Privacy Policy

Principles of VSh’s Privacy Policy

“VSh” Ltd. strictly monitors the security and integrity of all personal data collected from our customers.

We process personal data lawfully, fairly and in a transparent manner in relation to the data subjects.

We collect personal data for specified, explicit and legitimate purposes and do not further process data in a manner that is incompatible with those purposes.

The data we collect is adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed. We make every effort within our organization to ensure that personal data is accurate and, where necessary, kept up to date; in cases, when personal data is inaccurate, having regard to the purposes for which it is processed, we undertake that such data is erased or rectified without delay.

We never store data for a period longer than necessary for the purposes for which it is processed.

We provide data subjects the opportunity to withdraw their consent to process their data at any time and without giving reasons, as well as to delete their data, upon request.

At the same time, it is our priority that processing is carried out in such a way as to guarantee the appropriate level of security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. We have implemented the technical and organizational measures necessary and prescribed in the applicable legislation to ensure the protection and security of the personal data of our customers.

“VSh” Ltd. complies with the provisions of the applicable legislation (General Data Protection Regulation- Regulation (EU) 2016/679, the Bulgarian Personal Data Protection Act, etc.)


Personal data” – any information relating 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.

“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.

Our privacy policy also describes the options we provide for data subjects to access, update or otherwise take control of their personal data. If you have any questions about our practices or any of your rights described below, you can contact our team at This mailbox is actively monitored and managed.

What data do we collect?

“VSh” Ltd. collects and processes personal data in connection with the use of the online platform, more specifically processing shall be lawful only if and to the extent that at least one of the following applies:

Purpose for which the data is collected:

We collect names and e-mails in order to establish contact with the user and send information, to register a user at our online platform, to ensure the performance of the contract for the provision of the relevant goods, as well as to send a newsletter.

We collect the customer’s date of birth in order to ensure that the person is of legal age to make a purchase of artwork of significant value. According to Bulgarian legislation, persons who have not reached the age of 14 are minors. In their stead and on their behalf, legal actions are performed by their legal representatives – parents or guardians. Persons from 14 to 18 years of age can perform legal actions with the consent of their parents or guardians.

Lawfulness of processing this personal data:

Express consent received from the customer; taking steps to conclude a contract and concluding a contract – by  registering at the online platform or placing an order without registration, as well as by purchasing  and requesting delivery from our online platform, a contractual relationship is created, on the basis of which we process your personal data.

A photo is provided only under customer’s discretion and only on the basis of his consent. If the customer decides to provide a photo, he will participate in the blogs and reviews on the platform and will benefit from all the functionalities of the site.

Gender is provided only under customer’s discretion and solely on the basis of his consent. We use gender information to carry out our marketing researches.

Purpose for which the data is collected:

Fulfillment of the administrator’s obligations under the sale contract and delivery of the purchased goods, including when exercising the right of return and exchange or refusal of the purchased goods.

Lawfulness of processing this personal data:

Fulfillment of the administrator’s obligation to deliver the purchased goods.

Purpose for which the data is collected:

We process these personal data in order to fulfill obligations arising from accounting and tax legislation – tax and accounting legislation in the Republic of Bulgaria requires that certain accounting and commercial information be compiled, including that this information, as well as any other information and documents, be stored for a certain period of time relevant for taxation. When fulfilling this obligation, the relevant information and documents, which also contain personal data, are stored for the periods stipulated in the relevant laws.

Lawfulness of processing this personal data:

Compliance with legal obligations that apply to the company.

The company does not collect and process data for persons under the age of 16, except with the express consent of their parents or legal representatives.

Purpose for which the data is collected:

Implementation of a payment method for the artwork ordered by the customer.

Lawfulness of processing this personal data:

Fulfilling the obligations of the parties to the contract for the purchase of the artworks.

Please note that for making payments from our customers, we use the “myPOS Service”. It is a FinTech platform providing the option to receive POS payments (card-present) and online payments (card-not-present) in various currencies with immediate settlement in one or more e-money accounts, as well as other payment services, provided by the Company for electronic money – “Icard” AD, with headquarters and management address at Business Park Varna, building B1, postal code 9009, Varna, Bulgaria, with EIC 175325806, licensed and regulated by the Bulgarian National Bank according to Directive 2009/110/ EC (“Electronic Money Directive”) with license number no. 4703-5081/25.07.2011, having the right to provide electronic money, payment services and cards in the EU/EEA under the Payment Services Directive and the EU Electronic Money Directive.

Please note that once you have agreed to the relevant terms of the Electronic Money Company – “Icard” JSC, it will process your personal data as a data controller in accordance with its own privacy policy, which can be found at the following address: We are not responsible for further processing carried out by this company and you should direct any complaints relating to the use of your data to them.

Purpose for which the data is collected:

Implementation a payment method for the artwork ordered by the customer.

Lawfulness of processing this personal data:

Fulfilling the customer’s obligation to pay the price of the purchased artwork.

Please note that in such cases, we might use the services of Onfido ( services for identification and identity verification. It is an online platform providing the ability to authenticate a person’s identity, verify identity documents and prevent fraud.

Please note that once you have selected this payment method and agreed to the relevant Onfido terms and conditions, this company will process your personal data according to its own privacy policy, which can be found at the following address: We are not responsible for further processing carried out by this company and you should direct any complaints relating to the use of your data to them.

Purpose for which the data is collected:

Offering and selling the works of the artists we have concluded contracts.

Lawfulness of processing this personal data:

Fulfillment of obligations of “VSh” Ltd. under the contracts with the artists for the offer and sale of their works, in some cases – their express consent.

Sharing/transfer of personal data

“VSh” Ltd. does not share, sell, rent, trade or transfer personal data collected from its customers.

There are exceptions where your personal information may be disclosed to third parties as follows:

It may be transferred as an asset in connection with a business merger or sale or as part of our business or as part of a corporate reorganization or other changes in corporate governance.

It can be provided to the service providers who assist us in providing our goods – couriers, accountants, insurance companies. No supplier can have access to personal data stored by “VSh” Ltd. without a prior data confidentiality agreement, which gives “VSh” OOD the right to verify compliance with the obligations accepted by the agreement. We transfer the collected personal information only to our trusted partners, together with whom we carry out the organization and provision of the works offered by us. Before any such transfer of data, we check that these providers provide sufficient guarantees that they apply appropriate technical and organizational measures, in such a way that the processing meets the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679), of the Bulgarian Personal Data Protection Act, as well as our privacy policy and to ensure the protection of the rights of the data subject. In accordance with the principle of minimizing the data that is processed, these providers receive only that personal information that they need to perform their functions.

Service providers are not permitted to retain data for their own or independent purposes or benefit, nor to retain it for longer than is necessary to perform the specified service.

We share personal data with the supplier when we have your express permission to do so or when there is another legal basis to do so (for example an obligation to deliver the purchased work).

Finally, personal data may be provided to government authorities (e.g. control authorities and their subdivisions, authorities for the detection and prevention of crimes and violations) only when provided for by law and under the conditions specified therein.

“VSh” Ltd. does not transmit/share your personal data with administrators and processors in countries outside the EU.

Term and duration of personal data processing by “VSh” Ltd

“VSh” Ltd. stores personal data of customers for a period not longer than the existence of their profile in the online platform or until the consent to processing is withdrawn.

 After deleting your account or withdrawing your consent, “VSh” Ltd. takes the necessary care to delete and destroy all your data without undue delay or to anonymize it (i.e. reduce it to a form that does not reveal your identity).

“VSh” Ltd. stores your personal data, provided in connection with online orders, for a period of 5 years for the purpose of protecting its legal interests in legal or administrative disputes with users of the online store. Accounting documents are kept for the relevant statutory period.

“VSh” Ltd. notifies you in the event that the data storage period needs to be extended in order to fulfil a legal obligation or in order to meet the legitimate interests of the administrator or otherwise.

Your rights as a customer in relation to the personal data provided.

You have the right at any time to request information about whether your personal data is stored, the purposes for which it is processed, what categories of personal data are processed, the recipients to whom the personal data is disclosed, the expected period for which it will be stored, the existence of automated decision-making, including profiling.

If you have given consent to the use of your data, you can withdraw it at any time with effect in the future, without having to give reasons.

Your request to withdraw your consent can be sent to us by email:

If you find that your data stored by us is inaccurate, you can contact us to correct it.

You have the right to request that we delete your data without undue delay. We will delete it within a reasonable time, as soon as we are satisfied that there are no other grounds that require its processing/storage.

After the deletion of your data, it is no longer possible to provide information.

In certain cases, e.g. if you dispute the accuracy of the data, when checking the grounds for their storage, etc., you have the right to request that we limit the processing of your personal data. During the restriction, we can only store the personal data, and other processing activities are only possible with your consent.

Upon your request, we will transmit or transfer the data to you or another controller in a structured, widely used and machine-readable format. Direct transfer of the data only takes place if this is technically feasible.

You can at any time and without stating reasons object to the processing of your personal data for the purposes of direct marketing, including profiling, as well as in cases where your data is processed on the basis of the performance of a task of public interest or the processing is necessary for the purposes of our legitimate interests.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.

“VSh” Ltd. does not carry out such data processing.

You have the right to file a complaint against the processing of your personal data before the competent supervisory authority (in Bulgaria – the Commission for the Protection of Personal Data or the court) if you believe that your rights to the protection of personal data have been violated.

The Commission for the Protection of Personal Data

address: Sofia, p.k. 1592, Prof. Blvd. Tsvetan Lazarov” No. 2

phone: 00359 2 915 3518

Center for information and contacts



Contacts of “VSh” Ltd and details of the data protection officer:

“VSh” Ltd

with address: Gabrovo, p.k. 5300, “St. B. Gencheva” No. 25

phone: 00359 896 899 945

Vasil Petrov Shandurkov



Please note that when you contact us via the above email, the data you provide (your email, possibly your name and your phone number) is processed by us in order to answer your questions and resolve the problem you placed.

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