Privacy Policy

The “Purple Wardrobe” game by Outlet Village Sofia

In force from 26.10.2026

This is a translation of the Bulgarian original. If the two versions differ, the Bulgarian text prevails.

This policy explains what personal data we collect when you sign up and play on the game’s websites (promo.outletvillage.bg and outletvillage-promo.bg), why, how long we keep it and what your rights are. It supplements Section X “Personal data” of the Official Rules of the Game. If they differ, the Official Rules prevail.

1. Who is responsible for your personal data

The controller of your personal data is the Organiser of the game:

NITRAM COMMUNICATIONS, UIC 203535184, registered office and address of management: 18A Angel Kanchev Str., floor 2, Sofia Email: believe@nitram.bg

The principal of the game and provider of the rewards is TRINITY PARK SOFIA EAD, UIC 175404926, 7 Zheneva Str., Sofia (Outlet Village Sofia).

2. What data we collect

When you sign up:

• your first name and surname;
• your email address;
• your phone number;
• the language you sign up in (Bulgarian or English);
• whether you accepted the Official Rules and this policy (with the date of the version you accepted), and whether you agreed to receive news and offers by email and/or by phone;
• the date and time you signed up.

When you play (once the game starts on 16.11.2026):

• which brands you found and when, how many hints you used and how long the game took you;
• the code for the reward you redeemed, and when and at which till it was used.

When you collect a reward on site: your full name, signature and – for a taxable reward – your personal identification number (EGN). These are collected on paper at Outlet Village Sofia, not through this website.

Technical data: your IP address is used only at the moment of each request, to limit mass automated sign-ups and abuse. We do not store it in the database with your data and we do not keep a log of IP addresses.

We do not collect data about children: only people aged 18 or over can take part in the game.

3. Why we process it and on what legal basis

Consent to news and offers is optional and given separately for email and for phone. You can sign up and play without it.

We do not make automated decisions or profile you. Rewards in the game depend only on the number of brands you find, and the raffle winner is drawn at random.

4. Who has access to your data

We do not sell your data. Access is given only to:

• employees and authorised persons of the Organiser and the Principal, as far as they need it for the game and the rewards;
• the providers of the technical services the platform relies on, only for the purpose of their service and under a contract with us:
  • the company that developed and maintains the platform;
  • Hetzner Online GmbH (Germany) – the servers that store the data, in the European Union;
  • Cloudflare, Inc. – network protection and delivery of the website; it processes IP addresses and technical request data;
  • Resend – sending the email with your reward code;
• accounting, tax and legal advisers;
• public authorities, where required by law.

Cloudflare and Resend are based in the USA and may process data outside the European Union. In those cases the transfer is made with the safeguards of the Regulation: the EU–US Data Privacy Framework and/or the European Commission’s standard contractual clauses.

5. How long we keep the data

• Sign-up and game data – until 28.05.2027, unless the law requires a longer period.
• Documents for rewards handed over (handover and tax/accounting documents) – 6 years from the date of the document.
• Data for news and offers – until you withdraw your consent or it is no longer needed for that purpose.

After that, the data are deleted.

6. Cookies and data in your browser

The website uses no advertising or analytics cookies and loads no third-party scripts.

• lg_session – a single cookie the game needs to recognise you when you come back. It holds only a random key that scripts on the page cannot read, and it expires after 90 days. The game cannot work without it, so it does not require consent.
• Your browser’s local storage – on your device we keep your name, email and phone number (so you do not have to type them again), the language you chose and your progress in the game. This data does not leave your device this way, and you can delete it by clearing the site’s data in your browser.

7. Your rights

You have the right to:

• access your data and get a copy of it;
• have inaccurate data corrected;
• have your data erased;
• restrict the processing;
• receive your data in a machine-readable format (portability);
• object to processing based on legitimate interest;
• withdraw your consent to news and offers at any time, for one or both channels – this does not affect the lawfulness of the processing before you withdrew it.

You can exercise your rights as described in Section X, point 7 of the Official Rules:

• in person, with a written request on paper at the Organiser’s office at 18A Angel Kanchev Str., Sofia 1000, on presentation of an identity document; or
• with a written request by email to believe@nitram.bg, drawn up as an electronic document signed with an electronic signature.

We will reply within one month.

If you believe your rights have been breached, you can complain to the Commission for Personal Data Protection: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, www.cpdp.bg.

8. How we protect the data

Access to the data is limited to the people who need it for their work and is protected with personal passwords. The connection to the website is encrypted (HTTPS) and the servers are in the European Union.

9. Changes to this policy

If we change this policy, we will publish the new version on this page with the new date from which it applies.