Privacy Policy


We take the protection of data privacy seriously

The protection of your privacy in the processing of personal data is important to us. When you visit our website, our web servers will by default save the IP of your Internet Service Provider, the website from which you visit us, the web pages you visit as well as the date and the duration of your visit. This information is necessary for the technical transmission of the websites and a reliable server operation. A personalized evaluation of these data does not take place.

If you send us data via a contact form, these data will be saved on our servers in the course of the data backup. We will use your data exclusively for the processing of your request. Your data will be treated as strictly confidential. It will not be disclosed to a third party.

Responsible party:

Eleen Marine JSC
Sofia, bul. “Akademik Peter Dinekov”, 23

Tel.: (+359) 2 437 2115

Personal data

Personal data are data about your person. They include your name, your address and your e-mail address. You do not have to disclose any personal data in order to be able to visit our website. In some cases, we will require your name and address as well as other information in order to be able to offer you the requested service.

The same applies in case you want to receive information material or if we answer your requests. In these cases, we will always point this out. We will only save the data that you have automatically or voluntarily sent to us.

If you use one of our services, we will usually only collect the data required to offer you our service. We might ask you for additional information which are, however, of a voluntary nature. Whenever we process personal data, we do this so we can offer you our service or to pursue our commercial goals.

Automatically saved non-personal data

When you visit our websites, we save certain information for administrative and technical reasons. These are the following: Type and version of the browser used, data and time of day of the visit as well as the IP address.

These data will be anonymized and used only for statistical purposes or to improve our Internet and online services.

These anonymized data will be – separate from the personal data – saved on secure systems and cannot be assigned to any individual person. This means that your personal data are protected at all times.


When you use our websites, we might save information on your computer in the form of cookies. Cookies are small files that are transmitted from an Internet server to your browser and saved on the hard drive. Section 6 Para. 1 lit f GDPR forms the legal basis for the use of cookies.

Only the protocol address is saved in the process – no other personal data. The information saved in the cookies makes it possible to automatically recognize you during the next visit, which makes it easier for you to use it.

Of course, you can also visit our websites without cookies. If you don’t want that your computer is identified during the next visit, you can also reject the use of cookies by changing the settings in your browser to “Do not accept cookies”. Refer to the instructions of your corresponding browser to learn how to proceed. However, if you do not accept cookies, the use of some areas of our website might be restricted.

Google Double-click

Double-click by Google is a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Double-click by Google uses cookies in order to show you relevant ads. For this purpose, a pseudonym identification number (ID) will be assigned to your browser in order to check which ads were shown in your browser and which ads were clicked on. The cookies do not contain any personal information. The use of the Double-click cookies allows Google and its partner websites only to place ads based on previous visits to our website or others on the Internet. Google will transmit the information generated by the cookie to a server in the USA and store it at this location. Google complies with the data protection regulations of the “Privacy Shield” agreement and is registered with the “Privacy Shield” program of the US Department of Commerce. Google will transmit data to third parties only when required by legal provisions or within the scope of the processing of order data. Google will never combine your data with other data collected by Google.

By using our website, you agree with the processing of the data collected about you by Google and with the described method of data processing as well as with the named purpose. You can prevent the storage of cookies via a corresponding setting of your browser software; however, we would like to point out that in this case you won’t be able to make full use of all the functions on our website. In addition, you can prevent the collection of the data by Google generated by the cookie and related to the use of the website as well as the processing of these data by Google by downloading and installing the browser plug-in available under the following link under the item Double-click deactivation add-on. Alternatively, you can also deactivate the Double-click cookies with this opt-out

Google reCaptcha

The LSW uses the reCAPTCHA service offered by Google Inc. (Google) to protect your orders made via Internet forms. The query is used to see whether the input is being made by a human being or fraudulently via automated machine processing. The query will also send the IP address and possibly other data required for the reCAPTCHA service to Google. For this purpose, your input will be transmitted to Google, where it is processed further. By using reCaptcha, you agree that identification provided by you will enter into the digitization of older works. If the IP anonymization on this website is activated, Google will first shorten your IP address within the member states of the European Union or other signatories of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the USA and shortened at this location. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address sent by your browser within the scope of reCaptcha will not be combined with other data from Google. The deviating data protection provisions of Google apply to these data. For more information regarding the privacy policies of Google, go to:

Google Maps

This website uses Google Maps to display maps and to generate route maps.

Google Maps is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

By using Google Maps on this website, you agree with the collection, processing and use of the automatically collected data as well as the data you entered by Google or one of its representatives or third party providers.

You will find the terms of use for Google Maps here.

Click here to view the data privacy statement from Google Maps.

YouTube in extended data protection mode

We use YouTube to incorporate videos. The videos have been embedded in the extended Data Privacy Mode. Like most other websites, YouTube also uses cookies in order to collect information about the visitors to their website. YouTube uses them to create video statistics, prevent fraud and improve user-friendliness, for example. This will also lead to a contact with the Google Double-click network. When you start the video, this could trigger further data processing. We have no influence in this regard. For more information on data protection at YouTube, you will find the data privacy statement at: 


We have taken technical and administrative safety precautions to protect your personal data against loss, destruction, manipulation and unauthorized access. All of our employees as well as service providers working for us are obligated to comply with the applicable data protection laws.

Whenever we collect and process personal data, they will be encrypted before their transmission. This means that your data can not be misused by a third party. Our safety precautions are constantly improved and our data protection statements are continuously revised. Please make sure that you have the latest version available.

Rights of persons affected

Please do not hesitate to contact us if you want to know which of your personal data we save or if you want to have them corrected or deleted. You also have the right to restrict the processing (Section 18 GDPR), the right to object to the processing (Section 21 GDPR) as well as the right to data portability (Section 20 GDPR).

Please contact us in these cases.

Amendments to this data privacy statement

We reserve the right to change our data privacy statements in case this should become necessary due to new technologies. Please make sure that you have the latest version available. All important changes to this data privacy statement will be disclosed on our website.

In regard to data protection, all interested parties and visitors to our website can contact us at:

Eleen Marine JSC
Sofia, bul. “Akademik Peter Dinekov”, 23

Tel.: (+359) 2 437 2115

Should our data protection officer not be able to address your concern to your satisfaction, you will have the right to appeal at the regulatory authority responsible in your federal state.


The protection of your personal data is a special concern to us. Therefore we only process your personal data (in short, “data”) on the basis of legal provisions. This data privacy statement is intended to provide you with information about the processing of your data in our company and the claims and rights that you have under data protection law within the meaning of art. 13 of the European General Data Protection Regulation (EU-GDPR).

1. Who is responsible for data processing and whom can you contact?

The data controller is

Eleen Marine JSC
Sofia, bul. “Akademik Peter Dinekov”, 23

Tel.: (+359) 2 437 2115

2. What data is processed and what are the sources of this data?

We process the data that we receive from you as part of initiating or executing the contract, based on consent or in the context of your application or employment with us.

Personal data includes:

Your reference/contact data, which for customers includes first and last name, address, contact information (e-mail address, phone number, fax), bank details etc.

For applicants and employees, this includes first and last name, address, contact information (e-mail address, phone number, fax), date of birth, data from CV and employer’s references, bank details, religious affiliation, pictures etc.

For business partners, this includes the name of your legal representative, company, commercial register number, VAT ID no., company registration number, address, contact information for point of contact (e-mail address, phone number, fax), bank details etc.

For those visiting our company, this includes name and signature.

For journalists, this includes first and last name, e-mail address, fax number.

For contest participants, this includes first and last name, e-mail address.

We also process the other following personal data:

  • information about the nature and content of contractual data, order data, sales and document data, customer and supplier history and consultation materials,
  • advertising and distribution data,
  • information from your electronic traffic with us (such as IP address, login info),
  • other data that we have received from you in the context of our business relationship (such as in customer meetings),
  • data that we generate ourselves from reference/contact data or otherwise, such as through analysis of customer needs and customer potential,
  • documentation of your consent form for receiving newsletters, etc.,
  • photos taken at events.

 3. For what purposes and on what legal basis is data processed?

We process your data in compliance with the provisions of the General Data Protection Regulation (GDPR) and the 2018 Federal Data Protection Act in its current valid form:

  • to fulfill (pre-)contractual obligations (art 6(1)b GDPR):

Your data is processed online or in one of our branches in order to process the contract for your employment in our company. In particular, data is processed when business is initiated and contracts are implemented with you.

  • to fulfill legal requirements (art 6(1)c GDPR):

It is required to process your data for the purpose of fulfilling various legal requirements, such as from the commercial code or tax code.

  • to safeguard legitimate interests (art 6(1)f GDPR):

Due to a balancing of interests, data may be processed beyond the actual fulfillment of the contract in order to safeguard our legitimate interests or those of third parties. Data will be processed to safeguard legitimate interests in the following cases, for example:

–              advertising or marketing (see no. 4),

–              measures for business management and further development of services and products;

–              keeping a group-wide customer database to improve customer service

–              as part of the prosecution

–              sending non-promotional information and press releases.

  • in the context of your consent (art 6(1)a GDPR):

If you have given us your consent to have your data processed, e.g. to send our newsletter, publish photos, contests etc.

4. Processing of personal data for advertising purposes

You may object to the use of your personal data for advertising purposes at any time, in whole or to individual actions, without incurring costs other than those for transmission based on the base rates.

According to the statutory conditions under § 7(3) of the Unfair Competition Act, we are entitled to use the e-mail address that you provided us when concluding the contract for direct advertising of our own similar goods or services. You will receive these product recommendations from us regardless of whether you have subscribed to a newsletter.

If you do not wish to receive any recommendations like this via e-mail, you can object to the use of your address for this purpose at any time, without incurring costs other than those for transmission based on the base rates. Notification in text form is sufficient for this. Each e-mail will also always include a link to unsubscribe.

5. Who receives my data?

If we use a service provider in the sense of processing an order, we will still be responsible for protecting your data. All order processors are contractually obliged to handle your data as confidential and only to process it in the context of rendering services. The order processors we commission will receive your data where this is necessary in order to fulfill the respective service. This includes IT service providers whom we require for the operation and security of our IT system, as well as advertising and address publishers for our own ad campaigns.

Your data will be processed in our customer database. The customer database helps to improve the data quality of existing customer data (duplicate cleansing, removed/defunct registration numbers, address corrections) and allows it to be supplemented with data from public sources.

This data is made available to the companies in the group where necessary for executing a contract. Customer data is stored on a company basis and separately, whereby our parent company acts as a service provider to the individual participating companies.

If there is a legal requirement or as part of prosecution, authorities, courts and external auditors may be recipients of your data.

Insurance companies, banks, credit agencies and service providers may also be recipients of your data for the purpose of initiating and fulfilling contracts.

6. How long will my data be stored for?

We process your data until the end of the business relationship or until the valid legal retention periods have expired (e.g. from the commercial code, the tax code or the Working Hours Act); additionally, until the end of all legal disputes in which the data is needed as evidence.

7. Will personal data be transmitted to a third country?

We do not transmit any data to third countries as a general rule. Data will only be transmitted in isolated cases based on an adequacy decision by the European Commission, standard contractual clauses, applicative warranties or your express consent.

8. What are my data protection rights?

Anytime, you have the right to obtain information, correction, erasure or restriction of the processing of your stored data, right to object to processing and the right to data portability and to lodge a complaint under the conditions of the data protection law.

Right to information:

You may request information from us on whether and to what extent we process your data.

Right to correction:

If we process your data and it is incomplete or inaccurate, you may request that we complete or correct it at any time.

Right to erasure:

You may request that we erase your data if we are processing it unlawfully or the processing of it unreasonably infringes on your legitimate interests. Please note that there may be reasons that preclude immediate erasure, e.g. in the event of retention periods regulated by law.

Regardless of whether you exercise your right to erasure, your data will be immediately and completely erased if there are no contractual or statutory retention periods that preclude this.

Right to the restriction of processing:

You may request the restriction of the processing of your data if:

–              you dispute the accuracy of the data, and for a period that allows us to review the accuracy of the data.

–              your data is processed unlawfully, but you decline its erasure and instead request that its use be restricted,

–              we no longer need data for its intended purpose, but you still require the data to assert or defend legal claims, or

–              you have lodged an objection to the processing of data.

Right to data portability:

You may request that we provide the data you have given us to you in a structured, common and machine-readable format and that you may have us transmit this data to another controller without hindrance if:

–              we process this data based on the revocable consent granted by you or to fulfill the contract between us, and

–              processing is completed by automated means.

Where technically feasible, you may request that we directly transmit your data to another controller.

Right of objection:

If we process your data for legitimate interests, you may object to this data processing at any time. We will then no longer process your data unless we can demonstrate compelling reasons for processing that are worthy of protection and outweigh your interests, rights and freedoms or unless processing serves the purpose of asserting, exercising or defending legal claims. You may object to the processing of your data for the purpose of direct advertising at any time without stating reasons.

Right to lodge a complaint:

If you believe that we have violated German or European data protection law in processing your data, we ask that you contact us so that we can resolve the issues. You naturally also have the right to contact your responsible regulatory authority, the respective state office for data protection supervision.

If you wish to assert one of the rights above against us, please contact our data protection officer. In case of doubt, we may request additional information to confirm your identity.

9. Am I obligated to provide data?

The processing of your data is necessary to conclude or fulfill your contract with us. If you do not provide us with this data, we will generally have to refuse to conclude the contract or we will no longer be able to implement an existing contract, and subsequently terminate it. However, you are not obligated to consent to the processing of data that is not relevant to contractual fulfillment or not legally required.