PRIVACY CHARTER

Last updated: March 23, 2025

1 – PURPOSE

This section illustrates the company's commitment through its website available at the following URL: www.edou.com (the "Site"), with regard to respecting your privacy and protecting your personal data (the "Data"), collected and processed during your use of the Site and Services under the conditions specified in our General Terms of Use and Sale (available in the "T.O.U." and "T.O.S." sections of the Site).

This Charter has been developed to:

Inform you in advance and with complete transparency about the Data that may be collected and how it may be used;
Allow you to navigate the Site and use its features with complete confidence;
Inform you of your rights regarding the Data concerning you that will be collected, should you give your consent to their processing by checking the acceptance box provided for this purpose.

2 – CONTENT SENT ON THE SITE

All personal information that you voluntarily put online (in your profile or in messages) is not accessible to the public and cannot be collected and used by third parties.

3 – DATA COLLECTED

The Data collected and subsequently processed by our Site is that which you voluntarily transmit to us when opening your User account (the "Account"), via the Registration Form, and concerns at minimum your last name(s) and first name(s), a valid email address (which constitutes your identifier/username to access your Account and our Services), and a password of your choosing.

Your consent to the processing of your Data transmitted when opening your Account via the Registration Form will result from checking the acceptance box provided for this purpose on the Site. Some advanced features of the Site may, for authentication purposes, require you to provide additional Data, such as your telephone number and postal address, particularly when purchasing Products (see: our General Terms of Sale).

Your prior acceptance will then be required again, by checking the box provided for this purpose, when activating advanced Site features that require this Data. You may naturally refuse to provide this additional Data, but such refusal may prevent access to advanced Site features that require it.

The Data automatically collected by the Site is your IP address (your computer's Internet address) associated with your browser version, the address of the displayed page, and the date of the request.

Furthermore, browsing the Site may result in the automatic installation of cookies on your computer. Cookies are small text files sent by a website to your browser and stored on your computer. In this case, they allow our servers to identify you and thus offer you personalized information and automatically connect you to our services. They therefore only serve to simplify navigation and improve the Site's ergonomics.

However, you may refuse the installation of cookies on your computer by modifying the relevant settings of your Internet browser, but such refusal may prevent access to certain Site services.

These cookies and their use are subject to a specific Charter established by the Company that you can consult now in the "Cookie Charter" section of the Site.

4 – PROCESSING PURPOSES

The Data identified as mandatory in the Registration Form is necessary to benefit from the Site's features.

We will use this information to manage and maintain our Site, to allow you to benefit from personalized features, and to process any reports or correspondence from you.

The Data automatically collected by the Site allows us to perform consultation statistics on its web pages.

We do not use your email address or any other information that could personally identify you without your consent, whether to send advertising or marketing messages, except as part of a specific program or feature that you can previously activate or block.

However, we may use your email address without your consent in the following cases:

Registration as a Site member: the new User member receives a welcome email containing an activation link for their Account;
Order validation: the User receives an email confirmation of their order, including details of the products ordered, the postal delivery address, and telephone contact details;
Password reset: the User, in case of password loss, can request a password reset, and a reset email will then be sent;
Password modification: with each password change made by the User, a confirmation email of the action is sent;
Account closure: In case of a request made to the Company by the User to permanently close or temporarily deactivate their Account, a notification email may be sent by the Site to inform them of the completion of the requested operation;
Events, Games and Contests: the Company may send the User emails to inform them of the existence of games and contests or special events organized by the Site;
Information about the Site and Services offered: the Company may send the User emails to inform them of Site developments, transmit newsletters and notifications of Services to which they are subscribed;
Assistance request or submission of questions/suggestions: the Company responds by email to the User who requests assistance to connect to the Site, modify or access their Account, or for any remarks or suggestions submitted to the Company through the "Contact Us" section available on the Site.

Important:

None of the processing enumerated above has the purpose of any automated decision-making, including profiling, concerning you;
At certain times, we may ask for your consent to use your Data for certain very specific reasons (new purpose, modification or deletion of existing purpose). You naturally remain free to accept or refuse this request;
At any time, you may decide to withdraw your consent to all or part of the processing enumerated above by modifying certain parameters available in your Account profile page or by sending your request to the Company (as part of exercising your rights as provided in Article 8 below). However, you must keep in mind that certain parts of the Site and certain Services will then be unavailable.

5 – DATA RECIPIENTS

The Company is committed to protecting your privacy and the confidentiality of your Data.

Consequently, we undertake never to share or disclose your Data to third parties, except in the following strictly enumerated situations:

When we are required to do so by a judicial authority, police authorities, and generally by any administrative authority authorized by law;
When you have given us your prior consent to share this information;
When you violate our General Terms of Use (we are thus able to transmit your IP address to access providers for identification purposes — and thus obtain your possible removal — or even, if we deem it necessary given the nature of your abuses, transmit your IP address directly to the competent authorities).

6 – SECURITY AND DATA RETENTION PERIOD

6a – Security

Concerned about the trust shown by the User when connecting to our Site, we attach great importance to the security and protection of their Data and implement all necessary technical and organizational measures to:

Restrict the risks of loss, deterioration, or misuse;
Prevent any violation thereof.

Thus, to ensure optimal security, the Company uses the standard 256-bit SSL (Secure Socket Layer) technology. The use of the SSL protocol, one of the most effective and widely used encryption methods currently, guarantees maximum protection of your Data.

Furthermore, still within the framework of this security charter, we inform you that:

Your User account is protected by a personal password stored in encrypted form in our database;
A secure cookie system is made available to you to render ineffective any attempt to steal your cookies;
Your email address is only accessible to the Site administrator, as well as our webmasters if you have accepted that the Company contact you by email;
In accordance with the provisions of the GDPR, we will notify the supervisory authority ("Bulgarian Commission for Personal Data Protection") of any possible personal data breach of which we might be a victim despite our security measures and will communicate to you, if applicable, any possible breach concerning your Data more particularly, if this breach results in a high risk to your rights and freedoms.

6b – Data Retention Period

Your Data is stored at the Site host's premises and is kept for the duration strictly necessary to manage the commercial relationship between us, in compliance with the purposes as stated in Article 5 of this Charter, and only to the extent authorized by current regulations.

Beyond this period, they will be anonymized and kept for statistical purposes and will not give rise to any exploitation of any kind.

7 – PARTNER SITES

You may access, through the hyperlinks present on the Site, Partner sites that are not governed by these Data protection provisions. You are, consequently, invited to examine the rules applicable to the use and disclosure of information you have communicated on these sites.

8 – RIGHTS OF ACCESS, MODIFICATION AND DELETION OF YOUR DATA

The Company respects the regulations applicable to the processing of personal data and in particular the Bulgarian Personal Data Protection Act of December 21, 2001, as well as the European Data Protection Regulation No. 2016/679 of April 27, 2016 (hereinafter referred to as "GDPR").

Thus, in accordance with the Bulgarian Personal Data Protection Act and the GDPR, you have at any time:

A right of access: you may, by proving your identity, obtain communication of the data concerning you and verify their accuracy;
A right of rectification: in case of inaccuracy of this information, you may require that it be rectified, completed, updated, locked, or erased;
A right to erasure ("right to be forgotten"): you may obtain the erasure, as soon as possible, of the data concerning you;
A right to limitation of processing: you may, in certain cases provided by the regulations, obtain the limitation of the processing of data concerning you;
A right to data portability: you may, under the conditions set by the regulations, require the transmission of data concerning you to another data controller, without the Company that initially collected them being able to oppose it;
A right to object: you have the possibility to object to the data concerning you being subject to processing or to refuse the communication of information concerning you to third parties.

For any additional information you would like to obtain on these protective provisions, or for any possible introduction of a complaint with a supervisory authority, you may contact the Commission for the Protection of Personal Data ("Bulgarian Commission for Personal Data Protection"), at the following address:

1 Dondukov Boulevard
1000 Sofia, Bulgaria
Telephone: +359 2 940 2046
Fax: +359 2 940 3640
Email: kzld@government.bg
Website: http://www.cpdp.bg

Furthermore, we inform you that:

You may very well choose not to transmit your Data on the Site. In this case, you may freely navigate on it, but certain parts of the Site and certain Services will then be unavailable (for example, placing an order);
At any time, you may update or correct your personal information in your Account profile page.

9 – CONFIDENTIALITY REGARDING CHILDREN

The Site and Services are only accessible to adult users, i.e., 18 years of age or older. We therefore do not authorize users under the age of 18 and do not knowingly collect personal data from any minors under 18, who are subject to specific protection under the GDPR.

10 – UPDATES TO THE PRIVACY CHARTER

The Company may modify this Privacy Charter at any time.

All modifications to the Charter will be posted on this page. If the changes are significant, the Company undertakes to provide you with a more substantial notice (notification by email, for example).

11 – QUESTIONS, COMPLAINTS OR SUGGESTIONS

We want to offer you the greatest clarity, precision, and efficiency regarding the confidentiality of your Data. Therefore, for any questions, suggestions, or other concerns relating to the processing of Data or the way the Company collects and uses Data concerning you, do not hesitate to contact us about this via the "Contact" section of the Site.