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BOGOEV TRANSPORT Ltd, Corporate ID: 205190954, Address: Meden Rudnick Housing District, Bldg 70, Entrance 2, Floor 5, Burgas, Bulgaria, VAT No. BG205190954, T: +359 876 005 107, Email: office@exoticstyle.bg, applies these General Terms and Conditions in all its commercial dealings with customers (referred to as the ‘Controller’ or ‘BOGOEV TRANSPORT Ltd’),
Store: Burgas, 59 Slavyanska Street
PREAMBLE
BOGOEV TRANSPORT Ltd, acting as data controller, is authorised to collect and process certain information about natural persons.
Such information may refer to employees, managers, customers, clients, suppliers, contractors, business connections and other natural persons to whom the Controller is related or would like to contact for business purposes.
This data protection policy governs the ways in which personal data should be collected, processed, and stored in order to meet the standards of the Controller’s organization and to be consistent with the legal regulations.
This data protection policy (‘Policy’) is drawn up on the basis of the Personal Data Protection Act and its regulations, as amended (‘Bulgarian laws’) and the General Data Protection Regulation (EU) 2016/679 (‘GDPR’).
The Bulgarian laws and GDPR lay down rules that all organizations, including BOGOEV TRANSPORT Ltd, must follow when collecting, processing, and storing personal data. These rules are implemented by the Controller regardless of whether the data are processed as hard or soft copies, or in other forms.
To assure that the processing of personal data complies with the legal regulations, such data are collected and used only for legitimate purposes and are stored securely; the Controller undertakes all necessary measures to prevent unlawful disclosure of the personal data.
The Data Controller has read and observes all principles set out in GDPR:
- personal data are processed lawfully, fairly, and in a transparent manner;
- personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- personal data are adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed;
- personal data are accurate and, where necessary, kept up to date;
- personal data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
- personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
The objective of this Policy is that the Controller will:
- comply with the applicable personal data laws and follow the established good practices;
- identify mechanisms for keeping, maintaining, and protecting the records of processing activities;
- define the responsibilities of the data processors and/or all other employees who have access or are subordinated to the data processors, and their liability in case of non-compliance;
- protect the rights of the personnel, customers, and partners;
- ensure the transparency of the storage and protection of the personal data of natural persons;
- put in place the necessary technical and organization measures for personal data protection from unlawful processing (accidental or illegal destruction, accidental loss, unauthorised access, modification or dissemination, or any other illegal methods of personal data processing);
- be protected if there is a risk of violations.
III. Scope
This Policy applies to the processing of personal data of suppliers, human resources, customers, and partners, as they are described in the electronic records established in compliance with this Policy, the Bulgarian laws, and Article 30 of GDPR (‘Records of Processing Activities’).
Categories of personal data and subjects
‘Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’), in particular:
The Controller may collect personal data for the following categories of data subjects:
- people representing the companies with which the Controller has established business relationships;
- points of contact at the companies with which the Controller has established business relationships;
- people requesting information services – information newsletter, reference books, etc;
- people registering to use the online store.
Purposes for collection of data
The Controller will collect personal data for the following purposes:
- drafting of documents;
- getting in touch with the relevant contact person by phone, fax, or in any other lawful way;
- delivering and/or accepting goods/services, discussing the supply and/or receipt of goods/services, and providing the necessary customer support;
- keeping accounting records for any agreements to which the Controller is a party;
- processing payments related to the agreements signed by the Controller;
- sending important information to the subjects concerning changes in the rules, terms, or policies of the Controller and/or other administrative information;
Collection of data
Data of contractors and partners (managers, representatives, and/or contact persons of legal entities)
Each person’s data are supplied voluntarily by the person and collected by the Controller as part of the Controller’s legal responsibilities for the conclusion of contracts and/or performance of obligations under concluded contracts, in compliance with the provisions of the Commercial Act, the Accounting Act, the Contracts & Obligations Act, the VAT Act, etc., and the terms and conditions of the trade contracts signed with the relevant customer, in the form of: hard copies – written documents (including powers of attorney, agreements, attachment orders, bank information, etc.), emails – provided in connection with the performance of a trade contract and/or by filling out a registration form. The subjects are notified of the provisions of this Policy in advance or at the time they supply their data.
In connection with the processing of the data of managers and contractors/partners:
Data processing is carried out on the basis of legal interests and in connection with the conclusion, performance, amendment, or termination of trade contracts and freelance agreements, for the implementation of and compliance with the legal regulations of the Commercial Act, the Social Security Code, the Tax & Insurance Procedure Code, the Insurance Code, the Personal Income Tax Act, the Accounting Act, the Contracts & Obligations Act and others.
Transparency and requirements for exercising the rights of data subjects
The Controller provides information to the data subjects in a concise, transparent, easy to understand and easily accessible form, using clear and plain language.
The Controller must make sure that the data subjects are informed of the existence of the processing operation and that they understand fully and completely, and are notified of the processing in compliance with the requirements of GDPR and the Bulgarian laws.
The Controller will provide such information to the data subjects in writing or by other means, including, where appropriate, by electronic means. When requested by the data subject, the information may be provided orally, provided that the identity of the data subject is proven by other means.
The Controller will provide information to the data subjects free of charge about any operations conducted in connection with a request for obtaining access to their personal data, or for rectification, erasure, restriction of processing, portability, right to object, and automated individual decision-making, without unnecessary delay, and in all cases, within one moth from the receipt of such request.
Where necessary, this term may be extended by up to two months, depending on the complexity and number of requests. The Controller will inform the data subject of any extension within one month from the receipt of the request and will specify the reasons for the delay. If the data subject files an electronic request, if possible, the information should also be provided by electronic means, unless otherwise requested by the data subject.
If the Controller does not take action on the request of the data subject, the Controller should inform the data subject without delay, and in any case not later than one month from the receipt of the request, of the reasons for not taking any action and on the possibility of filing a compliant with a supervisory authority and seeking a judicial remedy.
When the request of the data subject is manifestly unfounded or excessive, in particular because of their repetitive character, the Controller may either:
- charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or
- refuse to act on the request.
Right of access by the data subjects
Each data subject has the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed (including recipients in third countries or international organisations);
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
- the right to lodge a complaint with the Personal Data Protection Commission;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data are transferred to a third country or to an international organisation, the data subject will have the right to be informed of the appropriate safeguards relating to the transfer.
The Controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the Controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information will be provided in a commonly used electronic form.
Right to rectification
Each data subject has the right to obtain from the Controller, without undue delay, the rectification of inaccurate personal data concerning him/her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed.
Right to erasure (‘right to be forgotten’)
Each data subject has the right to obtain from the Controller the erasure of personal data concerning him/her without undue delay and the Controller has the obligation to erase personal data without undue delay when:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws his/her consent on which the processing is based and there is no other legal ground for the processing;
- the data subject objects to the processing and there are no overriding legitimate grounds for the processing which take precedence;
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation to which the Controller is subject;
- the personal data have been collected in relation to the offer of information society services.
Where the Controller has made the personal data public and is obliged pursuant to the previous paragraph to erase the personal data, the Controller, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
Right to restriction of processing
Each data subject will have the right to obtain from the Controller restriction of processing where one of the following applies:
- the accuracy of the personal data is contested by the data subject, for a period enabling the Controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the Controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pending the verification whether the legitimate grounds of the Controller override those of the data subject.
Where processing has been restricted under the previous paragraph, such personal data will, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest.
The data subject who has obtained restriction of processing will be informed by the Controller before the restriction of processing is lifted.
Notification obligation regarding rectification or erasure of personal data or restriction of processing
The Controller will communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controller shall inform the data subject about those recipients if the data subject requests it.
Right to data portability
The data subject will have the right to receive the personal data concerning him/her, which he/she has provided to the Controller, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from the Controller, where (i) the processing is based on consent given for specific purposes or on a contractual obligation of the data subject, or measures taken before concluding a contract, and (ii) the processing is carried out by automated means.
In exercising his/her right to data portability, the data subject will have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
Right to object
The data subject will have the right to object, on grounds relating to his/her particular situation, at any time to processing of personal data concerning him/her (when such processing is required for the performance of a task of public interest or in the exercise of official authority vested in the Controller, or is necessary for the purposes of the legitimate interests pursued by the Controller, or by a third party) including profiling based on those provisions. The Controller will no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, the data subject will have the right to object at any time to processing of personal data concerning him/her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data will no longer be processed for such purposes.
At the latest at the time of the first communication with the data subject, the right referred to in the previous paragraphs will be explicitly brought to the attention of the data subject and will be presented clearly and separately from any other information.
VII. Technical and organizational measures for data protection
The protection of personal data stored as hard or soft copies from unauthorised access, loss, or destruction, will be ensured by a series of internally regulated technical and organizational measures.
VIII. Transfers of personal data
The Controller is not and will not be transferring personal data to countries outside the European Union.
Breaches
Breaches of personal data security occur when any of the personal data for which BOGOEV TRANSPORT Ltd is responsible for are affected by a security-related incident which breaches the confidentiality, availability, or integrity of the personal data. In that sense, a personal data breach occurs where there is a security breach leading to accidental or illegal destruction, loss, modification or unauthorised disclosure of data which are being transferred, stored, or otherwise processed.
In the event of a data security breach, please immediately notify
Ivan Ivanov.
Assessment of breaches
As soon as the responsible employee of BOGOEV TRANSPORT Ltd becomes aware that a personal data breach has occurred, he must assess if the incident refers to a personal data breach and notify such event to the managers of the Controller (if they do not know about it).
If there is a breach in data security, which is likely to jeopardise the rights and freedoms of the natural persons, the Controller (acting through its responsible employee) should without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the Personal Data Protection Commission.
If and to the extent that such information may not be transferred simultaneously, it should be transferred in stages, without any further undue delay.
The Controller should communicate to the data subject a personal data breach, without undue delay, where that personal data breach is likely to result in a high risk to the rights and freedoms of the natural person.
The Controller should record each personal data breach, including all facts relating to the breach, its consequences and the actions taken to resolve it.
All accounting and commercial information, as well as all other data and documents relevant to taxation and the compulsory national insurance contributions will be stored by the Controller for the following periods:
- payrolls - 50 years;
- accounting registers and financial statements - 10 years;
- tax and insurance control records - 5 years after the expiration of the statute of limitations for the repayment of the public debt to which they refer;
- all other records - 5 years.
Upon the expiration of their retention periods, the information carriers (hard copies or technical carriers) which are not subject to filing with the National Archives Foundation, may be destroyed.
Upon the expiration of their retention period, data must be destroyed at the earliest possible convenience, by shredding all hard copies, and erasure and deletion of the electronic copies, including all files from the computers of the Company.
Further provisions
For the purposes of these internal rules:
This Policy was approved by the managers of BOGOEV TRANSPORT Ltd on 1 October 2019
The Policy is effective as of 1 October 2019
Date of next revision: 1 April 2020