Data Protection Regulation

INFORMATION ON THE PROCESSING OF THE PERSONAL DATA BY THE EKOAL LTD

 

For EKOAL LTD is committed to protect any personal information it processes and invests a lot of efforts in this regard. In many cases the entity interacts with other companies providing different supplies and services (including transport and forwarding) (“Suppliers”), which act and operate by their employees, representatives, proxies and other persons who have the right or the obligation to represent them and bind them as well as to perform their obligations. Hereby we would like to explain how EKOAL LTD process personal information of natural persons who represent or act on behalf of entities that are in trade relation with the respective entity of  EKOAL LTD with regard to a purchase order for various supplies and services (including transport and forwarding) placed thereby, to a service or supplies agreement and to their performance, and its/their conduct or based on negotiations and agreement/s for sale of products manufactured or provided by the respective EKOAL LTD entity. The information that is protected is any information, which identifies or allows for natural persons to be directly or indirectly identified (“Personal data”).


 1.       Who process the Personal data?

 

ЕKOAL Ltd is company established and registered in Bulgaria under unified identification code 826047538 with head office located in the town of Razgrad - Razgrad 7200,  Severen Blvg 1, e-mail: info@ekoalbg.com. ЕKOAL Ltd has several stores located as follows:


Town of Razgrad - Warehouse, Store and Office.
Town of Silistra - Warehouse, Store and Office.
Town of Haskovo - Store.
Town of Byala (Rousse District) - Store.
Town of Isperih (Razgrad District) - Store.

Town of Tzar Kaloyan (Razgrad District) – Store.

 

Razgrad 7200 ,1, Severen Blvg.,E-mail: info@ekoalbg.com

Silistra 7500 ,West Industrial Zone, 20, Chinar

Byala 7100 ,Rousse region, 24, Nikola Petkov Str.

Haskovo 6300 ,62, Saedinenie Blvd.

Isperih 7400 ,Razgrad Region, 1,Stopanski dvor

Tzar Kaloyan 7280 ,Razgrad Region, 1,Drujba str.

 

ЕKOAL Ltd process Personal data as a data controller, legally and earnestly.

 

2. Who are the natural persons whose Personal data is processed?


 For conclusion and execution on a agreement/purchase order, for placing a purchase order or for acceptance a  purchase order for supplies and services (including transportation and forwarding), entering into supplies or service agreement and their delivery EKOAL LTD processes Personal data of at least one of the following natural persons (each referred to herein below as “the Person”):

 1.  Legal representative of the Supplier;

2.  Empowered representative holding a valid Power of attorney to represent the Supplier;

3.   Contact person of the Supplier explicitly announced by the Supplier in the supplies or service agreement or in any other way; and/or

4.  Employee of the Supplier whose duties are related to or necessary for the performance of the agreement/ purchase order.

 

3. What Personal data are processed?


 With regard to placing a purchase order for supplies and services (including transportation and forwarding) and agreements for sale of products  , the entering into supplies or service agreement and to their delivery EKOAL LTD processes the following categories of Personal data of the Person :

 

-          Identification data;

 

-          Contact data;

 

-          Data revealing the rights of the Person to operate on behalf of the Supplier (e.g. position within the company of the Supplier; assignment agreement; other).

 

Considering that the Person may have different rights regarding the Supplier and the concrete purchase order/ agreement, EKOAL LTD processes different part of the Personal data of the Person for different purposes. This is because each Person may have different functions for the Supplier or the agreement. For instance, the legal representatives have the ex lege right to bind the Supplier with obligations and in order to be sure that an agreement is valid EKOAL needs to check if the Person who signs an agreement has the rights to undertake obligations for the Supplier. The legal representatives and other employees of the Supplier may be also contact persons. In this case EKOAL LTD should keep their data in order to be able to contact the Supplier. Some of the above-mentioned groups of Personal data are obtained directly from the Person or the Supplier, others are obtained from different freely accessed public registers and sources (e.g. the Public Registry of companies in the respective EU country if available in English on Internet).

 

4. What are the purposes for processing Personal data?


 EKOAL LTD process Personal data of the Person with regard to the placing a purchase order for supplies and services, the entering into supplies or service agreement and to their delivery. The concrete purposes for us to process Personal data of the Person include:

 

-          Entering into a supplies and services agreement and its performance or placing a purchase order for supplies and services and its execution;

-          Reporting the agreement/ purchase order in the books of the company as per the requirements of the Bulgarian and the EU law;

 

-          Payments on the agreement/purchase order or providing collaterals if agreed;

 

-          Transportation and insurance of freight if required by the respective agreement or purchase order;

 

-          Internel reporting and analysis of the company activity;

 

-          Statutory audit of the annual financial reports of the company by a certified auditor;

 

-          Providing access to the premises and offices of  EKOAL LTD if it is necessary for the entering into agreement/purchase order or for its performance.

 

5. What are the legal grounds for processing Personal data?


 EKOAL LTD process Personal data of the Person on at least one of the following legal grounds:

 

-          The processing is necessary for placing of a purchase order for supplies and services, for entering into supplies or service agreement and for their performance, where the Person acts on behalf of a contracting party;

 

-          The processing is necessary for compliance with a legal obligation to which EKOAL LTD is subject. For instance, for the lawful issuance of invoice, certain personal data of the client’s legal representative should be provided;

 

-          The processing is necessary for the purposes of the legitimate interests pursued by EKOAL LTD (except where such interests are overridden by the interests or fundamental rights and freedoms of the Person that is a data subject).

 

6. How do we maintain and process Personal data?

 

EKOAL LTD stores Personal data of the Person in electronic form and on paper. Besides, EKOAL LTD maintains databases with Personal data of the Person in various software applications that are used for processing and management of documentation. EKOAL LTD stores, maintains and process Personal data of the Person in a secured environment. Access to Personal data processed by EKOAL LTD is granted only to those employees who need such an access for the fulfilment of the above-listed purposes or for the compliance with legal obligation. These employees are limited down to a certain number of employees in the Finance and Accounting department and in Purchasing, Logistics, Marketing, IT or another department depending on the subject matter of the concrete order/ agreement.

The processing of Personal data may include one or more of the following operations: collecting, recording, arranging, structuring, storing, change or adaptation, extraction, consulting, use, providing access by transferring, circulating or in any other way, which make the data known to third parties, ordering or combining, restricting, deleting or destroying. EKOAL LTD has and maintains a strict policy and order for protection of Personal data that ensure the effective and secure processing of the Personal data of the Person.

 

7. For what period are the Personal data kept?

 

EKOAL LTD keeps Personal data of the Persons for the period of validity of the supplies and service agreement/purchase order for supplies and services and for 10 (ten) more years after the termination of the agreement as per the requirements of the accounting legislation.

 

8.  Who do we share Personal data with? Do we transfer personal data to third countries?

 

 

EKOAL LTD do not transfer Personal data of the Person to other controllers or processorsOther controllers have no access to the Personal data of the Person except if they have this right by law (e.g. National Revenue Agency, bailiffs, etc.).

 

9. Is it possible the Personal data to be further disclosed?


The personal data may be disclosed by EKOAL LTD in case this is allowed by law with regard to corporate reorganization, sale of shares, sale of assets, mergers and acquisitions or other way of corporate or financial conversion of EKOAL LTD. Personal data of the Person may be further disclosed for the conduct of the purchase order or the performance of the sale agreement e.g. to transporters, insurers, banks or other financial institutions, as the case may be. Personal data of the Person may be further disclosed in order for the vital interests of the Person or legitimate interests of EKOAL LTD (except where such interests are overridden by the interests or fundamental rights and freedoms of the Person) to be protected or when as per EKOAL LTD judgement this is necessary for EKOAL LTD to be compliant with the applicable law or its legal obligations or to provide information or meet the demands of the competent controlling authorities.

 

10. Are the Personal data protected?


 EKOAL LTD provides and maintains suitable technical and organizational measures for the protection of the Personal data of the Person against any illegal access or use and/or against their accidental loss, change, disclosure, access and/or damage or copying. These measures aim to ensure a long-term protection and inviolability of the Personal data. EKOAL LTD assesses the measures on regular basis in order to achieve a permanent safety of the Personal data.

 

11.   What are the rights of the Person with regard to the Personal data protection?

 

In compliance with the law the Person has the following rights with regard to the protection of his/her Personal data:

 

-          right of access to his/her Personal data that are processed;

 

-          right to rectification of his/her Personal data that are processed;

 

-          right to erasure of his/her Personal data that are processed (“right to be forgotten“);

 

-          right to restriction of processing of his/her Personal data;

 

-          right to data portability;

 

-          right to object to processing of his/her Personal data; and

 

-          right to lodge a complaint with the Bulgarian Personal Data Protection Commission.

 

The Person may perform his/her rights by a written notice to EKOAL LTD sent to the contacts specified herein in the beginning except the right to lodge a complaint, which is performed before the Bulgarian Personal Data Protection Commission.

 

12. What happens in case of changes?

 In case of major change in the way that EKOAL LTD process Personal data of the Person and/or in the categories/types of the Personal data that are processed and/or in any other part of the scope of this notice, EKOAL LTD shall immediately notify the Person for the respective change by sending an updated version of this notice. The present notice is made by EKOAL LTD to the Person in compliance with 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.

 

REPRESENTATION BY THE PERSON

 

 The undersigned __________________________________________

in my capacity of _____________________________

 

                         (capacity of the Person toward the Supplier)

hereby represent that I have received a copy of the above notice, I read it and forwarded copies of it for information to the other Persons who have any relation with the supplies and service agreement/purchase order for supplies and services and its performance on behalf of _________________. 

                                                                                                      (Supplier’s name)                                                                                                                            

I understand the meaning of this document, I accept it for information and undertake to clarify it to the other Persons acting on behalf of ________________, for the confirmation of which I sign as follows:

                                                                  (Supplier’s name)

 

___________________                                                                                 Date: _____________

     (Person’s signature)