Obligatory information on the rights of personal data protection (Privacy Policy)

General information

From May 25, 2018 A new General Data Protection Regulation, adopted by the European Union, enters into force. The regulation aims to guarantee the protection of the data of individuals from all EU Member States and to harmonize the rules for their processing.

As a personal data controller, RONEVA Ltd. meets all the requirements of the new regulation, collecting only the data of the persons to the extent necessary for the provision of the service, and keeping them responsibly and legally.

Information about the Data Controller

1. The name "RONEVA" Ltd.

2. UIC / BULSTAT: BG202435373

3. Registered office and registered office: Varna, 6 Donka Zlateva Str.

4. Correspondence data: Varna, 6 Donka Zlateva Str.

5. Email: office@roneva.bg

Information concerning the competent supervisory authority

1. Name: Personal Data Protection Commission

2. Registered office and registered office: 1592 Sofia, Prof. Tsvetan Lazarov ”№ 2

3. Correspondence data: 1592 Sofia, Prof. Tsvetan Lazarov ”№ 2

4. Phone: 02 915 3 518

5. Email: kzld@government.bg, kzld@cpdp.bg

6. Website: www.cpdp.bg

RONEVA Ltd. operates in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

Grounds for collecting, processing and storing your personal data

Art. 1. (1) RONEVA Ltd. collects and processes your personal data in connection with the provision of services on the basis of the following:

● Fulfillment of the obligations of RONEVA Ltd. under contract with you;

● Your explicit consent was obtained upon request through the site of RONEVA Ltd. https://www.roneva.bg/en/contacts/ AND https://www.roneva.bg/en/imot/

● For the purposes of the legitimate interest of RONEVA OOD.

Objectives and principles for the collection, processing and storage of your personal data

Art. 2. (1) RONEVA OOD collects and processes the personal data you provide to us in connection with the use of our services and to conclude a contract with the company, as well as to request through the site of RONEVA OOD, including for the following purposes :

● individualisation of a party to the contract;

● accounting goals;

● protection of information security;

● ensuring the performance of the contract for the provision of the relevant service;

(2) RONEVA Ltd. adheres to the following principles in the processing of your personal data:

● lawfulness, integrity and transparency;

● limitation of processing purposes;

● correlation with the purposes of processing and minimizing the data collected;

● data accuracy and timeliness;

● storage limitation to achieve goals;

● integrity and confidentiality of processing and ensuring an adequate level of personal data security.

(3) In the processing and storage of personal data, RONEVA Ltd. may process and store personal data in order to protect its legitimate interests:

● fulfillment of its obligations to the National Revenue Agency, the Ministry of the Interior and other state and municipal bodies.

What types of personal data is collected, processed and stored by RONEVA OOD?

Art. 3. (1) "RONEVA" Ltd. performs the following operations with personal data for the following purposes:

● Conclude and execute a trade transaction with a client or partner

(2) RONEVA Ltd. processes the following categories of personal data and information for the following purposes and on the following grounds:

● Data: Your personally identifiable information: Names on ID card or passport, PIN / ID, citizenship, ID card / valid national ID, address, email and telephone.

○ Purpose for which data is collected: 1) execution of a contract with a trading partner and its administration ;;

○ Reason for processing your personal data - contractual basis

● Additional information provided by you - If you would like to make a request through the site of RONEVA Ltd.: https://www.roneva.bg/en/contacts/ And https://www.roneva.bg/en/imot /, you must fill out an online form that requires: name, surname, email and telephone.

○ Purpose for which the data is collected: Request for information on the activities and services of RONEVA Ltd.

○ Grounds for data processing: By agreeing to the terms and conditions and privacy policy of the Website, you give your express consent to the processing of your personal data for that purpose.

● Other data that RONEVA OOD processes - Upon entering our website, RONEVA OOD collects data about the IP address used.

○ Purpose for which data is collected: Improvement of service security and interface localization, statistical and marketing surveys.

○ Grounds for data processing: The IP address is collected on the grounds of fulfilling the legitimate interests of the administrator - Art. 6, para. 1, b. (f) GDPR;

● Your Individual Invoice Information - If you wish to be issued an invoice in your capacity as an individual, you must provide your unique citizen ID.

○ Purpose for which the data is collected: Issuance of an invoice for making payments under a concluded service contract.

Вание Reason for processing your personal data - Upon entering into a written contract, a contractual relationship is created between RONEVA Ltd. and you, on the basis of which we process your personal data - Art. 6, para. 1, b. (b) GDPR.

(3) RONEVA Ltd. does not collect or process personal data related to the following:

● disclose racial or ethnic origin;

● reveal political, religious or philosophical beliefs, or membership in trade union organizations;

● Genetic and biometric data, health data, or sexual life or sexual orientation data.

(4) The personal data have been collected by RONEVA Ltd. from the persons to whom they relate.

(5) The company does not carry out automated decision making with data.

The storage period of your personal data

Art. 4. (1) "RONEVA" OOD shall store your personal data for a period not longer than the requirements of the applicable legislation for the respective envisaged period. After this deadline, RONEVA Ltd. takes the necessary care to delete and destroy all your data without undue delay.

(2) RONEVA Ltd. notifies you in the event that the storage period of the data needs to be extended for the purpose of fulfilling the goals, the fulfillment of the contract, for the legitimate interests of RONEVA Ltd. or other.

Transmission of your personal data for processing

Art. 5. (1) RONEVA Ltd. may, at its sole discretion, transmit some or all of your personal data to processing personal data for the fulfillment of the processing objectives in compliance with the requirements of Regulation (EU) 2016/679.

(2) RONEVA Ltd. notifies you in case you intend to transfer some or all of your personal data to third countries or international organizations.

Your rights in the collection, processing and storage of your personal data

Withdrawal of consent to the processing of your personal data

Art. 6. (1) If you do not wish all or part of your personal data to be further processed by "RONEVA" Ltd. for specific or for all purposes of processing, you may at any time withdraw your consent for processing by filling in an online form or by requesting in free text.

(2) RONEVA Ltd. may ask you to verify your identity and identity with the data subject.

Right of access

Art. 7. (1) You have the right to request and receive from RONEVA Ltd. confirmation that personal data related to you are processed.

(2) You have the right to access the data related to it, as well as to the information related to the collection, processing and storage of your personal data.

(3) "RONEVA" Ltd. provides you, upon request, with a copy of the processed personal data related to you, in electronic or other appropriate form.

(4) The granting of access to the data is free of charge, but RONEVA Ltd. reserves the right to impose an administrative fee in case of repeated or excessive requests.

Right of correction or completion

Art. 8. You may correct or fill in inaccurate or incomplete personal data related to you by making a request to "RONEVA" Ltd.

Right to be deleted ("to be forgotten")

Art. 9. (1) You have the right to request RONEVA OOD to delete your personal data related to you, and RONEVA OOD has the obligation to delete them without undue delay when any of the following reasons exist:

● personal data are no longer needed for purposes for which they were otherwise collected or processed;

● You withdraw your consent on which the processing of the data is based and there is no other legal basis for the processing;

● You object to the processing of personal data relating to you, including for direct marketing purposes, and there are no legitimate grounds for processing to take precedence;

● personal data were processed illegally;

● personal data must be deleted in order to comply with a legal obligation under EU or Member State law applicable to RONEVA OOD;

● personal data were collected in connection with the provision of information society services.

(2) RONEVA Ltd. shall not be obliged to delete personal data if it stores and processes:

● to exercise the right to freedom of expression and the right to information;

● compliance with a legal obligation requiring processing as provided for in EU or Member State law applicable to the Administrator or for the performance of a public interest task or in the exercise of official powers conferred on him;

● for reasons of public interest in the field of public health;

● for purposes of archiving in the public interest, for scientific or historical research or for statistical purposes;

● To establish, pursue, or defend legal claims.

(3) In order to exercise your right to "forget", you must submit a written request sent to RONEVA OOD, as well as to prove your identity and identity with the data subject by presenting your personal data on the spot card for identification purposes

(4) "RONEVA" Ltd. does not delete the data, which it has a legal obligation to keep, including for protection in connection with legal claims against it or proving its rights.

Right of restriction

Art. 10. You have the right to request RONEVA Ltd. to restrict the processing of your related data when:

● challenge the accuracy of personal data for a period allowing RONEVA OOD to verify the accuracy of personal data;

● the processing is unlawful, but you do not want your personal data to be deleted and only their use restricted;

● RONEVA OOD no longer needs personal data for the purposes of processing, but you require it to establish, exercise or defend your legal claims;

● You objected to the processing pending a review of whether the legitimate grounds of RONEVA OOD prevail over your interests.

Right to portability

Art. 11. (1) You may at any time download the data stored and processed for you in connection with the use of the services of "RONEVA" Ltd. by request by email.

(2) You may request RONEVA OOD to directly transfer your personal data to an administrator designated by you, where technically feasible.

Right to receive information

Art. 12. You may ask RONEVA OOD to inform you of any recipients to whom the personal data for which the processing, deletion or restriction of the processing has been requested have been disclosed. RONEVA OOD may refuse to provide this information if this would be impossible or would require a disproportionate effort.

Right to object

Art. 13. You may object at any time to the processing of personal data from RONEVA OOD that relate to you, including if it is processed for profiling or direct marketing purposes.

Your rights in breach of your personal data security

Art. 14. (1) If RONEVA OOD detects a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, we shall notify you without undue delay of the breach, as well as of the measures taken or forthcoming to be taken.

(2) RONEVA Ltd. shall not be obliged to notify you if:

● Has taken appropriate technical and organizational safeguards with respect to data affected by a security breach;

● subsequently took measures to ensure that the infringement would not pose a high risk to your rights;

● notification would require a disproportionate effort.

Persons to whom your personal data are provided

Art. 15. The controller does not transfer your data to third countries.

Other provisions

Art. 16. In the event of a violation of your rights under the aforementioned or applicable personal data protection legislation, you have the right to file a complaint with the Personal Data Protection Commission as follows:

1. Name: Personal Data Protection Commission

2. Registered office and registered office: 1592 Sofia, Prof. Tsvetan Lazarov ”№ 2

3. Correspondence data: 1592 Sofia, Prof. Tsvetan Lazarov ”№ 2

4. Phone: 02 915 3 518

5. Email: kzld@government.bg, kzld@cpdp.bg

6. Website: www.cpdp.bg

Art. 17. You may exercise all your rights regarding the protection of your personal data through the forms attached to this information. Of course, these forms are optional and you can submit your requests in any form that contains a statement to that effect and identifies you as the data owner.

Art. 18. If the consent concerns a transfer, the Administrator shall describe the potential risks of transferring the data to third countries in the absence of adequate protection and adequate remedies.

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