POLICY FOR PRIVACY AND PROTECTION OF PERSONAL DATA OF TREMOL SMD LTD.
Tremol SMD ltd. is a commercial entity registered in the Bulgarian Commercial Register under UIN: 104666520 in Veliko Tarnovo, with business address: 10 Asti str., Veliko Tarnovo, telephone: 062/604880, www.smd.tremol.bg, e-mail: email@example.com. It is represented by general managers: Dipl. Eng. Petar Yordanov Kolev and Ralitsa Tremol Koleva, together and separately.
Main objective of processing personal data
This policy aims at introducing an integrated approach to implementing the requirements of EC Regulation 2016/679.
We process your personal data for performance of employment and civil contracts and the realization of their lawful relations, including statutory imposed social security payments and benefits.
Security of the data you entrust us with it is of high importance to us. It is very important for the success of our business and for our public image. That is why we protect your data by applying all appropriate technical and organizational means at our disposal to prevent unauthorized access, unauthorized or malicious use, loss or premature deletion of information.
We collect and process personal data only according to the requirements of national and EU law. We understand that processing your data is for a specific reason and cannot be done without limitation.
Principles of processing personal data
Data processing is carried out in accordance with principles for protection of personal data in art. 5 of EC Regulation 2016/679.
Tremol SMD Ltd. applies the following principles when processing personal data:
- Personal data is processed lawfully, in good faith and transparently.
- Personal data is collected only for specific, explicit, and legitimate purposes.
- The processed personal data must be adequate, relevant and limited to what is necessary for the relevant purpose.
- Personal data must be accurate and up to date at all times. All reasonable steps shall be taken to ensure the timely erasure or rectification of inaccurate personal data.
- Personal data is stored in such a form that the data subject can only be identified for as long as necessary for processing.
- Personal data is processed in a way that ensures appropriate security.
- Compliance with the principle of accountability.
How and why we process your personal data
Processing is necessary for the performance of labour and civil contracts to which you are a party or for undertaking actions upon your request before, during and after the conclusion of such a contract.
Processing is done with the purpose to:
- identify you;
- make payment for wages and social security payments provided for in the contract and in the current legislation (benefits for temporary incapacity for work, unused leave, raising of a child, etc.);
- process your requests, applications, complaints, objections in connection with the performance of labour and civil contracts;
- communicating and sending notifications electronically and on paper for everything related to performance of concluded contracts;
- provide personal data to third parties - administrators of personal data for performance of contractual relations;
the transfer of information is made under a contract, which ensures that the processing of personal data takes place in accordance with appropriate technical and organizational measures and provides protection for your rights.
Compliance with statutory obligations
We process your identifications and other personal data necessary to comply with obligations that are provided in a legislative act such as:
- Law for the protection of personal data and EC Regulation 2016/679 - provision of information to the Commission for the protection of personal data in relation to obligations provided by the legislation on the protection of personal data;
- Law on accounting, the Tax-insurance procedure Code and other related legislative acts in relation to keeping of proper and lawful accounting;
- Procedural and substantive legislative acts for providing information to the court and third parties in the course of proceedings before a court, in accordance with the requirements of the acts applicable to the proceedings;
- other legislative acts.
After consent has been granted for processing of personal data
In some cases, your personal data is processed after prior written or electronic consent. Consent is a separate ground for processing of your personal data with the purpose of processing specified therein and does not match the purposes stated in this policy.
In the event that you grant us consent, we will process your personal data for the stated purposes until it is withdrawn.
Consent that is given may be withdrawn at any time, and this will not affect the performance of the contractual obligations of Tremol SMD Ltd.
Upon the withdrawal of the consent for processing of personal data, Tremol - SMD Ltd will not use your personal data for the purposes for which it was once provided.
Withdrawal of consent does not affect the lawfulness of consent-based processing prior to its withdrawal.
Consent can be withdrawn in writing / electronically, by e-mail: firstname.lastname@example.org (signed by electronic signature), by mail, or otherwise.
Where processing is necessary for the purposes of legitimate interest
We may process your personal data when the processing is necessary for the purposes of our legitimate interests or for the legitimate interests of a third party except where your interests or your fundamental rights and freedoms are advantageous to such interests.
What kind of data we process
Identification data - full name, single citizen number / personal number of foreigner, permanent and current address. Other data - information about the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including:
- emails, letters, including but not limited to: requests, complaints, signals, etc.;
- personal contact details - contact address, phone number and email;
- video recordings made to improve security in the company's offices, production and storage facilities;
- bank account number or other bank and payment information related to payments under the concluded contracts.
How we protect your personal information
To ensure adequate protection of personal data, we apply all necessary organizational and technical measures provided for in EC Regulation 2016/679 and the Law for the protection of personal data. Tremol SMD Ltd. will appoint a special officer for data protection, when circumstances require, and has created conditions to prevent abuses and security breaches.
For the purpose of achieving maximum security during processing, transfer and storage of personal data, we may use additional security mechanisms such as encryption, pseudonymisation, etc.
Erasure (right “to be forgotten”)
You have the right to request from Tremol SMD Ltd. erasure of personal data related to you, when:
- personal data is not necessary for the purposes for which it was collected;
- processing is based on consent, upon withdrawal of your consent;
- personal data has been unlawfully processed;
- personal data must be deleted in order to comply with a legal obligation under EU law or the law of a member-state, which is applicable to Tremol SMD Ltd.
Protection of personal data
Tremol SMD Ltd. discontinues use of your personal data after fulfilling the purposes for which it was provided; when it is not necessary to protect a legitimate interest; after termination of a contractual relationship or final settlement of all financial relations; or after expiry of the statutory obligations for data storage, such as:
- under the Law on accounting for the storage and processing of accounting data (11 years);
- under the Law on obligations and contracts - after expiry of the limitation periods for claims (5 years).
- Labour Code and Social Security Code (3 years).
Please note that we will not delete your personal data if it is necessary for pending legal, administrative or other proceedings, such as when there is an obligation to provide information to the court, competent state authorities and other reasons provided for in current legislation.
When and why we share personal data with third parties
Provision of personal data to partners and third parties, where there is a valid ground for doing so, is done under a contract that ensures that processing takes place via application of appropriate technical and organizational measures and provides protection for your rights.
We do not provide your personal data to third parties before making sure that all technical and organizational measures are taken to protect this data by striving to carry out strict controls to meet this goal.
Third parties to whom we provide personal data
- Companies providing accounting services.
- Banks, which service payments made to you.
- Postal operators and courier companies.
- Governmental bodies, institutions and individuals to which we are required to provide personal data under current legislation.
- Licensed security companies, in connection with processing of video recordings from Tremol SMD Ltd.’s sites and/or supervision over access to these sites.
- Providers of paper destruction services.
- Persons performing legal and consulting services in various fields.
Rights of the personal data subject
Right of information
You have the right to:
- ask whether personal data relating to you is being processed. In the case of confirmation, request access to the data, information for the purposes of processing, as well as information on who the recipients of this data are;
- receive the information in a short, transparent, comprehensible and easily accessible form.
Right of rectification
You have the right to:
- If we process incomplete, inaccurate or outdated personal data, you may at any time request that it is corrected.
- When correcting your personal data, you have the right to ask us to notify you of the third parties to whom this personal data has been disclosed.
Right of objection
During any time:
- you may object to the processing of your personal data. If the objection is justified Tremol SMD Ltd. will terminate processing of your personal data.
Right to restriction of processing
You may request that we limit processing of your personal data if:
- you challenge the accuracy of the data for the period we need to verify its accuracy;
- data processing is done without legal grounds, but instead of being deleted, you request restriction of processing;
- your data are not necessary for the purposes of processing, but you require them for the establishment, exercise or protection of legal claims;
- you have objected to data processing during the verification period.
Right to portability
You have the right to receive your personal data in an organized, orderly, structured, widely used electronic format if:
- process your personal data on the basis of your consent or processing is based on an obligation under our agreement with you; and
- processing is done automatically.
The right to appeal
You have the right to appeal to Tremol SMD Ltd. in case you believe that processing of your personal data violates applicable legal requirements.
The complaint should be filed in writing personally or through an authorized person with a power of attorney certified by a notary.
The complaint may also be filed electronically, in accordance with the Law on electronic document and electronic signature.
Data protection officer Nina Krasimirova
Tremol SMD Ltd. decides on your complaint within one month of filing it. If necessary, this period may be extended by a further month in order to collect additional information.
Update and policy changes
Policy for privacy and protection of personal data of Tremol SMD Ltd. is last updated 08.06.2018.
This policy is adopted with a decision of the General assembly of Tremol SMD Ltd. from 15.05.2018.