Privacy and personal data protection policy of ‘235 DEVELOPMENTS’ OOD with UIC 205092613 with a seat of business and registered addressed in Sofia, 1000, dist. Sredets, 6 N. Mihaylov Str. Fl. 4
Provision of personal data on your part is voluntary in view of the using of certain services provided by us. Please be aware that in some cases without granting of the necessary information we may be unable to provide the service and/or to sell the goods that you have requested. You shall also be aware that in some cases your consent for processing of personal data may not be necessary if ‘235 DEVELOPMENTS’ OOD has other legal grounds for processing, for example fulfillment of statutory obligations.
Who processes and who is responsible for your personal data?
You may contact us at:
Registered address: Sofia, 1000, dist. Sredets, 6 N. Mihaylov Str. Fl. 4., e-mail: firstname.lastname@example.org
Categories of personal data processed by ‘235 DEVELOPMENTS’ OOD.
1. ‘235 DEVELOPMENTS’ OOD may process publicly accessible personal data and/or personal data provided by you. The main types of personal data that are processed are:
Personal identification information (incl. name, e-mail address, language of communication etc.);
Contact information (incl. post and e-mail addresses, your telephone numbers or the telephone numbers of your contact person etc.);
Financial information (bank account etc.);
Information about the representative (legal or authorized representative) of our client legal entity;
Data necessary for signing of a contract (such as names, PIN etc.).
2. ‘235 DEVELOPMENTS’ OOD may process data elaborated and generated in the process of provision of services:
Data about the used end electronic communication device, type of device, used operation system, IP address, location;
Data, which is part of our communication, your preferences, your satisfaction from our services (activity at using of the services, complaints etc.);
Data received at fulfillment of statutory obligations (i.e. data ensuing from inquiries, regulations, investigative authorities, notaries, taxation services, courts, bailiffs);
3. In order to assure the proper provision of the services and fulfillment of obligations under contracts with clients, ‘235 DEVELOPMENTS’ OOD shall be entitled to process any information available in public registers (incl. public databases and data announced on the internet) as well as information received by third parties in relation to fulfillment of statutory requirements referring to clients.
4. ‘235 DEVELOPMENTS’ OOD shall be entitled and obliged to check the correctness of personal data entered in the database and for this purpose we may request from you to verify the data and if necessary to correct the data or to confirm the correctness of your data.
5. Different types of personal data may be processed independently or in combinations.
Purposes and legal grounds of personal data processing
1. Processing of personal data necessary for signing or fulfillment of contracts signed with us or for preparation for signing of contracts with us. ‘235 DEVELOPMENTS’ OOD processes your personal data for the following purposes:
Identification of a client at: signing of a new or amendment to an existing contact with us; (fulfillment of a signed contract)
Elaboration of offers for signing of contracts, pre-contractual information and a draft contract;
Data received from you at fulfillment of obligations ensuing from contracts signed with you or a company represented by you, realization of rights and assuring of fulfillment of contracts on the part of our clients;
Administration and response to client`s complaints/inquiries/appeals/reclamations/returning of sums;
Guarantee and service maintenance;
2. In fulfillment of its statutory obligations ‘235 DEVELOPMENTS’ OOD processes your personal data for the following purposes:
For drafting of contracts, annexes and any other documentation necessary for performance of commercial activity;
Issuing of invoices;
Performance of tax-insurance control by the respective authorities;
Provision of information to the Commission for Personal Data Protection in relation to obligations envisaged under the personal data protection legislation – Law on Personal Data Protection, Regulation (EU) 2016/679 of 27 April 2016 etc.;
Obligations envisaged under the Law on Accounting and the Tax Insurance Procedure Code and other related normative acts with regard to keeping of proper and lawful accounting.
3. ‘235 DEVELOPMENTS’ OOD processes the respective data provided with the explicit written consent of the client for their processing for the following purposes:
Categories of third parties that receive access and process your personal data
Transport/courier companies, post operators in view of our contractual obligations, sending of correspondence and communications in relation to our contracts;
Persons to whom ‘235 DEVELOPMENTS’ OOD has assigned the maintenance of equipment and software used for processing of your personal data;
Providers of debt collection services, banks, notaries, attorneys at law, bailiffs or other third parties, if the client has breached an obligation under a contract signed with us;
The banks that administer the payments performed by and towards you;
Persons to whom ‘235 DEVELOPMENTS’ OOD has assigned performance of part of activities or obligations related to a particular service that we shall provide to you; persons processing personal data by virtue of a contract with ‘235 DEVELOPMENTS’ OOD process your personal data on behalf of ‘235 DEVELOPMENTS’ OOD;
Persons providing consultancy services in different fields – attorneys at law, judges etc.
Authorities, institutions and persons, to which we are obliged to provide personal data by virtue of the legislation in force.
The term for storing of your personal data depends on the purposes of processing, for which they have been collected:
1. Personal data processed for the purposes of signing/amending and fulfillment of contracts between ‘235 DEVELOPMENTS’ OOD and you or a company represented by you – for the term of the contract and until the final settlement of all financial relations between the parties. ‘235 DEVELOPMENTS’ OOD may store some of your personal data for a longer period of time until expiry of the respective prescription for the purposes of protection of interests in case of eventual claims of clients in relation to fulfillment/termination of a contract as well as in case of existing dispute until its final settlement by an enforceable court decision/arbitration award.;
2. Personal data processed for the purposes of issuing of accounting/financial documents for performance of tax-insurance control such as, but not limited to – invoices, debit, credit notices, written statements on delivery and acceptance, contracts for provision of services/goods shall be stored for at least for 10 years after expiry of prescription for payment of public debts, except if longer term is envisaged by the applicable legislation.
Your rights in relation to processing of your personal data
In relation to processing of personal data you have the following rights that you may always realize during the term of keeping or processing of your personal data by sending of an application in an electronic format to the following e-mail: email@example.com. You are entitled to request from ‘235 DEVELOPMENTS’ OOD:
• A copy of your personal data and access to them at any time;
• To correct without undue delay of your incorrect personal data and of your data that have become out of date;
• Your personal data in a format convenient for transferring to another personal data administrator or to request from us to do this without any impediments on our part (right of transferring);
• To delete your personal data without undue delay in case of occurrence of some of the legal grounds in this regard;
• To limit the processing of your personal data and in this case your personal data will be only kept and will not be processed.
Our refusal to limit the processing shall be only in writing and motivated by particular legal grounds;
You are also entitled:
• To withdraw your consent for processing of your personal data at any time by a separate request addressed to ‘235 DEVELOPMENTS’ OOD in cases when we process your personal data on the basis of your consent;
• To object to the processing of your personal data;
• To object to the automated processing, including profiling;
• Not to be subject to a decision based only on automated processing, including profiling;
You are entitled to file a complaint to the supervisory authority.
You are entitled to file a complaint directly to the supervisory authority, which is the Commission for Personal Data Protection, address: Sofia 1592, 2 Prof. Tzvetan Lazarov blvd. (www.cpdp.bg). In case you wish to file a complaint referring to the processing of your personal data by ‘235 DEVELOPMENTS’ OOD you may address your complaint to the Administrator or directly to the Personal data protection officer (contact information shown above).
3. You may receive additional information referring to the measures undertaken for protection of your personal data and to your rights from:
4. May you refuse to provide your personal data to ‘235 DEVELOPMENTS’ OOD and what are the consequences of your refusal? In order to sign a contract with you and/or to provide the services requested by you in conformity to the legal and contractual requirements, ‘235 DEVELOPMENTS’ OOD needs certain data to identify the party to the contract, its authorized representative, contact information, information about payment of obligations. The refusal to provide such data prevents us from signing a contract with you.
How we protect your personal data
‘235 DEVELOPMENTS’ OOD applies organizational, physical, IT and other measures necessary to guarantee the security and protection of your personal data and the monitoring of personal data processing.
Among other things, such security measures include the following activities:
• ‘235 DEVELOPMENTS’ OOD has established the requirements for processing, registration and storage of personal data by internal procedures whose observation is constantly monitored;
• The access of employees of ‘235 DEVELOPMENTS’ OOD to personal data and the permission for personal data processing in the company`s database is restricted depending on their duties;
• ‘235 DEVELOPMENTS’ OOD has imposed confidentiality obligations to its employees;
• The access to the office equipment of ‘235 DEVELOPMENTS’ OOD and the computers of any employees is restricted.
• We apply all necessary organizational and technical measures envisaged in the Law on Personal Data Protection, as well as the best practices from international standards;
• To ensure maximum security when processing, porting and storing your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc. The security measures we apply are subject to ongoing improvement and adaptation to the latest technologies.
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