Policy for confidentiality and protection of personal data implemented by BONONIA ESTATE Ltd.
Our Customers’ satisfaction is a priority for us, which is why it is important for us that our Customers understand how and why we process their personal data.
DETAILS OF THE CONTROLLER
BONONIA ESTATE Ltd. is a commercial company registered in the Commercial Register of the Registry Agency under UIC 201666651, having its seat and registered address at 27B SREDNA GORA Str., ZONE B-5-3, Vazrazhdane Region, 1000 Sofia.
BONONIA ESTATE Ltd. is a data controller and, as such, processes your personal data in compliance with the principles of legality, good faith and transparency.
‘Personal data’ means 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 identity of that natural person.
BONONIA ESTATE Ltd. is a data controller, pursuant to the Regulation. The company processes personal data for the purpose of fulfilling pre-contractual and contractual obligations and performing duties imposed by the Accountancy Act, the Code of Tax and Social Security Procedure and other laws and regulations, in:
1/ the conclusion and execution of contracts for the supply of goods and services;
2/ the selection of staff and management of employment relations with its employees and persons employed under management and control contracts;
3/ others legal relations.
Apart from the above, BONONIA ESTATE Ltd. also has the right to process personal data subject to the explicit consent of the data subject.
‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
‘Recipient’ means a natural or legal person, public authority, agency or other body to which the personal data are disclosed, whether a third party or not.
PERSONAL DATA TO BE PROCESSED
BONONIA ESTATE Ltd. processes personal data either alone or jointly with service providers requiring data processing. Depending on the specific objectives, we process the following personal data:
- Data provided by you necessary for the identification and performance of contractual obligations toward the Customer: names, address, phone, e-mail, details of your representative if the item is received by a representative.
- Data collected on payment: identification number, bank account number.
- Details of the browsers, applications, type of access device, IP address used by you.
If you refuse to provide the required personal data, BONONIA ESTATE Ltd. will not be able to complete your order through its website.
PRINCIPLES, BASIS AND PURPOSES OF PROCESSING
BONONIA ESTATE Ltd. processes personal data of natural persons who are customers, counterparties, their representatives, obtained from them or from third parties, subject to the principles of legality, good faith, transparency, confidentiality, limitation of purposes, data minimization, storage limitation.
Personal data shall be processed on the grounds provided for in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on the protection of natural persons with regard to the processing of personal data, namely:
Where your consent to the processing of your personal data is necessary, we will only do this after having received your consent. In view of the need to fulfill our obligations, refusal to give consent could result in the impossibility to provide the respective product, e.g. without entering your names, phone and address, including an e-mail address, we would not be able to deliver the goods you have ordered. Where the processing of your personal data for a specific purpose is based on your consent, you may withdraw it at any time, without prejudice to the lawfulness of the processing prior to its withdrawal. The withdrawal of consent shall be valid henceforth and shall not be retroactive.
BONONIA ESTATE Ltd. processes your personal data where the processing is necessary for the performance of a contract to which the data subject is a party or for taking steps at the request of the person to conclude a contract. In order to conclude a contract with us, you need to provide information representing personal data so that we can deliver the goods and services you wish to receive.
In view of the need to fulfill our obligations and to exercise our rights under our respective relations with you, the refusal to provide personal data on your part could make it impossible for us to have the respective legal relations with you.
We process your personal data when processing is necessary for compliance with legal obligations, such as issuing invoices with personal data provided for in the Accountancy Act, providing customer information requested by a competent authority, keeping accounts and storing accounting and commercial information, as well as any other information and documents relevant to taxation and compulsory social security contributions.
Insofar as we are obliged to meet certain regulatory requirements laid down in laws or in other regulations, respectively, in view of the need to fulfill our obligations and to exercise our rights under our respective relations with our customers, the refusal to provide personal data on the part of a specific person could make it impossible for us to have the respective legal relations with you.
We process your personal data to deliver the goods or services you have requested, including by providing data to third parties, such as courier services or insurers, required for the performance of our contractual obligations, as well as on another valid legal basis, such as exploring the interest in our products in order to best meet the consumer demand.
The PURPOSES for which BONONIA ESTATE Ltd. processes your personal data are:
– conclusion or performance of a contract concluded with us, namely: the identification of a customer on registration to enter into a supply contract, amendment or termination of such contract;
– fulfilment of legal requirements: issuing of invoices with personal data provided for in the Accountancy Act, provision of customer information at the request of a competent authority;
– compliance with legal obligations of the controller under the Code of Tax and Social Security Procedure and the Accountancy Act: for the preservation of accounting and commercial information, keeping accounts and storage of the accounting information, as well as any other relevant information and documents relating to taxation and compulsory social security contributions;
– processing for the purposes of the legitimate interests of the controller: preparation and storage of statistical information and aggregated summaries for the development and improvement of the goods and services offered;
In the event that your personal data will subsequently be processed for purposes other than those for which they were collected/provided, before that processing, we will provide you with information about this other purpose and the remaining information required by law.
In accordance with the requirements of Regulation (EU) 2016/679, BONONIA ESTATE Ltd. may provide the personal data obtained from you which it processes to the following categories of recipients:
– to the natural persons to whom the data relate;
– for the execution of a statutory obligation of recipient third parties, such as bodies of the Ministry of Interior, public prosecution, court, enforcement agents, audit firms, National Revenue Agency, insurers, other public/supervisory authorities, agencies or persons.
– for the performance of contractual obligations of the following recipient third parties: courier services, transport firms, insurers, payment service providers and banks;
– to individuals who, by delegation from BONONIA ESTATE Ltd., support the software used for the processing of your personal data;
– to individuals carrying out accounting and auditing activity.
TRANSFERRING PERSONAL DATA
Your personal data shall not be transferred to a third country outside the EU. In the event that a service you use requires the transfer of your personal data to a third country outside the EU, appropriate safeguards shall be provided – standard contractual clauses or consent of the data subject. Transfer of personal data to a third country shall be permissible in accordance with the provisions of the Code of Tax and Social Security Procedure /relevant data shall be transmitted to the Executive Director of the National Revenue Agency and, in turn, to relevant participating jurisdictions/.
STORING PERSONAL DATA
BONONIA ESTATE Ltd. processes and stores your personal data for the time limits laid down in the current legislation. After the statutory deadlines have passed, we will destroy your personal data. Personal data for which no explicit retention period is set will be destroyed after the purposes for which they were collected and processed have been achieved. In particular, we will store your personal data as follows:
- In the case of a supply contract concluded between us, we will process and store your personal data for a period of time that is necessary and sufficient to prove the proper performance of our obligations to you, for a period no shorter than that laid down in the relevant regulation, but not less than 5 (five) years after the termination of the relevant legal relationship, arising from a contract concluded between us.
The accounting and commercial information as well as any other relevant information and documents relating to taxation and compulsory social security contributions shall be stored as follows: 1. accounting records and financial statements – 10 years; 2. tax and social security control documents – 5 years after the expiry of the limitation period for the discharge of the public debt to which they are related; 3. all other carriers – 5 years;
If no contract or order for delivery (where no contract is concluded) is concluded between BONONIA ESTATE Ltd. and you within 6 /six/ months of the date of receipt of personal data, your personal data that you have provided to BONONIA ESTATE Ltd. will be destroyed/deleted within 9 /nine/ months from the date of receipt.
Time limits may be extended further, for example in cases of court proceedings, extension of the limitation period due to interruption, and in the enforcement of legal provisions and requirements of supervisory bodies.
RIGHTS OF THE DATA SUBJECT
As the subject of personal data which are and as far as are processed by BONONIA ESTATE Ltd., you have the right to:
– request access to your personal data stored with us or to require from us to have your personal data corrected, respectively;
– require from us to restrict the processing of your personal data and to delete your personal data after the expiry of the relevant time limits specified in this notification;
– object to the processing of your personal data by BONONIA ESTATE Ltd.;
– data portability, where technically feasible and subject to a request from you and the new controller selected;
– withdraw your consent, at any time, to the processing of personal data by BONONIA ESTATE Ltd., where this is done on the basis of Article 6(1)(a) or Article 9(2)(a) of Regulation (EU) 2016/679.
– file a complaint to the Data Protection Commission at 2 Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Phone: 91 53 518, е-mail: firstname.lastname@example.org.
Any data subject may exercise his or her rights by submitting a written request to BONONIA ESTATE Ltd. in free text at the e-mail address of the company to which he or she will receive a reply in due time.