Personal Data Protection Policy


Information about us:

LAVENA AD is a company registered in the Commercial Register of the Registry Agency under UIC 837066835, with registered office and address of management: Shumen, Industrial Zone, PO 114, tel .: 054850138; fax: 054850119; e-mail: office@lavena.bg

Information about protection of personal data:

"Lavena" AD, Shumen, Industrial Zone, PO 114, dp@lavena.bg

LAVENA AD processes personal data in order to provide better and more diverse products and / or services. We are constantly striving to improve our service and, in doing so, we build strategic business partnerships with which we try to meet the needs of our customers when using our product portfolio.

Data confidentiality is of utmost importance to us and to the success of our business. The security of your data is ensured by appropriate technical and organizational measures aimed at preventing unauthorized access, unauthorized use, loss or destruction of information. We collect and process personal data in compliance with the requirements of the law, with the understanding that the processing of personal data is not unlimited and is for a specific purpose.

USE OF PERSONAL DATA FOR THE IMPLEMENTATION OF LEGAL OBLIGATIONS

We process personal data where this is provided for in statutory instruments in fulfilment of obligations:

• provided for in the Accountancy Law and the Tax-Insurance Procedure Code and other related statutory instruments in relation to bookkeeping;
  
  
• stipulated in the Public Offering of Securities Act and other related normative acts;
  
  
• for distance and / or off-site sales provided by the Consumer Protection Act;
  
  
• to provide information to the Consumer Protection Commission or third parties provided for in the Consumer Protection Act;
  
  
• to provide information to the court and third parties, in accordance with the requirements of procedural and substantive legal acts applicable to the proceedings;
  
  
• to provide information to the Commission on the protection of personal data in relation to obligations under the General Data Protection Regulation (Regulation 2016/679).
  
  

USE OF PERSONAL DATA FOR THE IMPLEMENTATION OF CONTRACTUAL OBLIGATIONS

We process personal data to provide products and / or services you have requested from us in the performance of contractual obligations and rights. Processing is done to:

• identifying client identity through a commercial channel;
  
  
• management and execution of a request for products and / or services, execution of a contract;
  
  
• preparing a contract for the conclusion of a contract;
  
  
• preparing and sending an account / invoice for products and / or services from us;
  
  
• providing services and collecting amounts due for products and / or services;
  
  
• Notification of products and / or services, sending various notifications, problems, errors or replying to received messages, complaints;
  
  
• compiling aggregated sales and / or service statistics and / or clients that we can also provide to third parties;
  
  
• analyzing and preparing a profile for determining an appropriate bid;
  
  
• protecting and safeguarding our business, our employees and our clients;
  
  
• evaluating and measuring the performance of our advertisements as well as offering matching advertisements;
  
  
• processing of billing / invoicing data for purposes consistent with the original purpose of collecting them, in order to provide an overview of our products and / or services;
  
  
• researching and analyzing products and / or services based on anonymous or personalized information, including collaboration with third parties, to develop products and / or services;
  
  
• performing data processing, including by joint administrators, when entering into a contract, assigning, reporting, accepting, settling.
  
  

USE OF PERSONAL DATA AFTER YOUR CONSENT

• Consent is the basis for the processing of personal data and the purpose is stated therein. In certain cases the processing of personal data is only possible after prior consent. Upon giving consent, and until its withdrawal and / or termination, we can prepare appropriate product and / or service offerings for Lavena AD by performing analyzes of personal data and / or consumption data.
  
  
• The consent given may be withdrawn at any time and shall not affect the performance of our contractual obligations, if any. When withdrawing consent to the processing of personal data for some or all of the grounds, Lavena AD shall not use the personal data for the objectives set out therein.
  
  
• Withdrawal of consent does not affect the lawfulness of consent-based processing prior to its withdrawal. The withdrawal of consent is made in the manner specified therein or by using our contact details.
  
  

USE OF PERSONAL DATA WITH REGARD TO OUR LEGAL INTEREST

• We use video surveillance on the territory of the enterprise, in view of our legitimate interest, in order to protect the property of the company and to ensure the safety of our employees and workers.
  
  

PROTECTION OF PERSONAL DATA

• We apply organizational and technical measures provided by the law and applicable in our organizational practice to provide data protection to employees / workers, consumers and our trading partners. The Company has designated a Data Protection Working Group to support data protection and security processes. For the sake of maximum security in the processing, transfer and storage of personal data, we can use security mechanisms such as encryption and others.

DELETION OF PERSONAL DATA

• The use of personal data is terminated for contract-related purposes after the termination of a contract but the data is not erased before the expiration of one year from the termination of the contract or until the final settlement of all financial obligations and the expiry of the statutory obligations to store the data:
  
  
• the Accounting Act for the storage and processing of accounting data (11 years);
  
  
• the Accounting Act for keeping salary payroll (50 years);
  
  
• according to the Obligations and Contracts Act the expiry of the prescribed limitation periods for claims (5 years);
  
  
• under the Electronic Communications Act for storing and providing information for the purpose of detecting and investigating crimes, obligations (6 months);
  
  
• on the obligation to provide information to a court, competent state authorities and other grounds provided for in current legislation (5 years).
  
  

SHARING PERSONAL DATA WITH THIRD PARTIES

• The provision of personal data to third parties is the main purpose of offering quality and complex service – the products and / or services we offer to meet consumer expectations.
  
  
• Personal data of third parties is provided before we are confident about the availability of technical and organizational measures to protect this data. In this case, we remain responsible for the confidentiality and security of personal data.
  
  

PROVISION OF PERSONAL DATA BY CATEGORIES OF RECEIVERS

• Persons processing data on behalf of Lavena AD:
  
  

• Distributors of Lavena AD acting as representatives of the company in the sale of products and / or services;
  
  
• persons hired under a civil contract by Lavena AD, assisting the processes of sale, logistics, delivery, etc .;
  
  
• persons who, by contract, maintain equipment, software and hardware used for the processing of personal data and needed to build the company's network and to provide services such as technical support, etc .;
  
  
• providers of electronic authentication services where a document related to the provision of a product or service is signed with an electronic signature;
  
  
• banks servicing payments executed by us;
  
  
• security companies holding a license to perform private security activities in connection with the processing of video recordings and / or the provision of the access regime in the enterprise;
  
  
• persons performing consultancy services in different spheres;
  
  
• bodies, institutions and persons to whom we are required to provide personal data under current legislation;
  
  
• persons, postal operators, with a view to sending consignments containing contracts, agreements and other documents, and the need to certify the identity when they are served;
  
  
• companies collecting and / or securing receivables – debt collection agencies, credit agencies, which by endorsement or other means, service and collect receivables.

Persons processing data in their own name

• competent authorities which, by virtue of a statutory instrument, have the power to request the provision of personal data – courts, prosecution offices, regulatory bodies.

RIGHTS IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA

• Right to information
  
  
• You are entitled to:
  
  

• information about whether your personal data is being processed for processing purposes, for the categories of data and recipients to whom the data is disclosed;
  
  
• a message in comprehensible form that contains your personal data being processed and information about its source;
  
  
• Information on any automated processing of personal data relating to you, if any.
  
  

• Right of correction
  
  
• You have the right at any time while processing incomplete or erroneous data to request:
  
  

• correcting inaccurate personal data without unnecessary delay;
  
  
• completing incomplete personal data, including by adding a statement.
  
  

• Right of deletion
  
  
• You may request a deletion when:
  
  

• personal data is no longer needed for the purposes for which it was collected or otherwise processed;
  
  
• withdraw consent to processing;
  
  
• personal data is not processed legally;
  
  
• in order to comply with a legal obligation under Union law or the law of a Member State that applies to the administrator.

• Right to restrict processing
  
  
• You have the right to request restriction of processing when:
  
  

• you disagree with the accuracy of the data for the period for which we must verify its accuracy;
  
  
• the processing of the data is without legal basis, but instead of deleting it, you want limited processing;
  
  
• you need to establish, exercise or protect legal claims, and we do not need this data;
  
  
• you file an objection to the processing of the data, when there is pending verification whether the grounds are legitimate.

• Right of portability
  
  
• You may ask us to provide the personal data you have entrusted to our care in an organized, orderly, structured, generally accepted electronic format if:
  
  

• we process the data according to a contract and based on the declaration of consent that may be withdrawn or according to a contractual obligation;
  
  
• processing is done in an automated manner.

• Right of objection
  
  
• You have the right, at any time and on grounds related to a particular situation, to:
  
  

• object to the processing of personal data, where there is a legitimate reason for doing so;
  
  
• in the case of a reasonable objection, the personal data of the data subject can no longer be processed;
  
  
• object to the processing of personal data for the purposes of direct marketing.
• Right of complaint

• You have the right to complain to a regulatory body within the EU and the Personal Data Protection Commission:

• Name: Commission for Personal Data Protection
• Headquarters and address of management: Sofia 1592, "Prof. 2 Tsvetan Lazarov
• Correspondence data: Sofia 1592, "Prof. 2 Tsvetan Lazarov
• Telephone: 02 915 3 518
• Email: kzld@government.bg, kzld@cpdp.bg
• Web site: www.cpdp.bg
• An application relating to the exercise of rights may be filed in person or by an expressly authorized person with a notarized power of attorney. An application may also be submitted electronically in accordance with the Electronic Document and Electronic Signature Act. Within 14 days of filing, we will pronounce on it. If a longer period is necessary for objective reasons – in order to collect all the requested data, or this seriously impedes our work, this period may be up to 30 days.

CHANGES AND RENEWAL OF DATA PROTECTION POLICY OF LAVENA AD

• This Privacy Policy is updated regularly. If any major changes are required, we will post messages to our Website http://lavena.bg/.
  
  
• We recommend that you regularly monitor our Privacy Policy to stay informed about the protection of personal data.
  
  
• The Privacy Policy of our Website and detailed information can be found here.