Privacy Policy

Scope and Controller

This privacy policy describes the type, scope and purpose of processing (e.g. collection, processing and use, as well as obtaining consent) of personal data within our online offering and the websites, functions and content connected to it (hereinafter jointly referred to as "online offering" or "website"). The privacy policy applies regardless of the domains, systems, platforms and devices (e.g. desktop or mobile) on which the online offering is operated.

The provider of the online offering and the controller under data protection law is PixelSkalpell.com EOOD, Sofia, Bulgaria (hereinafter referred to as "provider", alternatively also "we" or "us"). For contact information please refer to the Legal Notice.

The term "user" includes all clients and visitors to our online offering. Terms used, such as "user", are gender-neutral.

General Principles of Data Processing

We process personal data of users only in compliance with the applicable data protection regulations, in particular the EU General Data Protection Regulation (GDPR) and the Bulgarian Personal Data Protection Act, and according to the principles of data minimisation and avoidance. This means that user data is only processed when there is a legal basis - in particular when the data is required to provide our contractual services and online services, when there is a legal obligation, or when consent has been given.

We take organisational, contractual and technical security measures in line with the state of the art to ensure compliance with data protection regulations and to protect the data we process against accidental or intentional manipulation, loss, destruction, or access by unauthorised persons.

Where third-party content, tools or other resources are used within this privacy policy (hereinafter jointly referred to as "third-party providers") and their stated registered office is abroad, it can be assumed that data is transferred to the country in which the third-party provider is based.

Personal Data Processing

Personal data is processed for the following purposes, in addition to the uses expressly mentioned in this privacy policy, on the basis of legal permissions or user consent:

• Provision, performance, maintenance, optimisation and security of our services and user offerings
• Ensuring effective customer service and technical support

We pass user data to third parties only when this is necessary for billing purposes (e.g. to a payment service provider) or for other purposes when necessary to fulfil our contractual obligations to users (e.g. address transmission to suppliers).

When you contact us (via contact form or email), the user's information is stored for the purpose of processing the request and in case follow-up questions arise. Personal data is deleted once it has fulfilled its purpose and there are no retention obligations preventing deletion.

Collection of Access Data

We collect data on every access to the server hosting this service (so-called server log files). Access data includes the name of the requested website, file, date and time of the request, transferred data volume, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

We use the log data without attribution to the user's person or other profiling, in accordance with statutory provisions, only for statistical analysis for the purposes of operating, securing and optimising our online offering. However, we reserve the right to subsequently review the log data if specific evidence gives rise to legitimate suspicion of unlawful use.

Cookies & Analytics

Cookies are pieces of information that are transferred from our web server or third-party web servers to users' web browsers, where they are stored for later retrieval. Users are informed about the use of cookies in the context of pseudonymous analytics within this privacy policy.

Use of this online offering is also possible while excluding cookies. If users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. Excluding cookies may lead to functional limitations of this online offering.

It is possible to manage many online advertising cookies from companies via the US site www.aboutads.info/choices or the EU site www.youronlinechoices.com.

Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google uses cookies. The information generated by the cookie about users' use of the online offering is generally transferred to a Google server in the USA and stored there.

Google will use this information on our behalf to evaluate users' use of our online offering, to compile reports on activities within this online offering, and to provide us with further services related to the use of this online offering and Internet usage. Pseudonymous user profiles can be created from the processed data.

We use Google Analytics only with IP anonymisation activated. This means that users' IP addresses are truncated by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area.

Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and relating to their use of the online offering by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout.

Google Re/Marketing Services

We use the marketing and remarketing services ("Google marketing services") of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

Google marketing services allow us to show advertisements for and on our website more specifically, in order to present users only with ads that potentially correspond to their interests. If users are shown ads for products in which they have shown an interest on other websites, this is referred to as "remarketing".

Users' data is processed pseudonymously within the Google marketing services. This means Google does not store or process users' names or email addresses but processes the relevant data on a cookie basis within pseudonymous user profiles.

The Google marketing services we use include the online advertising programme "Google AdWords". We also embed third-party advertisements based on the Google marketing services "DoubleClick" and "AdSense". Another Google marketing service we use is "Google Tag Manager".

If you wish to opt out of being tracked by Google marketing services, you can use the settings and opt-out options provided by Google: www.google.com/ads/preferences.

Facebook Social Plugins

Our online offering uses social plugins ("plugins") of the social network facebook.com, operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). The plugins can be recognised by one of the Facebook logos (white "f" on a blue tile, the words "Like", or a thumbs-up symbol) or are marked with the addition "Facebook Social Plugin".

When a user accesses a feature of this online offering that contains such a plugin, their device establishes a direct connection with Facebook's servers. The content of the plugin is transmitted directly from Facebook to the user's device and integrated into the online offering.

Through the integration of the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offering. If the user is logged into Facebook, Facebook can attribute the visit to their Facebook account.

Users can find the purpose and scope of data collection, and the related rights and settings options for protecting their privacy, in Facebook's privacy policy: facebook.com/about/privacy.

Facebook Remarketing

Within our online offering, so-called "Facebook pixels" of the social network Facebook are used. With the help of the Facebook pixel, Facebook can identify visitors to our offering as a target group for displaying ads, so-called "Facebook ads".

Accordingly, we use the Facebook pixel to display the Facebook ads we run only to those Facebook users who have shown an interest in our online offering. With the help of the Facebook pixel we can also track the effectiveness of Facebook ads for statistical and market research purposes.

You can opt out of being tracked by the Facebook pixel and the use of your data to display Facebook ads. To do this, you can visit the page set up by Facebook: facebook.com/settings/ads.

Newsletter

We send newsletters, emails and other electronic notifications with promotional information (hereinafter "newsletter") only with the recipient's consent or a legal permission. To the extent that the contents of the newsletter are specifically described during sign-up, those contents are decisive for user consent.

Double opt-in and logging

Sign-up for our newsletter takes place in a so-called double opt-in procedure. This means that after signing up you receive an email asking you to confirm your sign-up. This confirmation is necessary to ensure that no one can register with someone else's email address.

Statistical collection

The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from the dispatch service provider's server when the newsletter is opened. Statistical collection includes determining whether newsletters are opened, when they are opened, and which links are clicked.

Cancellation / withdrawal

You can cancel receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of every newsletter.

Integration of Third-Party Services and Content

It can happen that third-party content or services (e.g. street maps, fonts) are embedded within our online offering. The embedding of third-party content always presupposes that the third-party providers can see users' IP addresses, since without the IP address they could not send the content to the user's browser.

The following overview lists third-party providers:

• Google Fonts - external fonts by Google, Inc. Privacy, Opt-out
• Google Maps - maps from the "Google Maps" service. Privacy, Opt-out
• YouTube - videos from the "YouTube" platform. Privacy, Opt-out

User Rights and Deletion of Data

Under the GDPR, users have the right to obtain free information, on request, about the personal data we have stored about them. In addition, users have the right to rectification of inaccurate data, withdrawal of consent, restriction of processing and erasure of their personal data, the right to data portability, and the right to lodge a complaint with the competent supervisory authority (in Bulgaria: Commission for Personal Data Protection, CPDP) if they believe data processing has been unlawful.

Data stored with us is deleted as soon as it is no longer required for its intended purpose and provided no statutory retention obligations stand in the way of deletion.

Changes to the Privacy Policy

We reserve the right to amend the privacy policy in order to adapt it to changed legal situations or in case of changes to the service or data processing. However, this only applies in respect of declarations on data processing. Where user consent is required or components of the privacy policy contain provisions of the contractual relationship with users, changes will only be made with user consent.

Users are asked to inform themselves regularly about the content of the privacy policy.