Personal Data Protection

We care about the confidentiality of your personal data!

This website, wingo.bg, is owned by Winners Group EOOD (the Company), and in administering it the Company complies with the provisions of the Personal Data Protection Act and the related legislation, including Regulation (EU) 2016/679 (“GDPR”).

This document, in addition to the Privacy and Personal Data Protection Policy (the Policy), is intended to inform you of the manner in which Winners Group EOOD processes the information provided by users through the website wingo.bg and through the use of the services offered on the website wingo.bg. If you do not agree with what is described in this document and in the Policy, please do not agree to use our online services.

This document applies to the use of all services offered by wingo.bg and our mobile applications. It does not apply to third-party applications or software that integrate with the services of wingo.bg or with other third-party products/services.

User data collected and processed by the Company through wingo.bg

We collect personal identification information from users in a variety of ways, including, but not limited to, when users visit our sites, register on the sites, and in connection with other activities, services, features or resources that we make available on our sites. Users may be asked for their name, email address, postal address or payment information. We collect personal identification information from users only if they voluntarily provide us with such information. Users may always refuse to provide personal identification information, except where this may prevent them from engaging in certain site-related activities. We will never sell personal information to third parties and will not use your name or company name in any marketing statements without written permission.

We collect non-personal identification information about users whenever they interact with our websites. Non-personal identification information may include the browser name, the type of computer and technical information about users’ means of using our sites, such as the operating system and the internet service providers used, and other similar information.

Other information

Metadata – when users use our services, metadata is generated to provide additional information about the way in which users interact with our sites.

Device information – wingo.bg collects information about the computer, phone, tablet or other devices you use to access our services. This device information includes your connection type and settings when you install, access, update or use our services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers and crash data. We use your IP address and/or country preference to approximate your location in order to provide you with a better service. How much of this information we collect depends on the type and settings of the device you use to access the services.

Location information – wingo.bg will obtain this information from users during registration, as well as from our partner providers, in order to understand your approximate location.

How the data provided is used

To personalise the user experience, we may use aggregated information to understand how our users as a group use the services and resources provided on our site. To improve our site: we continually strive to improve the web services we offer, based on the information and feedback we receive from users.

Your information helps us to respond more effectively to your customer service requests and support needs. The email address that users provide will be used only to respond to their enquiries and/or other requests or questions, and to send users information that they have agreed to receive (if they give such consent) on topics that we believe will be of interest to them. If a user decides to join our mailing list, they will receive emails that may include company news, updates, related product or service information, etc.

A user may at any time opt out of receiving future emails; unsubscribe instructions are provided at the bottom of each email. We will always ask for consent before publishing any information for promotional purposes.

Sharing and disclosure of information

In addition to the purposes of processing, storing and using the data that are exhaustively set out in the Policy, the Company will disclose or share information about users only for the following purposes:

• upon request by an authorised body, it may disclose the user’s information;
• to disclose information about the user in order to investigate, prevent or take action against unlawful activities, suspected fraud or situations that pose a threat to persons;
• to share information about the user with other third parties where we have the user’s consent to such disclosure;
• receiving information when users authorise third-party services to integrate with our services. An example of such a service is the use of Google credentials to sign in to the user account on wingo.bg. We will receive the user’s names and email address, as permitted by the user’s settings in Google. The information we receive when users connect or integrate our services with a third-party service depends on the settings and privacy statement applied by that third party. We recommend that users review in detail the privacy settings of all third-party services in order to understand what types of data may be disclosed to or shared with us by those third parties;
• we work with third parties providing payment information, invoicing and technical services in order to deliver solutions to users. We may share information about users with those third parties in connection with their services;
• the activities of wingo.bg require our employees to have access to the systems that store and process user data. The purpose of this is to provide better service and to resolve potential problems. For example, in order to diagnose a problem that users may have with the services of wingo.bg, our employees may need access to your user data. All employees are prohibited from viewing user data for any reason unless it is absolutely necessary.

Deletion of data

Complete deletion of the data you have provided to us through the website wingo.bg will take place after 90 days. Users may at any time request the deletion of their personal data. If such a request is made, the data will remain in archives that we maintain, so as to ensure that we do not retain data in backup copies for more than 90 days. Users may send a request for the deletion of their data to: nonlife@winnersgroup.bg. If, however, users require the immediate deletion of their data, we urge users to delete their account, as this will help to initiate the process.

Retention of data

We store data as set out in the Policy and apply the data protection mechanisms described therein.

How long we retain the information we collect from you depends on the type of information, as described in detail in the Policy and below.

User account information: we retain user information for up to 90 days after the account has been deleted. We do so for the following reasons:

• Where the user’s account has been compromised and deliberately deleted, wingo.bg will help to maintain and restore the data so that the problem can be resolved;
• The account has been deleted by the user by mistake. In such a case, wingo.bg will be able to restore the users’ data.
• Where the user initially requested the cancellation of their account but later changes their mind. The user will be able to restore all data if the account is reactivated within 90 days of the initial deletion.

Marketing information

If users have opted in and given their consent to receive marketing, promotional and reminder emails from wingo.bg, we retain information about users’ marketing preferences unless we have been specifically asked to delete it. We retain information obtained from “cookies” and other tracking technologies for a reasonable period of time from the date on which such information was obtained.

Children

We do not collect personal information from children under the age of 14. If we learn that we have collected personal information of a child under the age of 14, we will take steps to delete the information as soon as possible. If parents and/or legal representatives of children discover that children have provided their data on wingo.bg, please contact us using the contact details provided. We will delete the information as soon as possible.

Contact details

If you wish to contact us on matters relating to the protection of personal data on wingo.bg, please send us a message at the email address elizabet.darwish@winnersgroup.bg or write to Winners Group EOOD, Vertigo Business Tower, office 2.2, 109 Bulgaria Blvd, Sofia, winnersgroup.bg, for the attention of the Data Protection Officer.

Declaration – consent to the collection and processing of personal data

I hereby declare that:

• I have been informed of the need to process the personal data provided by filling in data on wingo.bg for the provision of services by Winners Group EOOD (as an insurance broker) in accordance with my request and needs, and for the performance of all obligations under the pre-contractual and contractual relations with Winners Group EOOD, and I am aware that any refusal to provide the personal data requested as mandatory will render the Broker unable to provide the requested service and/or to perform its obligations as an insurance broker under the Insurance Code, for which reason it may refuse to enter into legal relations with me;
• I have been informed of my rights under the legislation in force in the Republic of Bulgaria in the field of personal data protection (including my rights under Regulation (EU) 2016/679 and under the Personal Data Protection Act (PDPA)), as well as of the types of personal data processed by Winners Group EOOD (as an insurance broker) and of the purposes for which the personal data provided will be processed;
• I have been informed of the Privacy Policy applied by Winners Group EOOD (as an insurance broker) and of the measures applied for the protection and confidentiality of personal data, information on which has been provided to me on a durable medium, and I am aware of the possibility of accessing it in full in electronic form on the websites winnersgroup.bg and wingo.bg;
• I am aware of the Broker’s obligation to store the personal data provided in good faith, in a manner that does not allow the data to be disclosed to random or unauthorised persons;
• I am aware of the period for which my personal data will be stored and of the criteria used to determine that period;
• I have been notified of my right to request from the controller access to, rectification or erasure of my personal data or restriction of their processing, as well as my right to object to processing and the right to data portability;
• I have been notified that the provision of my personal data is a statutory/contractual requirement necessary for entering into a contract, and of the possible consequences if such data are not provided;
• I am aware of my right to lodge a complaint with the supervisory authority in the event of a breach of my rights;
• I have been notified of my right to object to the processing of my personal data for the purposes of direct marketing, which includes profiling to the extent that it is related to direct marketing;
• I have been notified that, for the performance of my contract, information relating to my personal data may be provided to insurance companies, as well as to third parties, only where this is necessary for the Broker to perform its insurance intermediation services.