BEST DRINK AND DRIVE Ltd., is a company with UIC 205477160, having its seat and management address at Sofia City, zh.k.”Drujba”, flat 89, ent. B, 6th floor, app. 38, phone: +359883455060; e-mail: firstname.lastname@example.org
Data protection officer
Name Miroslav Alexandrov Ivanov
GROUNDS AND PURPOSES OF THE PROCESSING OF PERSONAL DATA
We process personal data only when one of the following applies:
- There is concluded contract between you and us with the purpose to execute our contractual obligations;
- We received explicit consent from you – the purpose is being specified for each case;
- There is legal obligation for us to process the personal data;
- The legitimate interest of the Controller
PROCESSING OF DATA FOR THE EXECUTION OF CONTRACT OR DURING PRECONTRACTUAL RELATIONS
We process personal data to execute our contractual and precontractual obligations. The purpose of the processing is as follows:
- To Identify the data subject
- To provide our services
- Prepare offers
- Send you invoices/ bills for the services you are using
- To provide you full support
- To receive payments from you
- To maintain correspondence with you
- To make a User profile
Data we process
On this ground we process information regarding the type and content of the contract as well as any other information related to the contracted, including:
- Personal contact data – address, email, phone;
- Identification data – name, UIC, date of birth, client number;
- Order history through the user profile
- Email and mail correspondence
- Payment information
- IP address
In order to execute our contractual obligations we need the above inforamtion the execution would be impossible without it.
Transfer of personal data to third parties
We transfer data to third parties with the purpose to improve the quality of our services and offer you full support. We only transfer personal data to third parties, who have proved to us they have applied or required organizational and technical security measures.
We transfer personal data to the following categories of third parties
- Postal, shipment and delivery service providers;
- Technical support staff, who provides software and hardware services for us;
- Consultant services providers in different areas;
We delete personal data processed on this ground after 5 years after the contract has expired regardless of the reason of the expiration. We chose this time period, because this is the expiration period for the claims from a contract.
We delete personal data collected during pre contractual relations after 12 months.
PROCESSING OF DATA FOR COMPLIANCE WITH LEGAL OBLIGATIONS TO WHICH WE ARE SUBJECT
Sometimes there is a legal obligation for us to process personal data. In these cases we are obliged to process personal data. Such cases are:
- Obligations under Measures against money laundry act (MAMLA);
- Obligations under Consumer protection act (CPA)
- Obligations to provide personal data to Consumer protection commission and third parties under CPA;
- Obligations to provide personal data information to Personal data protection commission
- Obligations under Accounting act and Tax-Insurance Procedure Code (TIPC)
- Obligations to provide information to the court or third parties under the applicable procedure laws;
- Obligation to certify the age of the data subject
Personal data processed on this ground is being deleted after the obligation has been fulfilled or has expired. For example under the Accounting act we must store the personal data 11 years.
Transfer of data to third parties
In case of legal obligation for us we could transfer personal data to third parties such as public authorities.
AFTER RECEIPT OF YOUR CONSENT
We process personal data on this ground only after your explicit consent. The consent is given in compliance with Art. 7 from Regulation 679/ 2016 (GDPR).
We do not foresee any negative consequences for you in case you decide not to share your personal data.
The consent is a separate ground for the processing of personal data and the purpose of the processing is specified for each case.
On this ground we process only the data for which we have received your explicit consent. However, in most cases this data include only email
Transfer to third parties
On this ground we could transfer personal data to third parties, specified with the consent, such as Facebook or Google.
Withdrawal of the consent
The consent could be withdrawn at any time. The withdrawal does not in any way affect any contracts or other relations between you and us. The withdrawal does not affect the processing before the withdrawal was given.
To withdraw your consent you just have to use our website or write us an email.
We delete the data processed on this ground after receiving demand from you or 6 months from the initial processing.
We process data for statistical purposes, which includes analyses in which the results are just general and thus the data is anonymous. It is impossible to identify a person from this data.
Your data could also be anonymized, which is an alternative of the data deletion. In this case all personal data elements, which allow the identification of a person will be permanently deleted. The anonymized data is not a personal data.
To ensure the protection of personal data of the company and the clients we apply all required organizational and technical measures under Data protection act and GDPR, as well as the best international practices.
We have adopted Rules for data processing in the company and have appointed Data protection officer.
To ensure maximum security we could apply additional protection measures such as pseudonymisation, encrypting and other.
DATA FROM THIRD PARTIES
We do not process data from 3rd parties.
DATA SUBJECT RIGHTS
You have all data protection rights under Data protection act and GDPR.
You could use your right by contacting us through our website or just by writing us an email.
You have the right to:
- Be informed regarding the processing of your personal data
- Access your personal data
- Demand correction your personal data
- Deman deletion of your personal data
- Demand limitation of the processing of personal data
- Portability of personal data between the controllers
- Object against the processing of personal data
- Be excluded from fully automated desicions
- Protect your right in court or through administrative procedure in case of violation of data protection rights
Data subject could demand deletion in the following cases:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the data subject withdraws consent on which the processing is based and there is no other legal ground for the processing;
- the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
- the personal data have been unlawfully processed;
- the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
- the personal data have been collected in relation to the offer of information society to a person under 16 years.
Data subject has the right to restriction of personal data, when:
- the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
- the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
- the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
- the processing is based on consent or on a contract pursuant to point (b) of Article 6(1); and
- the processing is carried out by automated means
Right to make a claim
Data subject has the right to make a claim against the unlawful processing of personal data to the Data protection commission or the according court.
Personal data records
We maintain a record of our processing activities. This record contains the following information:
- Name and coordinates of the controller
- Purposes of the processing
- Description of the categories of data subjects and processed data;
- the categories of recipients to whom the personal data have been or will be disclosed including recipients in third countries or international organisations;
- where applicable, transfers of personal data to a third country or an international organisation, including the identification of that third country or international organisation and, in the case of transfers referred to in the second subparagraph of Article 49(1), the documentation of suitable safeguards;
- where possible, the envisaged time limits for erasure of the different categories of data;
- where possible, a general description of the technical and organisational security measures referred to in Article 32(1).