PERSONAL DATA PROTECTION POLICY
of BULAGRO GROUP HOLDING EAD
From May 25, 2018 a new regulation on personal data protection (General Data Protection Regulation), adopted by the European Union, enters into force. The regulation aims to ensure the protection of individuals' data from all EU Member States and to harmonize the regulations for their processing.
As administrators of personal data, BULAGRO GROUP HOLDING EAD and all companies in the holding structure meet all the requirements of the new regulation by collecting and processing personal data as necessary, keeping them responsibly and legally.
Our main goal when working with personal data
BULAGRO GROUP HOLDING EAD and all companies in the holding structure process the personal data of their clients in order to provide better and more diverse products and services. In view of this goal, BULAGRO GROUP HOLDING EAD and all companies in the holding structure have built a network of strategic trade partnerships, which strive to meet all the needs of its customers when using the product portfolio.
The security of the data that the clients of BULAGRO GROUP HOLDING EAD and all companies in the holding structure have entrusted is important for the holding. That is why BULAGRO GROUP HOLDING EAD and all companies in the holding structure protect the personal data of their clients by applying all appropriate technical and organizational means to prevent unauthorized access, unauthorized or malicious use, loss or premature deletion of information.
BULAGRO GROUP HOLDING EAD and all companies in the holding structure collect and process personal data in compliance with the requirements of Bulgarian and European legislation.
This "Personal Data Protection Policy" aims to explain to the clients of BULAGRO GROUP HOLDING EAD and the companies in the holding structure how and why their personal data is processed.
How and why we use personal data:
1. For the performance of a contract or in the context of a pre-contractual relationship
BULAGRO GROUP HOLDING EAD and all companies in the holding structure process the identification data of their clients and other personal data in order to fulfill their contractual and pre-contractual obligations and to enjoy the rights under the contracts.
The processing is performed in order to:
establishing the identity of the client;
management and execution of orders for products or services, execution of contracts for products and services;
preparation of a proposal for concluding a contract;
preparation and sending of invoices for products and / or services;
to provide comprehensive service as well as to collect amounts due from customers;
performing credit assessment and determining credit rating;
2. For fulfillment of normative obligations
BULAGRO GROUP HOLDING EAD and all companies in the holding structure process the identification data of their clients in order to comply with the obligations provided for in a regulatory act, such as:
obligations provided for in the Accounting Act and the Tax and Social Security Procedure Code and other related normative acts in connection with the maintenance of proper and lawful accounting;
providing information to the court and third parties, in the framework of proceedings before a court, in accordance with the requirements of the procedural and substantive legal acts applicable to the proceedings;
3. With the consent of the client:
In some cases BULAGRO GROUP HOLDING EAD and the companies in the holding structure process the personal data of their clients only after their prior written consent. Consent is a separate ground for the processing of personal data and the purpose of the processing is stated in it, for example:
determination of credit rating and credit assessment.
In order to withdraw his consent, it is necessary for the client to contact a representative of the respective company.
What data is processed:
the three names, unique civil number or personal number of a foreigner, permanent address, UIC;
information on the type and content of the contractual relationship, as well as any other information related to the contractual relationship;
How to protect customers' personal data:
To ensure adequate data protection of the company and its customers, BULAGRO GROUP HOLDING EAD and all companies in the holding structure apply all necessary organizational and technical measures provided for in European and Bulgarian legislation.
When customer personal data is deleted:
As a rule, BULAGRO GROUP HOLDING EAD and the companies in the holding structure terminate the use of personal data of their clients for the purposes of the contractual relationship after termination of the contract, but do not delete them before final settlement of all financial relations between the parties and expiration of the statutory deadlines for data storage, such as obligations under the Accounting Act for storage and processing of accounting data, expiration of the statute of limitations for filing claims specified in the Obligations and Contracts Act, obligations to provide information to the court, competent state authorities, etc. grounds provided for in the current legislation. Personal data shall not be deleted if they are necessary for pending court proceedings.
When sharing personal data with third parties:
BULAGRO GROUP HOLDING EAD and all companies in the holding structure provide the personal data of their clients to the following categories of recipients (data controllers):
banks for servicing payments and pledge of receivables;
competent authorities, which by virtue of a normative act have the authority to require the provision of information, including personal data, such as - courts, prosecutors, etc .;
Clients' rights in relation to the processing of their personal data:
Right to information:
information on whether data relating to them are processed, information on the purposes of such processing, on the categories of data and on the recipients or categories of recipients to whom the data are disclosed;
a message in an understandable form containing the personal data being processed as well as any available information about their source;
Right to correction:
to delete, correct or block personal data, the processing of which does not meet the requirements of the law;
to notify third parties to whom the personal data of the client have been disclosed of any deletion, correction or blocking, except in cases where this is impossible or involves excessive effort.
Right of objection:
objection to the processing of personal data if there is a legal basis for it; where the objection is justified, the personal data of the person concerned may no longer be processed;
objection to the processing of personal data for marketing purposes.
Right to delete ("to be forgotten")
the clients of BULAGRO GROUP HOLDING EAD and the companies in the holding structure have the right to request deletion of the personal data related to them, and BULAGRO GROUP HOLDING EAD and all companies in the holding structure and all companies in the holding structure have the obligation to delete them without delay. for the following reasons:
personal data are no longer needed for the purposes for which they were collected or processed;
withdrawal of the consent on which the data processing is based and lack of other legal basis for the processing;
objection to the processing of personal data, including for marketing purposes and in the absence of a legal basis for the processing;
personal data have been processed illegally;
personal data must be deleted in order to comply with a legal obligation under EU law;
Right to limit processing when:
the processing of the data has no legal basis, but instead of being deleted, the client wants their limited processing;
this data is no longer needed (for the specified purpose), but the client needs it to establish, exercise or defend legal claims;
the client has filed an objection to the processing of the data and is awaiting verification as to whether the controller's grounds are lawful.
Right of portability provided by:
to obtain personal data in a structured, widely used and machine-readable format for transfer to another controller;
to obtain a direct transfer of personal data to another controller, if technically feasible.
Right of appeal:
In case the client believes that BULAGRO GROUP HOLDING EAD or any company from the holding structure violates the applicable regulations, he may contact a representative of BULAGRO GROUP HOLDING EAD to clarify the issue. The customer has the right to lodge a complaint with the regulatory authority.