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Privacy Policy

Personal Data Protection Policy of “BULTEXCOM” EOOD

I. SUBJECT

This Personal Data Protection Policy, hereinafter referred to as the “Personal Data Protection Policy”, provides information on how “BULTEXCOM” EOOD, hereinafter referred to as the “Provider”, “Controller”, “we” and/or “us”, owner/operator of the website: https://euro-trims.com/en/, hereinafter referred to as the “Website”, processes (including but not limited to collecting and storing) personal data of data subjects, such as users of the Website and of the Provider’s services, hereinafter referred to as “User/s”, “you” and/or “your”, as well as the rights of the latter in this regard.
The term “personal data” used in the Personal Data Protection Policy has the meaning given to it in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, hereinafter referred to as the “General Data Protection Regulation” and/or “GDPR”, namely: “any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
Below you can find brief information on:

  • The Provider,
  • The competent supervisory authority,
  • The legal basis on which we process personal data,
  • The purposes for which we use personal data,
  • The principles of personal data processing,
  • What personal data we collect,
  • The retention period of personal data,
  • Access to and transfer of personal data, and
  • The rights and safeguards that the GDPR grants to data subjects.

II. INFORMATION ABOUT THE PROVIDER

1. Name: “BULTEXCOM” EOOD, UIC 205390894
2. Registered office and management address: Sofia, 20 “Mitropolit Panaret” Str.
3. Tel.: (+359) 876 76 60 50, e-mail: [email protected]
4. Entry in public registers: Commercial Register at the Registry Agency of the Ministry of Justice of the Republic of Bulgaria.

III. INFORMATION ABOUT THE COMPETENT SUPERVISORY AUTHORITY

1. Name: Commission for Personal Data Protection of the Republic of Bulgaria
2. Address: Sofia 1592, 2 “Prof. Tsvetan Lazarov” Blvd.
3. Telephone: 02 915 3 518
4. E-mail: [email protected]
5. Website: https://www.cpdp.bg/

IV. GROUNDS FOR COLLECTING, PROCESSING AND STORING PERSONAL DATA

We process (including but not limited to: collect and store) your personal data solely in connection with our business and in accordance with the requirements of applicable legislation, including the Personal Data Protection Act of the Republic of Bulgaria and the General Data Protection Regulation.
We process your personal data on the basis of at least one of the following grounds:

  • The User’s consent to the processing of personal data;
  • Processing of personal data is necessary for the performance of the Provider’s contractual obligations to the User;
  • Processing of personal data is necessary in order to take steps at the User’s request prior to entering into a contract;
  • Processing of personal data is necessary for compliance with the Provider’s legal obligations;
  • Processing of personal data is necessary for the purposes of the Provider’s legitimate interests in carrying out its business.

V. PURPOSES OF COLLECTING, PROCESSING AND STORING PERSONAL DATA

We collect, process and store Users’ personal data in connection with the provision of our services and communication related to the use of the Website, as well as for the following purposes:

  • Communication and identification in the performance of a service contract and a sales contract (including in the performance of the respective contract);
  • Communication, identification, processing and fulfilment of submitted enquiries, orders, requests, reservations, purchases of goods or services (including preparation for concluding a contract, accepting orders, shipping goods, resolving issues related to cancellation of orders, reservations, returns of purchased goods, refunds of paid amounts and others);
  • Fulfilment of tax and other legal obligations;
  • Accounting purposes in connection with the use of our services;
  • Protection of our legitimate interests in connection with fulfilling our obligations to state and municipal authorities (for example: National Revenue Agency, Ministry of Interior);
  • Protection of our legitimate interests in connection with storing information for protection against legal or tax claims and for improving the performance of the Website;
  • Protection of the information security of the Website;
  • Statistical information on the use of the Website;
  • Provision of advertising content according to the User’s interests;

If a data subject refuses to provide us with some or all of the personal data necessary for the respective purpose stated above, we may not be able to provide the respective service (for example, perform a contract concluded with the respective User) or comply with the relevant legal requirements (for example, enable the data subject to exercise their rights under the GDPR).

VI. PRINCIPLES OF COLLECTING, PROCESSING AND STORING PERSONAL DATA

We observe the following principles when collecting, processing and storing your personal data:

    • lawfulness, fairness and transparency;
    • purpose limitation;
    • storage limitation in view of achieving the purposes for which the data is processed;
    • data minimisation;
    • accuracy and currency of the data;
    • integrity and confidentiality in data processing and ensuring an appropriate level of security of personal data.

VII. PERSONAL DATA

We collect the following categories of Users’ personal data for the following purposes and on the following grounds:

        • Your identifying data (first and last name, telephone number and e-mail address), as well as other data you provide voluntarily, for the purposes of processing your enquiries, providing service proposals and providing services on our part at your request, including communicating with you in this regard, on the basis of taking steps at your request for the possible conclusion of a contract, performance of a contract to which you are a party, or consent to processing given by you;
        • Your identifying data (first and last name, telephone number and e-mail address) and information related to payment and chosen payment methods for the purposes of issuing and sending accounting/tax documents (invoices) in connection with services you have used, including communicating with you in this regard, on the basis of taking steps at your request for the possible conclusion of a contract, performance of a contract to which you are a party, or compliance with our legal obligation;
        • Your IP address, browser settings and preferred language, pages visited and actions performed, for the purposes of sending push notifications, if you have expressed a wish to receive them;
        • Your IP address and pages visited, for the purposes of protecting information security;
        • Other data that may be necessary in certain cases or related to the provision of services to Users on our part, including data necessary for the performance of contractual obligations (for example date of birth, signature, personal identification number) or other data that Users choose to share with us voluntarily, on the basis of performance of a contract to which you are a party, consent to processing given by you, or compliance with our legal obligation.

We use “cookies” on the Website, which are small files downloaded to your computer to improve your experience as a user of the site. You can find more information on this on our dedicated cookie policy page here.
We do not process, and accordingly do not collect from Users, special categories of personal data (for example: data revealing racial or ethnic origin, political opinions, genetic or biometric data, or data concerning the sex life and sexual orientation of the data subject).
We do not make decisions based solely on automated data processing, including profiling.
We usually obtain personal data directly from the data subject. However, we may also receive personal data from other persons, such as other employees of the company where the respective data subject works, as well as from publicly available sources such as the Commercial Register and the Register of Non-Profit Legal Entities at the Registry Agency of the Ministry of Justice of the Republic of Bulgaria.

VIII. RETENTION PERIOD OF PERSONAL DATA

We store Users’ personal data for no longer than necessary to fulfil the respective purpose of processing or than the statutory period, where applicable. For example:

        • personal data you provide when filling in the contact form will be stored until your request is fulfilled or your enquiry is answered, and for a maximum of one year thereafter for statistics and marketing analysis;
        • personal data of our customers processed in connection with contracts concluded between us and the respective User will be stored for a period not exceeding ten years from 1 January of the year following the year in which the contract was reported for tax purposes;
        • personal data of our customers processed in connection with the issuing of tax documents (invoices) will be stored for a period not exceeding ten years from 1 January of the year following the year in which the document was reported for tax purposes;
        • personal data of our partners/suppliers processed in connection with contracts concluded between us and the respective partner/supplier will be stored for a period not exceeding ten years from 1 January of the year following the year in which the contract was reported for tax purposes;
        • personal data of participants in recruitment and selection procedures will be stored for a period not exceeding six months from the final completion of the recruitment/selection procedure in which the respective data subject participated, or after the expiry of the period for appealing the procedure, unless the data subject has consented to the storage of his/her personal data for a longer period, in which case the data subject has the right to withdraw consent at any time and without giving reasons.

The retention period depends, among other things, on the duration of the legal relationship between us and the respective User, as well as on the purposes for which the personal data is processed. Where there is any indication of potential legal claims or liability, these periods will be extended accordingly. Where processing is based on the User’s consent (for example: in the case of personal data provided by third parties for direct marketing), we store such personal data for as long as we have valid consent to process it.
After the above periods expire, we take the necessary care to delete and/or destroy your respective personal data without undue delay.

IX. ACCESS TO PERSONAL DATA AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES

As a rule, the Users’ personal data we process is accessible to our employees, representatives and partners who need it to fulfil legal obligations and/or contractual obligations (for example: providing a service under a contract with a User). In this regard, we may, at our own discretion and in compliance with the requirements of the GDPR, transfer all or part of your personal data to third parties such as accountants, professional advisers, including lawyers (for the purposes of financial, accounting and administrative support of our business), cloud platforms for data processing/storage (for the purposes of organisational support of our business, for example: storing and processing contracts with Users on cloud platforms for greater security), companies providing postal services (for the purposes of organisational support of our business, for example: sending paper contracts to Users), IT service providers, system administration, marketing services (for the purposes of more reliable and better operation of the Website and more secure data processing), and providers of services for storing third-party information (i.e. hosting companies) (for the purposes of performing contracts with Users).
Based on applicable legislation or at the request of public authorities, all or part of your personal data may also be made available to public authorities.
We have no intention of transferring your personal data to countries outside the European Economic Community or to international organisations.

X. RIGHTS OF DATA SUBJECTS

At any time while we process your personal data, and subject to the limitations set out in applicable legislation, you, as the data subject, have the following rights:

        • Right of access – you have the right to request information on whether we process your personal data, and to obtain access to and a copy of such personal data; if you request more than one copy of such personal data, you may be charged a fee for each additional copy;
        • Right to rectification/correction – you have the right to request that your personal data be corrected if you believe it is inaccurate or incomplete. We will make such rectifications/corrections without undue delay;
        • Right to erasure/to be forgotten – in certain circumstances (for example: the respective personal data is no longer necessary for the purposes for which it was collected; you have withdrawn your consent to the processing of certain personal data and there is no other legal basis for the processing) you may request that your personal data we process be erased from our records/database without undue delay. In certain cases we may refuse to erase such personal data (for example: the processing is necessary to comply with a legal obligation or for the establishment, exercise or defence of legal claims);
        • Right to restriction of processing – where certain conditions are met (for example: the processing of certain personal data is unlawful, but you do not want the data to be erased), you have the right to request a restriction of the way your personal data is processed;
        • Right to data portability – where your personal data has been provided by you and is processed by automated means, you have the right to request that such personal data be provided to you in a structured, commonly used and machine-readable format, and transferred to another controller, where technically feasible;
        • Right to object – you have the right, at any time, to object to the processing of your personal data for certain purposes, in which case we will stop using the personal data for that specific purpose unless we have compelling legitimate grounds to do so (for example: you have the right, at any time, to object to the processing of your personal data for direct marketing purposes, in which case we will stop processing your personal data for those purposes without undue delay);
        • Right to object to automated processing, including profiling – you have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, and you also have all the rights arising for you if you are subject to the legal effects of such processing;
        • Right to withdraw consent to processing – where we process your personal data on the basis of consent given, you have the right to withdraw your consent at any time. The withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

If, at a User’s request, we delete his/her personal data from our database, we will keep only the information that may be necessary to protect our legitimate interests or for public authorities.
You have the right to request that we inform you of all recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested has been disclosed. We may refuse to provide this information if this would be impossible or would involve disproportionate effort.
If we are required to transfer personal data to another controller, to rectify or erase personal data, to restrict or stop processing personal data, to provide information on the recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested was disclosed, or to provide access to personal data, and there are doubts as to the identity of the User making the request, we may first request additional information to confirm the identity of the data subject concerned.
If a third party to whom all or part of your personal data has been transferred is involved in the processing of your personal data (as stated in Part IX above), all of the above requests will be forwarded to that third party.
Exercising the above rights is free of charge for Users, except where the requests are manifestly unfounded or excessive. In such a case we may either charge a reasonable fee for fulfilling the request or refuse to act on the request.
Users may exercise the above rights by contacting us by e-mail at: [email protected]

XI. COMPLAINT TO A SUPERVISORY AUTHORITY

If you believe that your personal data is not being processed lawfully or that any of your rights related to personal data protection have been violated, you have the right to lodge a complaint with the competent supervisory authority for personal data protection specified in Part III above of the Personal Data Protection Policy. You also have the right to seek protection of your rights in court.
Where the Website contains links to other websites, we recommend that you carefully read the personal data protection/privacy policies of those other websites, because when you visit those pages your personal data may be processed by the websites in question, and such processing is not covered by the Personal Data Protection Policy.
We reserve the right to change the Personal Data Protection Policy at our discretion and whenever we see fit.

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