Нашата политика за поверителност
Policy for Confidentiality and Protection of Personal Data
- 1. Introduction
1.1. The present Policy for Confidentiality and Protection of personal Data (the “Policy”) regulates the manner, in which “Avis Medica” MPHAT and DCC Ltd. will collect, process, and store your personal data in compliance with the requirements of “General Regulation for Data Protection” – Regulation (EC) 2016/679, Law of Protection of Personal Data in Republic of Bulgaria, and other legislative Bulgarian and international acts.
1.2. The confidentiality of information about our consumers is an essential priority for us. “Avis Medica” MPHAT and DCC Ltd. in their capacity as Administrators of Personal Data and in compliance with the legislation, and the good practices, apply the required technical and organizational measures for protection of the personal data of natural persons. “Avis Medica” MPHAT and DCC Ltd. conform with all provisions of the new regulation, whereat, they only collect data for the persons, to an extent of necessity, respectively: for carrying out the company business activity; for provision of our services; for use of our websites, and for the purposes of marketing.
1.3. The present Policy provides information about how and what types of personal data are collected by us from you and about you, why are they needed by us, to whom they can be presented or revealed, and how they are protected.
1.4.1. “personal data” means any information, related to an identified natural person, or a natural person who can be identified (subject of data”); a natural person who can be identified, is a person that can be identified directly or indirectly, especially through an identifier, such as a name, identification number, data of location, online identifier or by one or more indices, specific for the physical, physiological, genetic, psychic, mental, economic, cultural, or social identity of that natural person;
1.4.2. „processing" means any operation or aggregate of operations, performed with personal data or collection of personal data via automatic or other means, such as collecting, recording, organizing, structuring, storing, adapting, or modification, extracting, consulting, usage, disclosure by transmission, broadcasting or another manner, by means of which, the data become available, sorting, combining, limiting, erasing, or destructing;
1.4.3. The „Regulation“ means “General Regulation on Protection of Data " – Regulation (ЕС) 2016/679.
Please, read carefully the present Policy. By submitting your personal data to “Avis Medica” MPHAT and DCC Ltd., regardless whether by electronic means or on paper, you accept and agree with the practices, described in the present Policy for Confidentiality and Protection of Personal Data.
Please, should you have any questions with regard to the present policy, do not hesitate to contact us – with the Official in Charge of the Data Protection, and if you do not agree with any of the provisions contained in the Policy for Protection of Personal Data, we advise you to refrain from usage of your products and services, provided by “Avis Medica” MPHAT and DCC Ltd., which mandatorily necessitate submission of your personal data.
2. Contacts and Connections
2.1. Information about “Avis Medica” MPHAT and DCC Ltd. in its capacity as Administrator of Personal Data.
In conjunction with processing of your personal data, you can contact us through the following contacts:
Name: “Avis Medica” MPHAT Ltd.
Registered address and address of management: town of Pleven, 7 Kosta H. Pakev Str.
Mailing address: 7 Kosta H. Pakev Str.
Telephone: 064 90 90 90
Coordinates for contact with the Official in Charge of the Protection of Personal Data:
Address: town of Pleven, 7 Kosta H. Pakev Str.
Telephone: 0888 508 049
2.2. Information about the competent supervising authority:
Name: Commission for Personal Data Protection
Registered address and address of management: city of Sofia, PC: 1592, 2 “Tsvetan Lazarov” Blvd.
Mailing address: Bulgaria, town of Sofia, PC: 1592, 2 “Tsvetan Lazarov” Blvd.
Telephone: +359 2 915 3518
I case you consider that we violate your rights, related to processing of your personal data, and in conformity with the provisions of “General Regulation on Data Protection” – Regulation (ЕС) 2016/679, you have the right to file a complaint with the Official in Charge of Data Protection, to lay an appeal with a supervisory authority, and to seek protection by court procedure, as follows:
Right of complaint with a supervisory authority
In case you wish to file a complaint with reference to processing of your personal data, performed by us, or regarding the manner, by means of which, we have considered your complaint, you have the right to lay an appeal with the Commission for Personal Data Protection and the Official in Charge of Data Protection (if such is available).
You can file the complaint in one of the following manners:
- Personally, on paper at the bookkeeper’s office of CPDP, at address: city of Sofia, PC: 1592, 2 “Tsvetan Lazarov” Blvd.
- With a letter, at address: city of Sofia, PC: 1592, 2 “Tsvetan Lazarov” Blvd., Commission for Personal Data Protection.
- By fax,at address: 029153525.
- By electronic mail, at e-mail address of CPDP: (firstname.lastname@example.org). In this case, your complaint should be laid out as an electronic document, signed by electronic signature (not scanned).
- Through CPDP’s site, at address: https://cpdp.bg/?p=pages&aid=6 in the manner, described on the respective page. In this case, your complaint should be laid out as an electronic document, signed by electronic signature.
In any of these cases, the complaint should contain:
- data about the complainer – full name(s), address, telephone for contact, e-mail address
- (if available)
- nature of complaint
- other information and documents relevant to the complaint
- date and signature (for the electronic documents – electronic signature, for the paper
documents – sign manual)
CPDP provides a form of complaint to the Commission (for facilitation and orientation of the citizens), regarding abusive processing of personal data in the electorate list, supporting the registration of political subjects. The form can be downloaded from the following web page: https://cpdp.bg/userfiles/file/Documents_2017/Forma_jalba_politicheski subekti.doc
- 3. Principles and Grounds for Collecting, Processing, and Storing of Personal Data
3.1. In order for the processing of personal data to be in compliance with the legal provisions, the personal data are collected and used in a lawful way, the required security of operation for processing has been provided and “Avis Medica” MPHAT and DCC Ltd. have taken the necessary measures not to process personal data subject of unauthorized disclosure. In accordance with the basic principles, observed by “Avis Medica” MPHAT and DCC Ltd., your personal data are:
3.1.1. Processed in a lawful way, in good faith and in a transparent manner, regarding the subject of the data (“lawfulness, good faith, and transparency”);
3.1.2. Collected for concrete, explicitly indicated and legitimate purposes, and are not processed further in a manner, incompatible with these purposes (“limitation of the purposes”);
3.1.3. Suitable for, related with, and limited to the necessity, in relation to the purposes, for which they are processed (“bringing the data to a minimum”);
3.1.4. Accurate and maintained in updated format; “Avis Medica” MPHAT and DCC Ltd. have taken all reasonable measures, in order for the timely erasure ore correction of inaccurate personal data, taking in consideration the purposes for which they are processed (accuracy”);
3.1.5. Stored in a format, allowing identification of the subject of the data for a period, no longer than the necessary for the purposes, for which the personal data are processed; (“limitation of storing");
3.1.6. Processed in a manner, which guarantees an appropriate level of security of the personal data, including protection against unauthorized or unlawful processing and against incidental loss, destruction, or damage, whereupon, suitable technical or organizational measures are applied (“integrity and confidentiality");
3.1.7. “Avis Medica” MPHAT and DCC Ltd. bear responsibility and are in a condition to prove that they comply with the basic principles, regarding the processing of personal data (accountability”).
3.2. Grounds for collecting of personal data:
3.2.1. “Avis Medica” MPHAT and DCC Ltd. collect and process your personal data in relation to the use of the company site and subsequent provision of information, pursuant to Art. 6, par. 1 of Regulation (ЕС) 2016/679, and more particularly – pursuant to an explicit consent, received from you as a client/potential client. You are not obligated and we do not require from you to make a registration or to submit your personal data, in order to view our website, or to gain access to the larger part of its content. Submission of personal data via our website is made by means of the enquiry form. Submitting your personal data in the enquiry form – you have to give your consent for disclosure of the data, which automatically also means consent to let us process them, in order to answer your enquiry;
3.2.2. “Avis Medica” MPHAT and DCC Ltd. collect and process your personal data in case that you give your consent to receive messages from us, related to our projects, events, campaigns, offers, suggestions regarding tour business activity and news about the company;
3.2.3. “Avis Medica” MPHAT and DCC Ltd. collect and process your personal data also on the occasion of conclusion (including during negotiations, which did not end in conclusion of a contract) and/or execution of a concluded contract – contracts for use of our services; purchase-sale contracts, contracts, by means of which, we assign the carrying out of a given work, or the carrying out of services and/or orders, etc.)
3.2.4. “Avis Medica” MPHAT and DCC Ltd. collect and process personal data in relation to the compliance with legal obligations, which are applied to the administrator – in fulfillment of our obligations to the NRA (National Revenue Agency), NSSI (National Social Security Institute), and other state and municipal authorities;
3.2.5. “Avis Medica” MPHAT and DCC Ltd. administer personal data for the purposes of legitimate interests of the administrator or a third party, except when, before such interests, the interests or fundamental rights and freedoms of the subject of the data, which require protection of personal data, prevail;
3.2.6. “Avis Medica” MPHAT and DCC Ltd. collect and process personal data in relation to cadre selection for various, announced by the company vacant positions. The vacancies can be announced in “Careers” section of our site, with opportunity for application for a given position by means of a special form for contact, or by sending us a message and necessary documents to a specified e-mail address;
As well as, in other legally established hypotheses.
- 4. Purposes for processing of personal data
4.1. In accordance with the provisions of Section I – Transparency and provisions of Regulation (ЕС) 2016/679, “Avis Medica” MPHAT and DCC Ltd. provide transparent information, communication, and terms and conditions for exercising the rights of subjects of data, pursuant to Article 12 of the Regulation.
4.2. “Avis Medica” MPHAT and DCC Ltd. collect, process, and store personal data for the following purposes:
- Provision of services;
- Carrying out sales;
- For marketing activities – related to our projects, events, campaigns, offers, suggestions, related to our business activity, and news about the company, and (at explicitly expressed willingness to receive such information), etc.
- For communication with you – regarding legal relations based on contracts and non-contractual relations;
- For legal purposes – for solving legal disputes and protection of the legal interests of the partnership;
- For fulfillment of the legal employment and social security relations, including for the purposes of personnel selection;
- 5. Types of data, collected, processed, and stored by “Avis Medica” MPHAT and DCC Ltd.
5.1. For realization of the purposes, indicated in item 4 of the present policy, “Avis Medica” MPHAT and DCC Ltd. collect and process, and store the following categories of data:
Data for identification of persons: name, middle name, surname;
Data for contact: address, telephone, e-mail, position, etc.;
Data for IP address used (on entering the site);
Data, needed for legal employment relations (in accordance with company procedures), etc.;
Data, depending on the specificity of the used services, respectively, the type of legal relations, which you are participating in;
5.2. “Avis Medica” MPHAT and DCC Ltd. do not collect personal data, which concern racial or ethnical origin; which reveal political, religious or philosophical beliefs; genetic and biometric data;
- 6. Period of time for storing of personal data:
6.1. “Avis Medica” MPHAT and DCC Ltd. store your personal data for the period, necessary for accomplishment of the purposes, described in the present Policy, except, if a longer period of storage is needed, or if such a period is permitted by the applicable legislation. The storage is carried out in conformity with the legally determined periods of time for a particular category of documents (pay sheets, cost sheets, financial statements, accounting registers, etc.), as well as, the legally established limitation periods in the Tax and Social Security Proceedings Code (TSSPC), Accountancy Act (AA), Social Security Code (SSC), Obligations and Contracts Act (OCA). After expiry of the period of storage, “Avis Medica” MPHAT and DCC Ltd. take the necessary measures to erase and destroy all data, without unnecessary delay, following the accepted internal company procedure for destruction of personal data;
6.2. “Avis Medica” MPHAT and DCC Ltd. will notify you, in case, the period for storage of the data has to be prolonged, in view of the fulfillment of the purposes, execution of the contract, in view of legitimate interests of “Avis Medica” MPHAT and DCC Ltd., or else.
- 7. Destruction
“Avis Medica” MPHAT and DCC Ltd. will destroy your personal data within the shortest possible period of time and in such a manner, so that they can??? be reproduced or restored. “Avis Medica” MPHAT and DCC Ltd. have accepted a company procedure for destruction of personal data.
8. Sources of personal data
The personal data, collected by “Avis Medica” MPHAT and DCC Ltd. are collected from the persons, to whom they refer; through the forms for contact in the sites of the company; by third parties – our counteragents and/or agents, in compliance with the provisions of the Regulation.
9. Rights of the persons, whose data are processed by “Avis Medica” MPHAT and DCC Ltd.
9.1. Right of access:You have the right to request and receive from “Avis Medica” MPHAT and DCC Ltd. confirmation, whether personal, data referring to you, are processed; to be granted access to the data, referring to you, as well as, the information regarding to the collecting, processing, and storing your personal data; “Avis Medica” MPHAT and DCC Ltd. will provide you at request with a copy of the processed personal data, referring to you, in electronic or other appropriate format; the granting of access to the data is free of charge, however, “Avis Medica” MPHAT and DCC Ltd. reserve the right to charge an administrative fee, in case of repetitiveness or excessiveness of the requests;
9.2. Right of correction:You can correct or complete incorrect or incomplete data, referring to you, directly by sending a request to “Avis Medica” MPHAT and DCC Ltd.;
9.3. Right of erasure (right “to be forgotten”): You have the right to request from “Avis Medica” MPHAT and DCC Ltd. to erase the personal data, referring to you, and “Avis Medica” MPHAT and DCC Ltd. are obligated to erase them without unnecessary delay, when the grounds provided by the law are available and if another lawful reason for legitimate processing, or a lawful reason for refusal on the part of the administrator to erase the data is at hand; “Avis Medica” MPHAT and DCC Ltd. do not erase data, about which they have the legal obligation to safe-keep, including for defense, on occasion of court claims forwarded against them, or proving own rights.
9.4. Right of limitation: You have the right to request from “Avis Medica” MPHAT and DCC Ltd. to limit the processing of personal data referring to you, when: you contest the accuracy of the personal data, for a period of time, which allows “Avis Medica” MPHAT and DCC Ltd. to check the accuracy of the personal data; processing is unauthorized, however, do not wish your personal data to be erased, but only their use to be limited; “Avis Medica” MPHAT and DCC Ltd. do not need your your personal data for the purposes of processing, but you request them for establishment or defense of own legal claims; you have objected the processing and are expecting an inspection whether the legal grounds of “Avis Medica” MPHAT and DCC Ltd. prevail over your interests;
9.5. Right of transfer: You can at any time withdraw the data that are stored and processed about you, in reference to your relationship with “Avis Medica” MPHAT and DCC Ltd., by sending a written request to the administrator. When technically feasible, you can request a direct transfer of personal data to an administrator, indicated by you;
9.6. Right of information: You have the right to request to be notified about any action, related to correcting, erasing, or limiting of the processing;
9.7. Right of contest: You can contest at any time against the processing on the part of “Avis Medica” MPHAT and DCC Ltd. of personal data, referring to you, when the processing is on the grounds of: execution of a task of public interest or on the grounds of official powers; for the purposes of administrator’s legitimate interests; for the purposes of scientific or historical researches or for statistical purposes, including for profiling or processing for direct marketing purposes;
9.8. You have the right to refuse to be the subject of a decision, based only on automated processing only, including profiling, which gives rise to legal consequences concerning you or has a considerable bearing on you. “Avis Medica” MPHAT and DCC Ltd. do not perform automated decision making with data.
9.9. Right of complaint: You have the right to file a complaint with the Commission for Personal Data Protection in case of violation of Regulation (ЕС) № 2016/679 of 27 April 2016 and right of effective defense against CPDP, administrator, or processor of your personal data;
9.10. Right of compensation: You have the right of compensation for material and non-material damages, occurring as a result of violation of Regulation (ЕС) № 2016/679.
9.11. In order to exercise the above-indicated rights, you should file a request with “Avis Medica” MPHAT and DCC Ltd., as well as, to prove your personal identity and identity with the person, to whom the data refer.
9.12. You can exercise your rights in the following way:
- At the office of “Avis Medica” MPHAT and DCC Ltd., at address: town of Pleven, 7 Kosta H. Pakev Str.
- By phone: Phone: 0888508049
- On the Internet: E-mail address email@example.com
- 10. Withdrawal of consent for processing of your personal data
When you have given your consent for processing of your personal data for one or more concrete purposes, if you do not wish all or part of the data to continue to be processed by “Avis Medica” MPHAT and DCC Ltd. for a concrete purpose or for all purposes of processing, you can, at any time, withdraw your consent for processing by means of a request sent to “Avis Medica” MPHAT and DCC Ltd., in a free text format.
- 11. Transmission of personal data to third states or international organizations
11.1. Transmission of personal data, which are being processed or are intended to be processed after transmission to a third country or an international organization outside the EU, is to be carried out by “Avis Medica” MPHAT and DCC Ltd. only in conformity with the provisions of the General Regulation concerning the protection of the data – Regulation (ЕС) 2016/679, whereupon, the provisions, specified in Chapter V of the Regulation, are being adhered to. “Avis Medica” MPHAT and DCC Ltd. apply all provisions of the Regulation, so that there will be no hazard for the necessary level of protection of the natural persons, provided by the Regulation.
11.2. In case that “Avis Medica” MPHAT and DCC Ltd. are about to make a transfer of personal data to a third country or to an international organization outside the EU, such a transfer is to be made in conformity with Company Procedure for Transfer of Data Outside the EU, and the subjects of the data shall be notified in advance, whereat, their Consent for Personal Data Transmission is required
- 12. Persons, before whom your personal data are disclosed
The persons – employees of “Avis Medica” MPHAT and DCC Ltd., who have access to your personal data, are strictly specified in the By-laws of the company and in the procedures for processing of personal data, whereupon, the level of access to the different registers has been determined.
It is possible for “Avis Medica” MPHAT and DCC Ltd. to transfer your personal data to third parties, who have a relation to the processing or are processors of personal data, to administrative structures and authorities of the executive power, etc., or persons, related to “Avis Medica” MPHAT and DCC Ltd., (for the purposes of financial statements). In all cages, the transmission of personal data by “Avis Medica” MPHAT and DCC Ltd. is carried out for achievement of the purposes of processing and in strict adherence to the provisions of Regulation (ЕС) 2016/679.
- 13. Violations and Notification for violations
13.1. “Violation of the personal data security” means a violation of the security, which leads to accidental or unauthorized destruction, loss, modification, unauthorized disclosure or access to personal data, which are transmitted, stored, or processed in another manner by “Avis Medica” MPHAT and DCC Ltd.
13.2. In case of violation of the personal data security, which provokes a possibility of occurrence of risk for the rights and freedoms of the natural persons, without an unnecessary delay, and when this is plausible, - no later than 72 hours after that has become obvious, “Avis Medica” MPHAT and DCC Ltd. notify the Commission for Personal Data Protection about the violation.
13.3. If “Avis Medica” MPHAT and DCC Ltd. detect a violation of your personal data security that can give rise to a high risk for your rights and freedoms, we will notify you without an unnecessary delay, about the violation, as well as, about the measures, which have been taken or are about to be taken.
“Avis Medica” MPHAT and DCC Ltd. may not notify you, if:
- They have taken appropriate technical and organizational measures for protection regarding the data, involved in the security violation;
- They have taken consequential measures, which guarantee that the violation will not lead to a high risk for your rights;
- The notification will require disproportionate efforts.
- 14. Modifications in the policy for confidentiality
“Avis Medica” MPHAT and DCC Ltd. have the right to update, whereat, amend and supplement the policy for protection of the personal data at any time in the future, whenever necessitated by the circumstances.