PERSONAL DATA PROTECTION POLICY OF IMPEXRON Ltd.
This Personal Data Protection Policy of IMPEXRON Ltd was approved in compliance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council, and its objective is to inform you of your rights in relation to activities concerning your personal data.
Please, get familiar with the content of this policy, so that you are informed about the activities of IMPEXRON Ltd. (herein referred to as the Company) concerning your personal data.
I. ADMINISTRATOR OF PERSONAL DATA:
- Name and legal form: IMPEXRON Ltd, Unified Identification Code: 201420621,
- Seat and registered office: city of Plovdiv, 254 Shesti Septemvri Blvd., floor 5, office 1
- Person representing the company: Ilyas Ozmus
- Person collecting and processing personal data: Kostadin Kolev
Telephone number: +35932571212;
IMPEXRON Ltd. is a company registered under the legislation of the Republic of Bulgaria. Its business activities are related to the purchase and sale of industrial spare parts, machines, components, elements, equipment for the industry and others, organization of transport (delivery of goods and products) in Bulgaria, the EU and third countries. For the implementation of its business activity, the Company needs personal data of its clients - individuals.
II. PERSONAL DATA
1. Definition of the term “personal data of individuals” - any information that relates to an identified or identifiable living individual.
2. Personal data which you provide to the Company as a client.
personal identification number/date of birth,
an email address for correspondence,
bank account number
3. Purpose on which you provide your personal data:
3.1. Conclusion and execution of a contract
You provide the above personal data in order to conclude a formal or informal contract with the Company in connection with the Company's business activities, so that you can be individualized as a party to the particular contract. In addition, your personal data is collected for the execution of the contract, under which both parties have certain rights and obligations.
When making a payment for the goods, products or services provided by the Company, you provide data related to your bank account.
Legal basis for data processing - Art. 6, item 1, letter “b” of Regulation 2016/679 of the European Parliament and of the Council; Obligations and Contracts Act; Commercial Act; Civil Procedure Code; Measures Against Money Laundering Act;
3.2. Protection of the Company's rights in case of default of the contract
In addition, your personal data is collected for cases of default of a contract concluded between you and the Company. For the entire period of the contract, both parties to it have certain rights and obligations under the terms of the contract. In case of default of your obligations, the Company has the right to seek protection of its legal rights and interests, including by using the necessary personal data.
Legal basis for data processing - Art. 6, item 1, letter “d” of Regulation 2016/679 of the European Parliament and of the Council; Obligations and Contracts Act; Commercial Act; Civil Procedure Code; Measures Against Money Laundering Act;
3.3. Accounting and tax purposes
Information on the contract concluded with you is stored and processed in connection with the legal obligations of the Company to perform and maintain tax accounting and to pay taxes. In this regard, your personal data is processed entirely for tax purposes.
Legal basis for data processing - Art. 6, item 1, letter “c” of Regulation 2016/679 of the European Parliament and of the Council; Accounting Act, Corporate Income Tax Act; Income Taxes on Natural Persons Act; Commercial Act;
3.4. Archiving and internal company use
After the execution of the concluded contract, the Company keeps information about the concluded and executed contract as well as other related documents, if any (additional agreements, annexes, correspondence regarding the conclusion and execution of the contract, invoices, bank statements) for the purposes of archiving, internal company use and analyzes of the Company's activities.
Legal basis for data processing - Art. 6, item 1, letter “d” of Regulation 2016/679 of the European Parliament and of the Council; Commercial Act;
4. How your personal data is collected
You provide your personal information solely at your discretion.
You choose how to provide your data - personally to an employee of the Company - Mr. Kostadin Kolev, by e-mail or using another, appropriate and convenient method.
Please, note that in your capacity of a client, in order to conclude a contract, you do not need to provide the Company with a copy of an identity document.
In case you send personal data via email or other electronic correspondence means (Viber, WhatsApp, Messenger, etc), you should be aware of the potential risk of unauthorized access to your data, which in no way depends on the Company.
When providing your personal data, you agree to provide your personal data and you have been duly informed of the purpose on which the Company will use it.
5. How the Company stores your personal data
Your personal data is stored on paper and/or electronically.
The Company maintains a paper archive in which copies of the contracts are stored, as well as other related documents, if any (additional agreements, annexes, correspondence regarding the conclusion and execution of the contract, invoices), data on payments made (bank statements). This archive is stored in a separate room with restricted access of people external to the Company and a lock system.
Your personal data is stored on electronic media - computers. Computers are equipped with licensed software and have the necessary programs and technical protection mechanisms, including protection against viruses. Access to computers for people external to the Company is restricted through a password.
The Company keeps accounting information using the accounting program invoicepro.bg, which complies with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council.
6. For what period personal data is stored
Your personal data is stored for a different time depending on the purpose for which it is collected.
6.1. Conclusion and execution of a contract and protection of the Company's rights in the case of default of a contract - a period of up to 10 years starting from the date on which the complete and final execution of the contract by the parties occurs or the date of termination of the contract on other grounds.
In the event of a default of the contract, and if either party has taken action to protect its rights in court or by other proceedings - up to 5 years from the date of the final judicial or another act.
6.2. Accounting and tax purposes – a period of up to 10 years from the date of the last payment. If revisions and/or inspections are undertaken by the National Revenue Agency (NRA) and/or other public authorities, the period for storage of personal data may be extended by the duration of the relevant activities of the governmental administration.
6.3. Archiving and internal company use – a period of up to 10 years from the date of execution of the contract by the Company.
7. How personal data is destroyed
Upon expiry of the period for which personal data is stored, this data is destroyed/pseudonymized in a way that you cannot be identified as an individual. Paper copies of the documents that contain your personal data are destroyed by a special device for destroying paper (shredder). The stored copies in electronic form are deleted, deleting your personal data.
8. Is your data provided to other persons
Your personal data may be provided to other persons, depending on the purposes for which the data is stored, namely:
8.1. Conclusion and execution of a contract and protection of the Company's rights in the case of default of a contract – for preparation of a contract, keeping official correspondence, for sending your copy of the contract, for conclusion and execution of a contract, for protection of the rights of either of the parties in accordance with the relevant judicial, administrative or another procedure - attorney, notary public, accountant/accountancy office, the National Revenue Agency, court, prosecutor's office, the Governmental Agency for National Security, well-established courier company, Bulgarian Posts EAD, persons responsible for technical and software support of equipment (IT specialists). In the event you want to know to which persons your personal data has been provided, please, contact the Company through the contacts listed above.
8.2. Accounting and tax purposes - to accountants and accountancy offices, to the competent governmental and municipal authorities upon their request (including the National Revenue Agency, the Governmental Agency for National Security and others).
8.3. Archiving and internal company use - This data is not provided to other persons except the Company's representative, partners, employees of the Company and the competent governmental authorities, if necessary and requested by them.
IMPORTANT NOTE: Your personal data may be provided to the Personal Data Protection Commission when exercising its powers of control over the compliance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council.
III. WHAT ARE YOUR RIGHTS regarding your personal data processed by the Company
1. Right to access, correct, delete (right to be forgotten), limit the processing of your data
You have the right to receive information as to whether the Company processes your personal data, which personal data it processes, which person processes the data, whether your personal data has been provided to other persons, for what period of time it is processed, what your rights are in relation to your personal data, whether you have the right to appeal. You may receive a copy of your personal data processed by the Company. In addition, you have the right to require the Company to update/correct your personal data if the data we have is inaccurate. You have the right to ask the Company not to take any action with respect to your data but only to store it, as well as to request the deletion of your personal data (right to be forgotten) when it is no longer necessary for the purposes for which it was processed, as well as after expiry of the period for which the data is stored.
IMPORTANT NOTE: You provide your personal data yourself, based on your own non-automated decision (no technical means or software are used to give your consent and/or provide your personal data) and the Company does not deal with profiling of your personal data.
2. Right to data transfer
You have the right to receive your personal data which you have provided to the Company and which we process in a structured and widely used format. In addition, you have the right to transfer your personal data which you have provided to the Company to other persons and/or administrators, either in person or by direct transfer of the data from the Company to another administrator specified by you if technically possible.
3. Right of objection
You have the right to object in cases where your personal data is processed for for the performance of a task carried out in the public interest or when the processing is necessary for the purposes of legitimate interests pursued by the Company or a third party, i. e. when processing of your data is performed based on Art. 6 (1) (e) and (f) of the Regulation. In such cases, you have the right to object and request that the Company terminate the processing of your personal data. If you decide to file such an objection, the Company shall review your request and answer you in the appropriate order within one month unless a longer period is necessary due to technical reasons.
4. Right to appeal
You can file an appeal with the Personal Data Protection Commission to protect your rights and legitimate interests with regard to activities related to your personal data.
IMPORTANT NOTE: If you need any further information regarding the collection, processing, storage, destruction or any other information related to your personal data, please, contact the Company through the contacts listed above.
Approved by the Director of IMPEXRON Ltd:
28 May 2018
city of Plovdiv