Privacy Policy

TOP SERVICE EOOD carries out deliveries of food and other products (collectively referred to as “the Products”) from Restaurant Raketa Rakia Bar. The purpose of this Privacy Policy (the Policy) is to define the conditions under which TOP SERVICE manages personal data in connection with the delivery of the Products.

This Policy contains the information provided to the subject of personal data within the meaning of Art. 13 of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR).

The Customer agrees to this Policy at the time of accepting the General Terms and Conditions of the contract for the use of the services provided by “Top Service” EOOD via an online ordering website (GTC). Terms and concepts designated in this Policy with a capital letter (such as Customer, Website) have the meaning defined in the GTC.

Personal Data Controller

TOP SERVICE EOOD, a company duly registered according to Bulgarian and European legislation, with its registered office and management address: 17 Yanko Sakazov Blvd., Sofia 1504, Bulgaria, with UIC 201746357, which operates the restaurant Raketa Rakia Bar and provides food and other product delivery services.

Correspondence Address with the Personal Data Controller

17 Yanko Sakazov Blvd., Sofia 1504, Bulgaria, tel.: +35924446111, email address: raketarakiabar@gmail.com

Subject of Personal Data

A subject of personal data within the meaning of this Policy is a natural person who places orders for Products through the site raketarakiabar.bg, hereinafter referred to as the “Customer.”

Definition of Personal Data

Personal data, according to the definition of Art. 4, item 1 of the GDPR, is any information through which a natural person can be identified – directly or indirectly. This includes, for example: Name, Personal ID Number (EGN), Personal Number of a Foreigner (LNCH), or another unique identifier; Contact data – email, phone number, address; Online identifiers – username, IP address, etc. Some data may not identify the Customer independently (e.g., a phone number), but in combination with others – such as a name or username – would allow for the establishment of the Customer’s identity. Direct identification occurs when the Customer provides a unique identifier such as an EGN or LNCH.

Categories of Personal Data Collected by TOP SERVICE for the Customer and Purposes of Processing

In order to provide effective access to its services, TOP SERVICE collects and processes personal data of the Customer. Below are the types of personal data that TOP SERVICE collects about the Customer and the reasons (purposes) for which TOP SERVICE processes these personal data:

Data that the Customer provides voluntarily when ordering Products from the website raketarakiabar.bg (hereinafter referred to as the Website):

  1. The information that the Customer fills in when ordering Products from the Website of TOP SERVICE – https://raketarakiabar.bg/ is the following: first and last name, mobile phone, email address, delivery address. TOP SERVICE collects and processes these data on a contractual basis within the meaning of Art. 6, item 1, letter “b” of the GDPR – in order for TOP SERVICE to be able to fulfill the contract with the Customer.
  2. Information for the purpose of direct marketing – in the event that, by marking the relevant field on the Website, the Customer has given their explicit consent for this, TOP SERVICE collects and processes information for the purpose of sending commercial messages by email or via SMS related to products and services provided by TOP SERVICE. For the avoidance of any doubt, the Customer’s consent to this Policy will not be considered consent for commercial messages for marketing purposes. In order for the Customer’s data to be used for marketing purposes, it is necessary for them to provide separate explicit consent by marking a specially designated checkbox for this purpose on the Website, or in another appropriate way.
  3. Information on order history: TOP SERVICE uses information about the Customer’s order history to send the Customer personalized marketing and advertising messages related to TOP SERVICE’s delivery services, including Products offered in Restaurant Raketa Rakia Bar that may be of interest to the Customer. TOP SERVICE also uses the information provided in this way to perform analyses and research for the purpose of improving and developing its services and ensuring the Customer a better experience when using the services of TOP SERVICE.
  4. Personal data collected through “cookies” and similar technologies that track the Customer’s behavior while using the Website, as well as their IP address, browser type, type and model of terminal device, so that TOP SERVICE can:
    • measure and analyze the use and effectiveness of TOP SERVICE’s services, including by submitting data to platforms such as Google Analytics, Facebook Pixel;
    • personalize and optimize the targeting of advertisements for TOP SERVICE’s services on other websites and platforms.
  5. Information collected through subscription to the Raketa Rakia Bar Newsletter. When the Customer subscribes to the email newsletter of TOP SERVICE, they will be asked to enter their email address. To administer and manage the distribution of the newsletter to users who have given consent, TOP SERVICE maintains a register of the Customer’s IP address, the emails the Customer opens, and the links the Customer clicks in those emails, to more accurately recommend content to the Customer and Products that the Customer may consider valuable. Any personal information that the Customer provides to TOP SERVICE, including the email address, will not be provided or sold to third parties.

Right to Withdraw Consent

The consent provided by the Customer may be withdrawn at any time by sending an email to the electronic address specified above in this Policy or a written statement to the correspondence address of TOP SERVICE, also specified above. The withdrawal of consent may refer to one or more purposes for which the data is processed. For example, in the event that the Customer withdraws their consent to receive marketing messages, their contact data will continue to be used to maintain their profile on the Website (if one was created) and to carry out their orders. In this case, the contact data will be processed on a contractual basis. In the event that the Customer wants to erase data without which it is impossible to maintain their profile on the website, the profile will be erased, and for subsequent use of TOP SERVICE’s services, it will be necessary for the Customer to provide their data again.

Period of Storage of Personal Data

TOP SERVICE will keep the Customer’s personal information for no longer than is necessary to fulfill the purposes described in this Privacy Policy. Depending on the basis on which TOP SERVICE processes the Customer’s personal data, the period of storage of the personal data is different. The Customer’s personal data is stored by TOP SERVICE for a period of 5 years from the termination of the contractual basis, if TOP SERVICE processes the personal data for the fulfillment of contractual obligations to the Customer, respectively until the termination of the basis if the only one is for the protection of the legitimate interests of TOP SERVICE and/or for the periods specified in the legislation if the basis for processing is for the fulfillment of legal obligations. After the expiration of this period and in the event that there is no legal basis for continuing the storage of the Customer’s personal data, the information about the Customer is destroyed. The personal information about the Customer is deleted from TOP SERVICE’s system. When the Customer provides data for the purposes of creating their user profile on a website, mobile application, etc., TOP SERVICE will consider that the Customer has an interest in storing these data until the erasure/deactivation is undertaken by them. TOP SERVICE may also retain certain elements of the Customer’s personal information for a period after the Customer erases or deactivates their user profile for the legitimate operations of TOP SERVICE, such as maintaining archives and complying with the legal obligations of TOP SERVICE. Every time TOP SERVICE retains the Customer’s information, TOP SERVICE will do so in accordance with the applicable legislation. Upon consent provided by the Customer for their data to be used for receiving marketing/advertising messages, the period for processing them for this purpose is until the withdrawal of the Customer’s consent.

Provision of Personal Data to Third Parties

Without the explicit consent of the Customer, TOP SERVICE does not provide the Customer’s personal data to third parties for purposes other than the fulfillment of its contractual obligations to them. TOP SERVICE uses software solutions and contractors in the performance of its services who maintain parts of the service and may share part of the Customer’s personal data with them for the purposes of exercising its contractual rights and obligations; for example, platforms are used for plotting and optimizing delivery routes to an address, in which only the address specified by the Customer is entered. TOP SERVICE may share the Customer’s personal information with the following recipients (in each separate case, TOP SERVICE will ensure that it has appropriate protective and contractual guarantees to protect it):

  1. The employees in the kitchen and/or delivery of restaurant Raketa Rakia Bar, to whom the Customer’s orders have been submitted for execution;
  2. Persons who, on a contractual basis other than an employment relationship with TOP SERVICE, perform the physical delivery of the Products to the Customer’s address;
  3. Third parties that support the services of TOP SERVICE (for example, partners for marketing or promotions in the food, beverage, and entertainment sectors based on the Customer’s preferences, provided there is a legal basis and the Customer’s rights are not preferentially affected over those of TOP SERVICE, courier services, companies related to web hosting);
  4. Any law enforcement or regulatory body, judicial authority, or other third party when disclosure is necessary under applicable laws or regulations;

TOP SERVICE Cookie Policy

“Cookies” are small text files that are recorded on the Customer’s device when visiting TOP SERVICE’s Website. TOP SERVICE may automatically receive certain information about the Customer and their device using tracking technologies based on the browser or device, described below. These technologies allow TOP SERVICE to ensure that its services function correctly, to improve its services, to provide and measure advertisements, as well as to provide personalized content for the Customer. The Customer can manage the way these tracking technologies are used by adjusting the settings on their device or browser. In some cases, the Customer may opt out of tracking by TOP SERVICE’s analytics providers by directly visiting their opt-out pages.

Specific tracking technologies and purposes of their use:

  • Cookies: Cookies are small information files stored in the Customer’s browser or device. They can be sent by the subject that operates the website the Customer visits (“first-party cookies”) or by other companies (“third-party cookies”).
  • Pixels: Pixels are small images on a web page or in an email. Pixels collect information about the Customer’s browser or device and can set cookies in their browser.
  • Local Storage: Local storage allows data about the Customer’s browser or device to be stored locally on their browser or device and includes HTML5 local storage and browser cache.
  • SDKs: SDKs (also known as “software development kits”) are blocks of code, usually provided by TOP SERVICE’s partners, which can be installed in its applications. SDKs can help TOP SERVICE understand how the Customer interacts with its applications and can collect information about the device and network the Customer uses to access its applications, such as the advertising identifier associated with its device, or information about how the Customer interacts with its applications.

The purposes for which TOP SERVICE uses cookies and similar technologies generally fall into the following categories:

  • Strictly Necessary: Examples include performing or facilitating the transmission of communications over a network, as well as technologies that are strictly necessary to provide an online service (e.g., Food orders through TOP SERVICE’s Website).
  • Functional: Examples include helping to ensure that TOP SERVICE’s services function correctly, remembering the Customer’s settings and preferences (such as their language preferences), helping to identify and prevent security risks, or helping TOP SERVICE understand and improve its services.
  • Performance: Examples include collecting information about how the Customer interacts with TOP SERVICE’s services and personalizing the content for the Customer.
  • Targeting: Examples include making advertising more relevant and meaningful to the Customer. They may also include “social cookies” that enable the Customer to share content with their friends on social media platforms, such as Facebook or Instagram.

Browser Controls

Although most browsers and devices accept cookies by default, their settings usually allow the Customer to clear and reject cookies. Web browsers often store the Customer’s preferences in a cookie. Blocking cookies may prevent the services from working as expected and may also prevent the storage of the Customer’s preferences and choices. Listed below are certain common web browsers, and the Customer has the opportunity to search for their opt-out pages for cookies. If the Customer’s web browser is not listed here, the Customer should review the terms of their web browser to learn more about its cookie capabilities.

  • Google Chrome
  • Apple Safari
  • Mozilla Firefox
  • Microsoft Internet Explorer

Rights of the Customer regarding the provided personal data

In the event that the Customer is a registered user of TOP SERVICE, through a user profile, they have access to their profile at any time to review and update their personal information, i.e., their personal data. The Customer may also contact TOP SERVICE to request that TOP SERVICE update or erase their personal data, as well as restrict their processing. Furthermore, the Customer has the right to terminate their subscription to the marketing messages that TOP SERVICE sends by using the unsubscribe function from any marketing communication they receive from TOP SERVICE, or by sending an email to the contact email address specified above. In addition, according to Bulgarian and European legislation, the Customer may exercise the following rights: The right of access to the personal data that TOP SERVICE processes about the Customer and to receive a copy of them; The right to request from TOP SERVICE correction, in the event they find inaccuracies or a need to update their personal data, by sending an email to the contact email address specified above; The right to request erasure, i.e., deletion of their personal data from TOP SERVICE; The right to object to the processing of their personal data; The right, whenever they wish, to withdraw the consent given by them for their personal data to be processed for marketing or other purposes for which they have given consent; The right to object and not be the subject of a decision based solely on automated processing, including profiling, which gives rise to legal consequences for the Customer or similarly affects them to a significant degree; The right to object to the provision of their personal data to third parties; The right to submit a request for portability of their personal data in a structured, machine-readable format that is commonly used; The right to file a complaint against the processing of their personal data to TOP SERVICE or to the supervisory authority – Commission for Personal Data Protection, in the event that the prerequisites for this are present. The Customer may exercise all rights at any time during the processing of their personal data.

TOP SERVICE recommends that the Customer periodically review this page to be familiar with the latest version of TOP SERVICE’s Privacy Policy. The date of the last update and changes to the Privacy Policy is indicated at the bottom of this document.

Use of Chatbot

A “Chatbot” is a software application using Artificial Intelligence (AI) that automates communication with Customers through the exchange of text messages on the Website. The Chatbot mimics human conversations, providing answers to questions, performing specific tasks, or providing information, interacting with the Customer in real time and giving them personalized suggestions based on identified preferences, actions, and time spent on the Website. In communication by the Customer with the Chatbot, profiling of the Customer’s behavior is performed for the purpose of providing suitable Products and services according to their personal preferences. For the avoidance of doubt, we state that all Chatbots work on this principle and perform profiling.

Technical and Organizational Protection Measures

With this Privacy Policy, TOP SERVICE declares that it applies all technical and organizational measures for the protection of personal data of natural persons that are prescribed by law or another normative act at the national and European level. Specifically, the following measures are subject to application in the organizational structure of TOP SERVICE: Organizational management and dedicated personnel responsible for the development, implementation, and maintenance of the information security program of TOP SERVICE.

  1. Procedures for audit and risk assessment for the purposes of periodic review and assessment of the risks to TOP SERVICE’s organization, monitoring and maintaining compliance with TOP SERVICE’s policies and procedures, and reporting the state of its information security and compliance to internal senior management.
  2. Data security control, which includes as a minimum, but is not limited to, logical separation of data, restricted access (e.g., based on roles) and monitoring, and use of commercially available and industry-standard technologies for encryption of Personal Data that are:
    • 3.1. transmitted over public networks (i.e., the Internet) or during wireless transmission; or
    • 3.2. at rest or stored on portable or removable media (i.e., laptops, CD/DVD, USB devices, backup tapes).
  3. Logical access controls designed to manage electronic access to data and system functionality based on levels of authority and job functions (e.g., granting access on a “need-to-know” basis).

This Policy was approved by the Manager of TOP SERVICE on 16.12.2025.