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PRIVACY AND PERSONAL DATA PROCESSING POLICY OF 4NEWME.COM

Last updated: 23 September 2026

This Policy explains how “Деси Щ” EOOD collects, uses, stores and protects the personal data of visitors to and customers of 4newme.com.

We process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”), the Bulgarian Personal Data Protection Act and other applicable Bulgarian and European legislation.

1. Data Controller and Contact Details

The controller of your personal data is:

“Деси Щ” EOOD
Unified Identification Code (UIC): 205920951
Registered address: Sofia, Lyulin 2 residential district, bl. 210, Bulgaria
Website: https://www.4newme.com
Email: info@4newme.com
Telephone: +359 877 770 508

For any questions concerning your personal data or the exercise of your rights, you may contact us by using the email or postal address specified above.

“Деси Щ” EOOD has not appointed a Data Protection Officer because it is not currently under a legal obligation to do so.

2. Scope of This Policy

This Policy applies when you:

  • visit or use 4newme.com;

  • create or use a customer account, where this feature is available;

  • place or process an order;

  • make a payment or arrange delivery;

  • send an enquiry by email, telephone or contact form;

  • subscribe to a newsletter or other marketing communications;

  • consent to analytical or advertising cookies;

  • submit a complaint, exercise a right of withdrawal or make another consumer request;

  • participate in a survey, campaign or other initiative organised through 4newme.com.

When you purchase through Etsy, your personal data is also processed in accordance with Etsy’s rules and policies.

3. Personal Data We Collect

Depending on how you use the website, we may process the following categories of data:

Identification and Contact Details

  • first and last name;

  • telephone number;

  • email address;

  • delivery address;

  • billing address and invoicing details;

  • company details where an invoice is requested.

Order and Payment Information

  • products ordered;

  • order value and currency;

  • selected delivery and payment method;

  • order number, date and status;

  • payment confirmation or transaction identifier;

  • information concerning complaints, returns and withdrawals;

  • correspondence relating to the order.

We do not store your full bank card details when payment is processed in the secure environment of an external payment service provider.

Information Relating to Personalised Items

When you order a personalised product, we may process information provided by you, including:

  • preferences concerning colours, dimensions and design;

  • wording, initials or other instructions;

  • images and additional materials required to create the product.

Please do not send us images or personal data relating to another person unless you have the right to provide them.

Communication Data

  • the content of enquiries and messages;

  • information submitted through forms;

  • information required to respond to or assist you;

  • the date and history of correspondence.

Technical and Online Data

  • IP address;

  • device type, operating system and browser;

  • date and time of access;

  • pages visited and actions performed;

  • approximate location derived from the IP address;

  • cookie and browser identifiers;

  • technical logs and security information.

Analytical and advertising data is processed only where you have provided the required consent, unless the relevant technology is strictly necessary for the operation or security of the website.

4. Purposes, Data, Legal Bases and Retention Periods

Purpose

Personal data processed

Legal basis

Main retention period

Accepting and fulfilling orders

name, contact details, address, products ordered, payment and delivery information

performance of a contract or steps taken before entering into a contract

up to five years after completion of the order, unless a longer statutory period applies

Creating a personalised product

instructions, dimensions, wording, images and correspondence

performance of a contract

up to five years after fulfilment of the order; working materials may be deleted sooner

Processing payments

order details, amount, payment method, payment status and transaction identifier

performance of a contract and compliance with a legal obligation

according to the applicable periods for contractual and accounting records

Issuing and retaining accounting documents

identification, invoicing and payment information

compliance with a legal obligation

for the statutory period, generally up to ten years for the relevant accounting documents

Delivering orders

name, telephone number, address, contents and value of the shipment where necessary

performance of a contract

until completion of delivery, after which the information is retained only insofar as necessary for accounting, complaints or the establishment and defence of legal claims

Complaints, returns and withdrawals

customer, order, payment, product and correspondence information

performance of a contract, compliance with a legal obligation and the establishment or defence of legal claims

up to five years after the matter has been finally resolved

Customer account

name, email address, addresses, order history and settings

performance of a contract

until the account is deleted or for up to three years after the last activity, except for information that must be retained by law

Responding to enquiries

name, contact details and the content of communications

steps taken before entering into a contract or legitimate interests

up to 12 months after the communication has ended, unless the enquiry results in an order or dispute

Newsletter and direct marketing

name, email address and consent records

consent

until consent is withdrawn; a limited record of the withdrawal may be retained to demonstrate compliance

Website analytics

online identifiers and usage information

consent

according to the lifetime of the relevant cookies, as described in the Cookie Policy

Personalised advertising

online identifiers, pages visited and interactions

consent

according to the lifetime of the relevant cookies and the provider’s settings

Security and prevention of misuse

IP address, technical logs and device information

legitimate interests in protecting the website and its users

generally up to 12 months, unless an incident, investigation or dispute requires longer retention

Establishment and defence of legal claims

contract, payment, communication and dispute information

legitimate interests and applicable legislation

until the relevant limitation periods have expired or the proceedings have been finally concluded

Where we rely on legitimate interests, we assess in advance whether our interests are overridden by your rights and freedoms.

5. Sources of Personal Data

We normally obtain personal data directly from you when you:

  • place an order;

  • create an account;

  • complete a form;

  • contact us;

  • request a personalised product;

  • exercise a consumer right;

  • consent to cookies or marketing communications.

We may also receive limited information from:

  • payment service providers and banks;

  • courier and logistics companies;

  • Etsy, where the order is placed through the platform;

  • Google and Meta, where you have consented to the relevant technologies;

  • providers of technical and security services;

  • public registers, where this is necessary for invoicing or the establishment and defence of legal claims.

6. Recipients and Processors

Depending on the service concerned, we may disclose the necessary personal data to:

  • Econt and/or Speedy for deliveries within Bulgaria;

  • “Годес” EOOD and other logistics providers for international deliveries;

  • ePay, EasyPay, banks and other payment service providers;

  • accountants and accounting service providers;

  • hosting and technical support providers;

  • email and communications service providers;

  • Google, where you have consented to analytical or advertising services;

  • Meta, where you have consented to the Meta Pixel or other advertising services;

  • Etsy, where a purchase is made through Etsy;

  • lawyers, consultants and competent authorities where necessary to comply with a legal obligation or protect legal rights;

  • other providers required to perform a service requested by you.

We disclose only the personal data necessary for the relevant purpose. Where a provider processes personal data on our behalf, the relationship is governed by a contract containing appropriate confidentiality and security requirements.

We do not sell your personal data.

7. Payments

4newme.com may offer payment by:

  • bank transfer;

  • ePay and/or EasyPay;

  • cash on delivery through a courier;

  • other payment methods displayed on the website;

  • Etsy for orders placed through the Design4Silk shop.

When payment is made through an external service provider, you may be redirected to that provider’s secure environment. The payment service provider processes the information submitted to it in accordance with its own terms and privacy policy.

4newme.com receives the information required to associate the payment with the relevant order, such as the amount, status, date and transaction identifier. We do not receive or store the full card number, security code or other complete bank card details.

For bank transfers, we process the information contained in the payment order and bank statement.

8. Deliveries Within Bulgaria and Abroad

To arrange delivery, we provide the selected courier or logistics provider with the information required for that purpose, normally including:

  • the recipient’s name;

  • telephone number;

  • address or selected courier office;

  • information about the shipment;

  • its value and payment method where necessary.

Deliveries within Bulgaria may be carried out by Econt, Speedy or another courier displayed when the order is placed.

International deliveries may be carried out by “Годес” EOOD, a postal operator or another logistics provider, depending on the destination and service selected.

Where delivery is made to a country outside the European Economic Area, personal data may be disclosed to local courier, postal and customs authorities insofar as necessary for delivery and compliance with legal requirements.

9. Cookies, Google and Meta

4newme.com uses strictly necessary cookies that support essential functions such as:

  • operation of the shopping basket;

  • maintaining the session;

  • website security;

  • saving selected settings;

  • recording your cookie preferences.

Consent is not required for strictly necessary cookies.

Only after you have provided your prior consent may the website use:

  • Google Analytics;

  • Google Tag Manager to manage authorised tags;

  • Meta Pixel;

  • other analytical, advertising or personalisation technologies.

These technologies may process information such as your IP address, browser identifier, device information, pages visited, interactions with the website and information about orders or other events.

You may:

  • accept all optional cookies;

  • reject them;

  • select individual categories;

  • change or withdraw your choice at any time through the “Cookie Settings” link on the website.

Rejecting optional cookies will not prevent you from placing an order.

Detailed information about specific cookies, providers, purposes and retention periods is available in the separate Cookie Policy.

Google and Meta may process certain personal data as independent data controllers in accordance with their own privacy policies:

10. International Data Transfers

Some providers, including Google, Meta, Etsy or their subcontractors, may process personal data outside the European Economic Area.

Where this occurs, the transfer is based on an applicable data protection mechanism, including:

  • an adequacy decision adopted by the European Commission;

  • the EU–US Data Privacy Framework where the recipient is duly certified;

  • Standard Contractual Clauses adopted by the European Commission;

  • other appropriate safeguards permitted under Chapter V of the GDPR.

Additional contractual, technical or organisational safeguards are applied where necessary.

You may request further information about the mechanism applicable to a particular transfer by contacting info@4newme.com.

11. Profiling and Automated Decision-Making

4newme.com does not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

Where you have consented to advertising technologies, Google and Meta may use information about your activities and interests to:

  • measure advertising performance;

  • create audiences;

  • display more relevant advertisements;

  • limit repeated display of the same advertisement.

You may stop this processing by withdrawing your consent through the cookie settings. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

12. Retention Periods

We do not retain personal data for longer than necessary.

When determining a retention period, we take into account:

  • the purpose for which the data was collected;

  • our contractual relationship;

  • applicable accounting and tax obligations;

  • periods for complaints and legal claims;

  • the need to protect the website and prevent misuse;

  • whether consent has been given or withdrawn;

  • the technical settings of the services used.

After the applicable period has expired, the personal data is deleted, anonymised or access to it is restricted, unless a longer retention period is required by law.

Information relating to a single order may be separated and retained for different periods. For example, an address stored in a customer account may be deleted while the accounting document relating to the same purchase is retained for the statutory period.

13. Security

We implement appropriate technical and organisational measures to protect personal data, including, where relevant to the particular risk:

  • an encrypted HTTPS connection;

  • access controls;

  • individual user accounts for administrators;

  • limiting access to authorised personnel and providers;

  • website updates and technical maintenance;

  • backups;

  • protection against unauthorised access and misuse;

  • contractual confidentiality obligations;

  • security incident procedures.

No system can provide absolute security. In the event of a personal data breach, we will take the measures required under the GDPR, including notifying the competent supervisory authority and affected individuals where required.

14. Your Rights and How to Exercise Them

Under the GDPR, you have the right to:

  • obtain confirmation as to whether we process your personal data;

  • obtain access to and a copy of your personal data;

  • request correction of inaccurate or incomplete personal data;

  • request erasure where the applicable legal conditions are met;

  • request restriction of processing;

  • object to processing based on legitimate interests;

  • object to direct marketing at any time;

  • receive personal data provided by you in a structured, commonly used and machine-readable format where applicable;

  • request transmission of the data to another controller where technically feasible;

  • withdraw consent at any time;

  • not be subject to a decision based solely on automated processing where it produces legal or similarly significant effects;

  • lodge a complaint with the Bulgarian Commission for Personal Data Protection.

To exercise any of these rights, send your request to:

Email: info@4newme.com
Postal address: “Деси Щ” EOOD, Sofia, Lyulin 2 residential district, bl. 210, Bulgaria

Please provide sufficient information to enable us to identify the personal data to which the request relates.

Where we have reasonable doubts concerning the identity of the person making the request, we may ask for additional information necessary to confirm their identity. We will not request more information than is necessary for that purpose.

We will respond without undue delay and normally within one month. Where the request is factually or legally complex, this period may be extended by a further two months. We will inform you if such an extension is required.

The exercise of these rights is generally free of charge. For manifestly unfounded or excessive requests, the GDPR permits the charging of a reasonable fee or refusal to act on the request.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

15. Complaints to the Bulgarian Commission for Personal Data Protection

If you believe that your personal data is being processed unlawfully, you may lodge a complaint with:

Commission for Personal Data Protection

Website: https://cpdp.bg
Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Email: kzld@cpdp.bg

The right to lodge a complaint does not restrict your right to use other administrative or judicial remedies.

We recommend that you contact us first so that we may attempt to resolve the matter promptly.

16. Changes to This Policy

We may update this Policy where there is:

  • a change in our activities or the website’s features;

  • an addition or removal of service providers;

  • a change in the analytical or advertising technologies used;

  • a change in legislation or guidance issued by a competent authority;

  • a need to provide a clearer description of our processing activities.

The current version will always be published on 4newme.com and will state the date on which it was last updated.

Where a change materially affects the way in which we process personal data, we will provide an appropriate notice through the website, by email or by another suitable method.

A change to this Policy cannot, by itself, replace consent where consent is required. Where consent is required for a new activity, it will be requested separately.


Contact for personal data enquiries

“Деси Щ” EOOD
Email: info@4newme.com
Telephone: +359 877 770 508
Website: https://www.4newme.com


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