Evo Radio Ltd
Personal data protection policy
In effect as of: 13. 01. 2022
Please, read carefully this Personal data protection policy before using the platform’s services.
This policy can be further updated. Please, note the date of the most recent update at the top of the page of the present document. Any change in this Policy enters into force at the moment of it’s publication on https://evoradio.eu unless stated otherwise.
Using the platform means that you agree with this Policy and explicitly confirm that you comply with it’s terms.
Providing the personal data is voluntarily considering the use of the platform’s services or accessing them. Your eventual refusal of providing us with your personal data would virtually mean that you waive your right to use the platform’s services or accessing it altogether.
In certain cases your explicit consent to the processing of your personal data may not be necessary if there is another legal basis for the processing, for an example: compliance with the legal obligations of the controller (Evo Radio); for executing a contract, etc.
1. Objectives and Content of the Policy
1.1. This Privacy Policy (hereinafter referred to as the "Policy") governs the relationship between Evo Radio Ltd., UIC BG208119453 (EVO RADIO), as an administrator or processor of personal data, and any user, including only a visitor to the website or otherwise a person using the services offered by the company through the online platform on the following address: https://evoradio.eu (hereinafter referred to as the "Platform"). In accordance with the legislation and good practices, the company applies the necessary technical and organizational measures for protection of the personal data of individuals.
1.2. Evo Radio privacy policy describes the ways of using, storing and protecting users' personal information in connection with the services they use and is an integral part of the General Terms of Use of the site.
1.3. The personal data required for performing Evo Radio’s activities shall be collected and processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 April 95/46, as well as the applicable national or EU law.
1.4 The policy is mandatory for all employees and representatives of Evo Radio. This Policy is also mandatory for the partners of Evo Radio who process personal data in connection with the implementation of a specific contract and have given their informed consent to adhere to this Policy.
2. Definitions
Within the meaning given by the applicable legislation and this Policy:
2.1. 'Personal data' means any information related to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
2.2. 'Administrator' means any natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data; when the purposes and means of such processing are determined by EU law or the law of a Member State, the controller or the specific criteria for determining it may be laid down in Union law or in the law of a Member State;
2.3. "Personal data processor" means a natural or legal person, public authority or any other body which processes personal data on behalf of the controller;
2.4. ‘Data subject’ means any living individual who is associated with specific personal data and whose personal data are processed. This would be any visitor, user or other person using the services offered by the company through the online platform on the following address: https://evoradio.eu. The data subject is hereinafter referred to as "Subject" or "User";
2.5. 'Processing' means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
2.6. Consent of the data subject" means any freely expressed, specific, informed and unambiguous indication of the data subject's will, by means of a statement or clear confirmatory action expressing his or her consent to the processing of personal data relating to him or her
2.7. "Restriction of processing" means the marking of stored personal data in order to limit their processing in the future;
2.8. " Identification data " are the names, date of birth, customer number, code or other identifier created by Evo Radio or by the users of the platform themselves to identify a person using the services offered through the platform.
2.9. "Traffic data" means data processed in an electronic communications network for the purpose of transmitting, distributing or exchanging content of electronic messages, including data used to track and identify the source and destination of communications, location and device data generated in the context of the provision of electronic communications services, as well as the date, time, duration and type of communication, data on the consumption of television services, etc .;
2.10. "Consumption data" are aggregated data on the consumption of the services provided by Evo Radio, including type of service, total number and duration of use;
2.11. 'Profiling' means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;
2.12. 'Personal data breach' means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
2.13. 'Recipient' means a natural or legal person, public authority, agency or another authority, to which the personal data are disclosed, whether a third party or not. The public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing;
2.14. 'Third party' means a natural or legal person, public authority, agency or authority other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data;
2.15. 'Partners' means companies with which Evo Radio has entered into partnership agreements and which provide a variety of products and services.
3. Conditions for personal data processing
Evo Radio collects and processes personal data in the presence of one of the following conditions:
3.1. In order to fulfill a contract or in the context of pre-contractual relations with users, Evo Radio processes personal data necessary to provide the services requested by the user, to fulfill its contractual and pre-contractual obligations to consumers, as well as to exercise its rights under the concluded contracts.
3.2. In order to fulfill normative obligations, Evo Radio processes personal data in order to comply with obligations stipulated in a normative act, including, but not limited to, providing information to control bodies, in connection with keeping proper and lawful accounting, in court proceedings, in accordance with the requirements of the legislation applicable to it.
3.3. After received consent of the User
3.3.1. In some cases, Evo Radio processes personal data only with the prior written consent of the user. Such explicit consent of the user will be required only if Evo Radio needs data that are more than the minimum established data necessary for the conclusion and performance of the contract and / or fulfillment of regulatory obligations. Consent is a separate ground for the processing of personal data and the purpose of the processing is stated in it and is not covered by the other purposes listed in this Policy.
3.3.2. Concessions granted may be withdrawn at any time. The withdrawal of the consent does not affect the fulfillment of the contractual obligations of Evo Radio. If the user withdraws his consent to the processing of personal data for some or all of the purposes described above, Evo Radio will not use the personal data and information for the relevant activities from the moment of withdrawal. Withdrawal of consent shall not affect the lawfulness of the processing based on a consent prior to its withdrawal.
3.3.3. When consent is given for data processing, this consent applies to all services used by the user.
3.4. Evo Radio also processes anonymized data - traffic data of users and data for consumption for statistical purposes. This means performing analyzes in which the results are summarized and the data used are anonymous. It is not possible to identify a specific person and related data from this information.
3.5. When we process the data for identification of the user and his traffic data, as well as the described other data for the purposes of providing services, for their payment, for execution of requests / orders for services, as well as in order to fulfill our regulatory obligations, this processing is mandatory to meet these objectives. Without this data, we would not be able to carry out the relevant activities.
3.6. The user is obliged to take reasonable necessary care for the protection of his personal data when they are provided to third parties other than Evo Radio.
3.7. For the processing of personal data, Evo Radio may use partially automated algorithms and methods in order to constantly improve our services, to adapt our products and services to the needs of users in the best possible way or for calculation. This process is called profiling.
4. Subjects of personal data, categories of processed data, purposes of processing
Depending on how individuals use our platform and the services it provides, they fall into several categories listed below, each of which may include processing of different categories of data, purposes and grounds, retention periods, security measures. and other. The same person may fall into more than one of the listed categories at the same time.
4.1. Visitors
4.1.1. A visitor is any person who loads in his web browser a page, part of the Platform, or visits various sections and pages of it (regardless of whether by directly entering the e-mail address in the browser, or by a link). Visitors' personal data is processed in accordance with the Cookie Policy.
4.1.2. Evo Radio processes the following personal data of visitors to the Platform: online identifiers stored in local cookies in the device / browser of the visitor according to the Cookie Policy: location data based on the IP address of the user device, an integral part of the received by any website information; information about actions performed by the subject in the Platform; preferences of the subject regarding specific aspects and settings of the functionalities of the platform, as far as there is a technical possibility at the moment of granting consent; information about the type of browser / device used.
4.1.3. Evo Radio processes the personal data of visitors to the platform for the following purposes: providing basic and auxiliary functions necessary for the correct and full functioning of the platform; counting the attendance of the platform; providing technical maintenance of the platform in order to provide quality services; providing the necessary conditions for the implementation of services of partners, for conducting analyzes and studies in order to improve the services. The information for analytical and marketing purposes is stored by Evo Radio or our partners in order to improve the services offered through the platform.
4.1.4. Retention period: until the expiry of each cookie (up to 6 months from the date of its registration), the carrier of the relevant information, or until it is deleted by the subject in whose device / browser it is stored.
4.2. Registered users
4.2.1. A registered user is any visitor who has registered on the platform by entering a username and password, with which action he creates his so-called profile or account. Personal data of registered users are processed on the basis of agreement with the General Terms and Conditions in connection with the registration of an account.
4.2.2. Evo Radio obligatorily processes the following personal data of registered users: identification data, passwords, e-mail addresses, IP addresses,, location based on the IP address of the user device, information about the used browser / device.
4.2.3. In case of voluntary provision, Evo Radio processes the following personal data of registered users: preferences for provided services, various settings related to the operation of the platform.
4.2.3. Evo Radio processes the personal data of registered users for the following purposes: providing an opportunity for the user to register his account for personalized use of services on the Platform, such as: concluding distance contracts for the use of services, maintaining a user profile, etc .; providing technical maintenance of the platform with a view to providing quality services; establishing and / or preventing illegal actions or actions in contradiction with the General Terms and Conditions of Evo Radio for the respective services; providing the necessary conditions for the implementation of services of partners for conducting analyzes and studies in order to improve the services. The information for analytical and marketing purposes is stored by Evo Radio or our partners in order to improve the products or services offered through the platform.
4.2.4. Period of processing and storage of data: years after cancelation of registration by the user. If there are none - after closing the account, which in this case is considered a withdrawal of consent.
4.3. Users
4.3.1. User is any registered user who through the technical means of the platform has performed (or declared the performance of) the conclusion of a contract for services offered through the platform. Personal data of the users are processed on the basis of agreement with the General Terms and Conditions in connection with the use of the services of the platform and fulfillment of a contract with the respective person who provided content on the platform.
4.3.2. Evo Radio processes the following personal data of users: identification data, passwords, e-mail addresses, IP addresses, password, location based on the IP address of the user device, information about the used browser / device, information about purchases, credit or debit information card, bank account number or other banking and payment information in connection with the payments made to Evo Radio, information about actions performed by the subject in the platform, preferences for provided services.
4.3.3.Evo Radio processes the personal data of the users for the following purposes:
(a) establishing the identity of the consumer;
b) preparation of a proposal for concluding a contract, including at a distance, servicing a waiver of a transaction;
c) providing the opportunity to use services through the platform and managing and executing the service requests themselves;
d) analysis of user history and preparation of a user profile in order to determine an appropriate offer for the User;
e) providing maintenance of the platform in order to provide quality services;
f) providing the necessary conditions for the implementation of services of partners or marketing platforms, for conducting analyzes and studies in order to improve the services; The information for analytical and marketing purposes is stored by Evo Radio or our partners in order to improve the products or services offered through the platform.
g) detection and / or prevention of illegal actions or actions in contradiction with the General Terms and Conditions of Evo Radio for the respective services;
4.3.4. Period of processing and storage of data: the use of personal data for the purposes of the contractual relationship is terminated after termination of the contract, but the data is not destroyed before the expiration of: 2 years after termination of registration by the user or until the final settlement of all financial relationships arising from the contractual relationship; expiration of the term for the normatively determined obligations for data storage, such as obligations under the Electronic Communications Act for storage and provision of information for the purposes of detection and investigation of crimes (6 months); under the Accounting Act for storage and processing of accounting data (11 years); expiration of the limitation periods for filing claims specified in the Law on Obligations and Contracts (3 years for services with recurring services and 5 years for other services); obligations to provide information to the court, competent state authorities, etc. grounds provided for in the current legislation (5 years).
4.4. Personal data can also be anonymized. Anonymization is an alternative to deleting data. Upon anonymization, all personally identifiable items / items that allow the user to be identified are irreversibly deleted. There is no legal obligation for anonymized data to be deleted, as they do not constitute personal data.
4.5. Evo Radio does not delete or anonymize personal data if they are necessary for pending court, administrative proceedings or proceedings for consideration of a consumer complaint to the company.
5. Providing personal data to third parties
5.1. Some pages of the Platform may contain links / links / links to other (external) sites. They are part of content published on the platform by third parties, but these are not third parties to whom Evo Radio provides personal data. If you visit an external site through a link available on the platform, Evo Radio is not responsible for the content of this external site, its services and functionalities, as well as its data protection policy.
5.2. In cases where for the implementation of contracts for the provision of services and / or for the implementation of the functionalities of the platform Evo Radio provides personal data to third parties, Evo Radio provides data only if these persons have taken technical and organizational measures to protect these data, striving to exercise strict control over the implementation of this goal. In this case, Evo Radio remains responsible for the confidentiality and security of personal data.
5.3. The categories of recipients to whom we provide personal data are the following:
5.3.1. persons who, by assignment, perform accounting services, maintain equipment, software and hardware used and necessary for the construction and operation of the platform, for performing various reporting services, payment for services and products, technical support, etc .;
5.3.2. persons employed on an employment or civil contract by Evo Radio, supporting the processes of providing services to users through the platform;
5.3.3. bodies, institutions and persons to whom we are obliged to provide personal data under current legislation;
5.3.4. providers of electronic certification services, when a document related to the provision of a service is signed with an electronic signature;
5.3.5. banks and other institutions offering financial services, as well as external platforms offering services for making and accepting online payments - for servicing payments made by consumers;
5.3.6. persons performing consulting services in various fields - legal, financial, accounting and other specialists;
5.3.7. assignees - a party to assignment agreements to which Evo Radio transfers (sells) outstanding liabilities, as well as companies securing receivables - credit agencies that service and collect receivables through suretyship or other means;
5.3.8. competent authorities which, by virtue of a normative act, have the power to require the provision of information, including personal data, such as courts, prosecutors, various regulatory bodies such as the Consumer Protection Commission, the Communications Regulation Commission, the Consumer Protection Commission personal data, bodies with powers to protect national security and public order.
5.4. Evo Radio assigns data processing by third parties only under the following conditions:
5.4.1. The assignment of data processing shall be carried out exclusively for the territory of a Member State of the European Union (EU) or in a Member State of the European Economic Area (EEA). Any transfer of data to a non-EU or EEA Member State requires the prior written consent of the EMPT as Data Controller.
5.4.2. Evo Radio requires processors of personal data to maintain the necessary technical and organizational measures for data protection in accordance with regulatory requirements, including ensuring compliance with the rules of confidentiality and data protection by its employees and all other persons with whom they have a contractual relationship.
5.4.3. Evo Radio requires the processors of personal data to immediately notify in cases of breach of personal data security.
5.4.3. In case Evo Radio as a personal data controller is subject to inspection by a supervisory authority, there is a claim by a data subject or a third party, or there are claims in connection with the processing of data by the Processor, Evo Radio requires the relevant Processor the necessary assistance until the case is fully clarified, including the provision of all relevant information and documents related to the case (including documents submitted by the data subject or held by the Processor).
6. Users’ rights in relation to the processing of their personal data
6.1. Right to information: consumers have the right to request:
(a) information on whether data relating to them are processed, information on the purposes of such processing, on the categories of data and on the recipients or categories of recipients to whom the data are disclosed;
b) a communication in an intelligible form containing the personal data being processed as well as any available information on their source;
c) information on the logic of any automated processing of personal data concerning users in the case of automated solutions.
6.2. Right of correction: in case we process incomplete or erroneous data, users have the right at any time to request:
a) to delete, correct or block their personal data, the processing of which does not meet the requirements of the law;
(b) notify third parties to whom users' personal data have been disclosed of any deletion, rectification or blocking, except where this is not possible or involves excessive effort.
6.3. Right of objection: consumers have the right at any time to:
(a) object to the processing of their personal data where there is a legal basis for doing so; where the objection is justified, the personal data of the natural person concerned may no longer be processed;
b) object to the processing of their personal data for the purposes of direct marketing.
6.4. Right to restrict processing: users may request a restriction on the credentials being processed if:
(a) challenge the accuracy of the data for the period during which Evo Radio must verify its accuracy; or
b) the processing of the data has no legal basis, but instead of being deleted, users have requested their limited processing; or
c) Evo Radio does not need this data (for the specified purpose), but users need it to establish, exercise or defend their legal claims; or
d) users have objected to the processing of the data, pending verification that the controller's grounds are lawful.
6.5. Right to data portability: users have the right to receive personal data concerning them which they have provided to Evo Radio in a structured and generally accepted electronic format and have the right to transfer this data to another controller when:
(a) the processing of such data by Evo Radio is based on the explicit consent of the user to process data for a specific purpose; and
b) the processing is carried out automatically.
6.6. Right of appeal: in case the user considers that Evo Radio violates the applicable regulations, we expect the user to contact us to clarify the issue. The user has the right to file a complaint to the Commission for Personal Data Protection. From 25 May 2018, consumers can also lodge a complaint with a regulatory body within the European Union.
6.7. Applications for access to information or for correction are submitted personally or by a person explicitly authorized by the user, through a notarized power of attorney. An application may also be submitted electronically, in accordance with the Electronic Document and Electronic Signature Act.
6.8. Evo Radio shall rule on the client's request within 14 days of its submission. In case of an objectively necessary longer term, in order to collect all the requested data and this seriously complicates our activity, this term may be extended up to 30 days. The decision on the appeal is motivated.
7. Obligations of Evo Radio as a processor of personal data
The rules below apply in cases where Evo Radio is both a controller and a processor of personal data, as well as a processor of personal data provided by another controller.
7.1. Technical and organizational measures
7.1.1. Evo Radio ensures data protection in accordance with Art. 5, paragraph 1 and paragraph 2, Art. 28, paragraph 3, letter “c” and Art. 32 of Regulation (EU) 2016/679.
7.1.2. Evo Radio keeps records of all data processing activities performed, ensuring that every step of data processing can be traced, including to whom the data was provided, when, what data, for what purpose and what are the recipient's agreements with third parties. .
7.1.3. As a processor of personal data provided by another controller, on request, Evo Radio shall at any time provide the records to the controllers of personal data or supervisory authorities.
7.2. Exercising the rights of a data subject
7.2.1. As a processor of personal data provided by another controller, Evo Radio does not correct, delete or limit the processing of data, does not make decisions in connection with the exercise of other rights of a data subject, which are processed on behalf of the Data Controller. Such actions are performed by Evo Radio only in the presence of written instructions from the administrator and / or when Evo Radio is in the capacity of both administrator and processor of personal data.
7.2.2. If a data subject contacts directly Evo Radio regarding the correction, deletion of personal data, restriction of processing or exercise of his other rights, Evo Radio as a processor may perform these actions only when is also an administrator. As a processor of personal data provided by another controller, it shall immediately forward the request of the data subject to the controller of personal data.
7.3. Deletion and return of personal data
7.3.1. As a processor of personal data provided by another controller, Evo Radio does not create copies or duplicates of the data without the knowledge and permission of the controller of personal data, except for backups, if such are necessary to ensure organized data processing, as well as data necessary to comply with regulatory requirements for the storage of personal data. Evo Radio, as a processor, can perform these actions only when it is also an administrator.
7.3.2. As a processor of personal data provided by another controller, upon termination of the contractual relationship between the parties or at the request of the controller of personal data, Evo Radio transmits to the controller, or with prior consent, destroys all documents, results of processing and use, as well as the data sets related to the contracts in his possession, in a manner that meets the data protection requirements.
7.3.3. Evo Radio does not return and / or destroy the data if there is a legal basis for their preservation.
7.4. Control and responsibility
7.4.1. As a processor of personal data provided by another controller Evo Radio provides an opportunity for the controller of personal data to verify compliance with the obligations for lawful data processing. Evo Radio provides the personal data controller with the necessary information upon request and, when required, proves the implementation of the technical and organizational measures.
7.4.2. In case the controller of personal data is subject to inspection by a supervisory authority, there is a claim filed by a data subject or a third party, or there are claims in connection with the processing of data by Evo Radio as a processor of personal data, Evo Radio provides full assistance of the administrator.
8. Contact details regarding the protection of the personal data
Evo Radio LTD
Company headquarters:
Country: Bulgaria
Sofia District (capital), Sofia Municipality
Sofia, p.k. 1336, Lulin district,
zh.k. Lulin 3, bl. 312, ent. B, apt. 23
contact: evoradioeu@gmail.com
The control body regarding the protection of personal data is the Commission for Personal Data Protection.
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