administering and protecting our business and our Website (including troubleshooting, data analysis, testing, system maintenance, reporting, and data hosting);
  • Providing you with relevant Website content and advertisements and measuring or understanding the effectiveness of these ads;
  • Using data analytics to improve and develop our Website, products/services, marketing, customer relationships, and experience;
  • Monitoring or recording communications (such as phone or video calls) with you to resolve inquiries or issues, as well as for training and quality purposes.

We may use artificial intelligence and Internet of Things technologies, including machine learning, to carry out some activities. When this is the case, the results will be subject to human oversight and review, and we will not include your personal data in any data analytics with a third-party model without informing you. When using publicly available models for general business purposes, we will give you the option to be anonymized or excluded from the provided data. We will always strive to use AI technologies in compliance with legislation, regulatory guidelines, and government policy.

Change of Purpose
We will use your personal data only for the purposes for which we collected it unless we reasonably believe that we need to use it for another reason and that reason is compatible with the original purpose. We may also process your personal data as part of an acquisition or sale. If this occurs, you will be notified of any change in processing or data controller resulting from this activity.
You have the right to object to the processing of your personal information for some of the business purposes listed above, but if you do so, it may affect our ability to provide you with some or all of our services. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent in compliance with the above rules where this is required or permitted by law.

5. How We Store Your Information
We are committed to ensuring the confidentiality of the personal information we hold and continue to review our security control mechanisms and related policies and procedures to ensure that your personal information remains protected.
When we contract with third parties, we impose appropriate security, confidentiality, and data protection obligations to ensure that personal information is stored securely and to prevent unauthorized or accidental access, processing, copying, modification, deletion, loss, or use.
If we work with third parties in countries outside the UK or EU, we ensure that these are countries that have been confirmed by the UK government and the European Commission to have adequate levels of data protection, or that the organization receiving personal data has provided adequate safeguards and agreed to treat your information with the same level of protection as we do.
We also use international data transfer agreements in the UK and EU Standard Contractual Clauses for transfers outside the UK or the European Economic Area.
In limited circumstances, employees outside our usual workplaces may have access to the data. In these circumstances, we ensure that appropriate information security measures are in place to protect your information.

6. Who We Share Your Information With and Why
We will not sell your personal data and generally do not provide it to third parties, but there are some exceptions. We may share your personal data in the following ways (as applicable):

  • Companies within the Culligan Group:

    • For administrative, analytical, and statistical purposes;
    • For testing information systems managed by our companies;
    • To create a consolidated overview of our relationship with you to improve the services we can offer you;
    • To send marketing communications you have opted (agreed) to receive, or that we think may interest you based on the services you receive from us or other companies in our group;
    • To provide business communications relevant to our relationship with you;
    • To address complaints and enforce data subject rights (such as the right of access).
  • Companies appointed by Culligan (these third parties may be based in countries outside the UK or EU):

    • With third parties or service providers that provide additional data about you to improve our ability to design and develop new products and services that can be marketed and sold, meeting the needs of our identified user groups;
    • With debt collection agencies to track and collect debts;
    • With payment service providers to enable payments to be made;
    • With our accountants to prepare tax returns and support mandatory reporting;
    • With legal or regulatory advisors or auditors appointed by us;
    • With IT and information security providers;
    • With third parties or service providers to conduct market research on our behalf, to help us improve and develop the products and services we provide to you and other customers;
    • With a potential buyer (or their advisors) for due diligence purposes if we consider selling all or part of our business. For example, in the case of a merger, acquisition, sale, change of control, or liquidation of Culligan or part of its business (or in anticipation of such an event), we may share your personal data as part of this transaction where necessary to fulfill our obligations in this Notice.
  • Organizations and parties appointed or authorized by you.

  • Statutory authorities

    • To prevent or detect crime and/or apprehend or prosecute criminals, we may share any personal data we collect with law enforcement agencies, other public or private sector agencies, government or representative bodies in accordance with relevant legislation, to comply with a legal obligation or as permitted by law. This will include public bodies, insurance companies, financial companies, and/or other agencies.

7. Data Retention
We will retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Where processing is based on your consent, we will process your personal data only until you withdraw your consent.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, as well as applicable legal requirements.
We will take all reasonable steps to ensure that your personal data is processed securely and in accordance with this notice.

8. How to Contact Us
If you have any questions about this notice, need more information about our privacy practices, or wish to file a complaint regarding the way we have handled your personal data, you can contact our Data Protection Officer, who will investigate the matter.


Authority contacts

  • Website: https://www.cpdp.bg/
  • phone number: 02/91-53-518
  • email: kzld@cpdp.bg
  • address: Sofia 1592, 2 „Prof. Tsvetan Lazarov blvd”