This policy aims to ensure the protection of the personal data of individuals by describing the way personal data are collected, processed and stored, as well as informing the data subjects of their rights that they can exercise.
KZU AD is administrator of personal data, according to Art. 4 (7) of Regulation (EC)2016/679 (General Data Protection Regulation) with address for correspondence: Sofia 1000, Triaditza district., 12 Uzundzjovska Str.
The principles we abide to are respect for the processing of personal data, good faith and transparency with respect to data subjects.
The collection, processing and storage of personal data by KZU AD is legally and contractually based on a legitimate interest or explicit declaratory consent.
What is personal Data?
Any information by which an individual may be identified, directly or indirectly, represents personal data.
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What personal data does KZU AD collect through this website (web portal) about you?
In order to provide you with effective access to its web portal and services, KZU AD collects the following information about you:
- Name, surname, e-mail (address), telephone, when filling out the various forms on our web site, including the contact form and upon sending comments and / or opinions;
- Name, surname, telephone, e-mail, settlement, address, bank account details, if applicable, upon entering into contracts and sending requests for offers between you and KZU AD
What are the grounds for personal data processing by KZU AD ?
Personal data processing involves collecting, storing, transmitting, correcting, updating, deleting, destroying and any other actions that are performed with your personal data.
KZU AD processes your personal data on a contractual basis in order to provide information in relation to pre-contractual relationships and/ or to fulfill its contractual obligations under contracts with you for the provision of services– Art. 6, para. 1, Regulation (EC) 2016/679.
KZU AD also processes your personal data after receiving your explicit, clear, free and unambiguous consent for the purposes of processing.
Consent would be necessary as grounds for processing, for example, for marketing purposes and receiving advertising newsletters.
The consent you provide can always be withdrawn by visiting one of our offices, as well as sending an email to the address specified in this Policy – firstname.lastname@example.org
KZU AD also processes personal data to fulfill its legal obligations as may be necessary to protect the life and health of the individual to whom the data relates.
KZU AD may also process personal data if it has legal (legitimate) interest, unless the interests of the individual to whom the data relates override those interests.
What are the purposes for which we collect your personal data?
The personal data we receive from you will be used to fulfill our obligations to you, as well as to help you exercise your rights, including but not limited to:
- To provide you with the services offered by KZU AD ;
- To grant you access to our webpage by showing you content that is relevant, personalized, and limited to the criteria you have set;
- To respond to your inquiries, opinions and recommendations;
- To send you information related to special campaigns and our new products and services;
- For statistical and accounting purposes in the performance of contractual obligations of KZU AD to you.
In addition to the above, we have a legitimate interest in collecting your personal data, because without it we cannot provide you the service/ product you are interested in.
How do we process your personal data?
In order to provide its services, KZU AD processes (collects) your personal data in the following ways:
– when you visit the web portal to use our website’s services;
– when you fill in applications, forms and declarations provided to you by the employees of KZU AD. Those forms are provided and filled in at our offices in case you make a service request;
– upon updating data at your request and filling in an update form on a hard copy or electronically;
– by processing information about your visits to the web portals of KZU AD ;
– by processing information about IP addresses, cookies, operating system and browser type.
How long do we retain and process your data before destroying it?
Depending on the grounds on which we process your personal data, the term of storing it is different.
Your personal data is stored by us for a period of 5 years from the termination of the contractual grounds if we process the personal data to fulfill contractual obligations to you. Upon expiration of this period and in case there is no legal basis for the continued storage of your personal data, the information about you will be destroyed.
Your personal data is stored for a longer or different period than indicated in any case of a legal obligation – in case of a legal basis for personal data processing.
In case of processing personal data based on an explicit consent, the data is stored until the withdrawal of your consent.
In cases where your personal data is processed to respond to opinions and comments sent to us via our platform, the storage period is between 1 and 3 months, depending on whether we should provide you with a response and the data is needed to prepare the response.
Who can we share your personal data with?
KZU AD undertakes not to disclose your personal data to third parties without your express consent, except where this is necessary to fulfill your contractual obligations to you.
In order to fulfill obligations under a contractual and/ or pre-contractual relationship with you, KZUAD may disclose your personal data to the following persons:
– Companies providing courier services;
– The company that provides hosting services related to this web -site.
– Third parties performing services in connection with contractual obligations to you or on a legal basis for processing;
KZU AD is entitled to provide your personal data to affiliated companies that are positioned on the territory of the Republic of Bulgaria, provided that there is a legal interest in the processing of your personal data for administrative purposes and needs. Such transfers are permitted subject to strict confidentiality and protection of your personal data.
Are there any other cases in which we can share your personal data?
Your personal data may also be provided to third parties in the following cases:
- At the request of the individual submitting the data, subject to the protection of personal data;
- At the request of competent authorities pursuant to the current legislation of the Republic of Bulgaria and the European Union.
In all the above cases, the persons to whom we provide your personal data have declared that they provide an adequate level of protection of your personal data, including foreign companies positioned within the EU and EEA. For companies located outside the EU and EEA, on a case-by-case basis, the company concerned ensures that it provides an adequate level of personal data protection, while complying with the requirements of the European legislation.
Automated decision making upon personal data processing and profiling
To ensure optimum speed in providing services, most often online, KZU AD may use the technical capability of automated decision making under Art. 22 of the Regulation. In case that your personal data is processed automatically, we will inform you. The processing of personal data, including “profiling”, consisting of any form of automated processing of personal data to assess personal aspects, in particular the analysis or forecasting of various aspects relevant to your personal preferences or interests, reliability or behavior, is carried out in strict compliance with the provisions of the Regulation. Upon automated processing of your personal data/ profiling, we:
- use appropriate procedures for profiling;
- implement appropriate technical and organizational measures to ensure that the factors that lead to inaccuracies in the personal data are corrected and the risk of errors is minimized;
- protect personal data in a way that takes into account any potential threats to your interests and rights and that does not give rise to discrimination based on race or ethnic origin, political opinions, religion or belief, membership in trade unions, genetic or health status or sexual orientation or from which no such measures may arise.
What are your rights regarding the personal data provided?
Subject to the Bulgarian and the European legislation, including Regulation (EU) 2016/679 of the EC and the Council (General Data Protection Regulation (GDPR)), you can exercise the following rights:
- The right of access to personal data that KZU AD processes about you and obtain a copy thereof;
- You may request a correction by KZU AD if you find any inaccuracies or need to update your personal data by sending an email to email@example.com
- The right to request blocking of your personal data or restriction of the processing of personal data in the cases specified by the law and the Regulation;
- The right to request erasure i.e. deletion of your personal data by KZU AD if the required conditions are met;
- The right to object to the disclosure of your personal data to third parties by entering your personal profile on our website and removing the check –mark regarding the provision of personal data to third parties;
- The right to withdraw your consent for personal data processing for the purposes for which you have given such consent, for example, for marketing purposes, by sending an email to: firstname.lastname@example.org
- The right to request portability of your personal data in a structured, machine-readable format that is commonly used;
- The right to file a complaint or request for protection of your rights with the Personal Data Protection Commission, if the relevant prerequisites are met;
You may exercise allrights at any time during the processing of your personal data.
Are you obliged to provide us with your personal data?
In order to provide our products and services, as well as to enter into contractual relationships, we collect and process your personal data. We process your personal data in order to fulfill our legal obligations.
If you refuse to voluntarily provide the required personal data, KZU AD will not be able to provide its products and services, respectively to conclude a contract/continue the performance of an already concluded contract.
This will provide you with the opportunity to stop using some or all of the services and/ or take advantage of your rights, some of which are explicitly mentioned above. In addition, we will take all possible measures to inform you in case of changes regarding the protection of personal data by posting messages in the office sand web portals of KZU AD companies.
Conditions for exercising the rights
Personal data subjects may exercise their rights by a written application to the data administrator of "KZU" AD at: 1000 Sofia, Triaditza district,12 Uzundzhovska Str.
This policy is designed to inform the data subjects, which may be updated, amended and supplemented at any time in the future when circumstances warrant.
This policy has been prepared in accordance with the requirements of Article 13of Regulation 2016/679. For the correct application of Regulation (EC) 2016/679and for the fulfillment of the obligations of the data controller, the internal procedures and rules in accordance with the requirements of the Administrator have been approved by Regulation (EC) 2016/679.