This Privacy Statement explains what information we collect about you, why and how we use the information, and your rights in relation to the information provided to us.
Who are we
IMPEXTIM EOOD is a limited liability company, registered under the laws of the Republic of Bulgaria with UIC 204423291 in the Trade Register of the Registry Agency (hereinafter referred to as IMPEXTIM).
How to contact Impextim
Location: City of Sofia, Mladost District, 89 Aleksandar Malinov Blvd., Alpha Center, 6th floor, office 6.1
Phone: +359 87 9236986
Principles which we observe when we collect personal data
We at IMPEXTIM are aware of the responsibility we have for the security of your personal data. We always aim to process and manage your personal information in a transparent way for you, so we observe the following principles:
- We strive to collect the minimum amount of data needed;
- We keep your personal data accurate and up to date;
- When we no longer need your personal data, we delete or anonymise it so that we cannot identify you.
What is personal data
Under the General Data Protection Regulation, personal data is defined as:
“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 physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;”.
Therefore, personal data is not only your name, personal identification code, social security number, but also your home address, email, phone number, etc.
What personal data we collect and process
In the course of its business, IMPEXTIM processes various types of personal data according to the categories listed below. Depending on the specific products and/or services we provide you, IMPEXTIM processes some or all of the specified data.
Category of personal data about clients and counterparties:
- full name and personal identification number (or other identification number, where applicable);
- address, telephone and email for correspondence;
- where applicable, bank account number or other bank and payment information in connection with bank payments to and from IMPEXTIM;
- video surveillance of the working premises and entry to the IMPEXTIM work areas;
- history and information about contractual relations with you.
Source: Data subjects.
Category of personal data about visitors of our web pages:
- name (when sending a request);
- email for correspondence (when sending a request);
- information about your inquiries made through our web pages;
- information about the end-use electronic device used, the type of device, the operating system used, the IP address when visiting a website maintained by IMPEXTIM, if cookies and similar technologies are used.
Source: Data subjects, as well as cookies and related technologies.
In all cases where we process your personal data, we undertake to comply with the rules set out in this Privacy Statement and the requirements of the applicable European and national data protection legislation.
We process personal data only for the following purposes
- concluding and performance of contracts between you and IMPEXTIM;
- preparing and sending the invoices and payment documents for the products and services provided;
- administering websites maintained by IMPEXTIM;
- correspondence about the products and services we provide you, sending notifications or responding to requests, complaints and questions submitted by you;
- fulfillment of IMPEXTIM’s obligations under instructions and orders of state bodies or persons performing public functions (e.g. NRA, NSSI, courts, bailiffs, etc.);
- fulfillment of IMPEXTIM’s obligations under the Accountancy Act, the Tax and Insurance Procedure Code, the Commercial Act, as well as the fulfillment of all other legal obligations of IMPEXTIM, arising from the applicable European and national law.
We process personal data on the following legal basis
Performance of contract
The processing of your personal data is necessary to take steps to conclude and perform the concluded contracts between you and IMPEXTIM.
The processing of your data is also necessary in order to comply with the legal obligations of IMPEXTIM under the Accountancy Law, the Tax Insurance Procedure Code, the Commercial Law and other legislation containing legal obligations for IMPEXTIM.
In some cases, IMPEXTIM processes your personal data on the basis of its legitimate interests.
For example, the data collected from the cookies on our web pages is processed to improve the services we provide. Some documents with personal data (which are not subject to a specific data retention period) are kept until the expiry of the limitation periods laid down in the Bulgarian Obligations and Contracts Act, in view of IMPEXTIM’s legitimate interest for the establishment, exercise or defense of legal claims, as well and providing the necessary documents to clarify the legal dispute.
The data from the video surveillance is processed on the basis of the legitimate interests of IMPEXTIM. These interests are related to ensuring the rules on health and safety at work; the guarantee of labor discipline; and ensuring the security and protection of employees as well as the premises where personal data and confidential information are processed.
Based on your consent, we may provide you answers to inquiries, notifications, and news about the activities of IMPEXTIM.
The provision of your personal data to us is voluntary
IMPEXTIM processes your personal data in order to provide the products or services for which an agreement is about to be reached or has already been reached with you, as well as for the purposes for which your explicit consent has been obtained.
If you do not provide your personal data to us, we may not be able to enter into or perform a contract you have already concluded with us, respectively we may not be able to fulfil our statutory obligations.
Upon withdrawal of consent to receive replies to inquiries, notifications, or news from IMPEXTIM, we will stop processing the data for these purposes.
Which third parties have the right to receive personal data processed by us
IMPEXTIM does not provide your personal data to external organizations / individuals before making sure that the processing is in compliance with applicable European and national data protection legislation. IMPEXTIM exercises rigorous control over whether the personal data is processed on an appropriate legal basis and whether the appropriate technical and organizational measures have been implemented.
We provide personal data to the following categories of recipients:
- to bodies, institutions and persons to which we are obliged to provide personal data under the applicable legislation (NSSI, NRA, MI, FSC, courts, etc.);
- our business counterparts who have committed to confidentiality, in compliance with applicable data protection legislation, including:
– Bulgarian post service and other persons providing courier services;
– persons providing accounting and auditing services;
– persons providing security services (when visiting a IMPEXTIM office / workplace);
– persons providing IT and telecommunication services;
– persons providing legal services;
– persons providing external consulting services in different areas;
– notaries, bailiffs and other persons performing public functions on the basis of their competencies provided by law.
- to banks, to the extent necessary to pay due remunerations;
- to IMPEXTIM’s employees authorized to process documents containing personal data, only to the extent necessary for performance of their work duties.
Transfer of personal data outside of EU
IMPEXTIM does not provide your personal data to companies in non-EU countries.
If IMPEXTIM decides to transfer your personal data outside of the EU, you will be notified.
Each transfer will be made in accordance with the requirements of the General Data Protection Regulation: subject to a decision on the adequacy of the European Commission, subject to appropriate safeguards or binding corporate rules approved by a competent authority.
Apart from the above, IMPEXTIM may transfer your personal data to non-EU countries only to the extent that you have given your consent or transfer is necessary for the conclusion/performance of contracts between you and IMPEXTIM or contracts concluded in your interest.
Data retention period
IMPEXTIM processes your personal data only for the period necessary to achieve the purpose for which it was collected.
Once the purpose has been achieved, IMPEXTIM terminates the processing of the data. As an exception, IMPEXTIM keeps the data until the final settlement of all financial relations and/or expiration of the minimum statutory retention periods provided by the applicable legislation: the Labor Code, the Social Security Code, the Tax Insurance Procedure Code, the Accountancy Act, the Value Added Tax Act, the Private Security Act, the Law on Obligations and Contracts and other legislation which provide minimum data retention periods.
For example: Payrolls are kept for 50 years and tax control documents for 10 years. Certain documents with personal data for which no minimum statutory retention period is provided are kept until the expiry of the limitation periods specified in the Law on Obligations and Contracts (three or five years, depending on the type of claim) in view of IMPEXTIM’s legitimate interest for the establishment, exercise or defense of legal claims, as well as providing the necessary documents to clarify the legal dispute.
In case of amendments to the applicable legislation regarding the above mentioned retention periods, IMPEXTIM will comply with the applicable regulatory requirements.
You have the following rights as a data subject
At any time, while we store or process your personal data, you have the following rights:
Right of access
You have the right to request a copy of your personal data from IMPEXTIM and a right to access at any time your personal data.
Right to data portability
You have the right to request from IMPEXTIM your personal data in a form convenient to transfer to another data controller or to ask us to do so:
It is important to take into account that this right is only applicable when:
- Processing is based on your consent;
- The processing is connected with the performance of a contract;
- Processing is carried out by automated means.
Right to rectification
You have the right to ask IMPEXTIM to correct without undue delay your inaccurate personal data as well as data that is not up to date.
Right to erasure (‘right to be forgotten’)
You have the right to ask IMPEXTIM for your personal information to be erased.
It is important to take into account that IMPEXTIM is obliged to erase the data only if one of the following grounds applies:
- your personal data is no longer necessary for the purposes for which they were collected;
- withdrawal of your consent and we no longer have any other legal basis for the processing of your personal data;
- you object to the processing of your personal data for the purposes of direct marketing;
- you object to the processing of your personal data for the purposes of IMPEXTIM’s legitimate interests and there are no overriding legitimate grounds (such as improving user experience on a website);
- the personal data have been unlawfully processed;
- your personal data must be deleted to comply with the law.
Right to restriction of processing
You have the right to ask IMPEXTIM to restrict the processing of your personal data, in which case the data will only be stored but not processed.
It is important to take into account that IMPEXTIM is obliged to restrict processing only if one of the following grounds applies:
- the personal data which we process is not accurate and up to date;
- the processing is unlawful, but instead of deleting, you want us to restrict the use of your personal data;
- your personal data is no longer necessary for the purposes for which they were collected, but you require the data for the establishment, exercise or defense of legal claims;
- you have objected to the processing of your personal data and you are awaiting confirmation that your interests in relation to such an objection override the legitimate grounds of IMPEXTIM for processing your data.
Withdrawal of consent
You have the right to withdraw your consent for the processing of your personal data at any time with a separate request addressed to the controller in case your data is processed only on the basis of consent.
Right to object
You have the right to object to certain types of processing, such as direct marketing (including against unsolicited advertising).
The right not to be the subject of automated decision making
You have the right to object to automated processing, including profiling.
Automated decision making (processing) means that certain decisions are taken automatically without human intervention.
If we intend to use such methods, we will inform you and give you the opportunity to express your objection to such processing in advance. In addition, you are free to contact us for further information about such processing.
Right to lodge a complaint with a supervisory authority
If you believe that we do not process your personal data lawfully, we ask you to contact us to clarify the matter. Of course, you have the right to lodge a complaint directly with the competent data protection supervisory authority, which for Bulgaria is the Commission for Personal Data Protection, and you also have the right to an effective judicial remedy.
The address for lodging a complaint to the Commission for Personal Data Protection is: Bulgaria, Sofia 1592, 2 Prof. Tsvetan Lazarov Boulevard.
How can I exercice my right
It is necessary to fill in an application in a form, which you will receive after submitting a request to the contact details of IMPEXTIM:
Location: City of Sofia, Mladost District, 89 Aleksandar Malinov Blvd., Alpha Center, 6th floor, office 6.1
Phone: +359 87 9236986
In general, cookies do not collect personal information, but if they collect such, we will treat this data in accordance with this Privacy Statement.
We may collect the following data for you through cookies:
- the time spent on the website and pages visited;
- browser and operating system information for your device;
- the IP address of the device you are using;
- the links you click while using our page.
Information about used cookies
From your browser settings, you can see all the cookies currently in use on our website, as well as information about when the cookie was created and when it will be deleted.
We may use the following type of cookies on our website:
Strictly necessary cookies
These cookies support the smooth operation of our webpage, because they allow you to browse the information in it and use its functions. For example: these cookies allow us to show you information on our website in the correct language, etc.
These cookies allow the website to remember choices you make and provide more personal features. For instance, a functional cookie can be used to remember the volume level you prefer to use when watching videos on our websites. This information is completely anonymous, is used for very limited purposes and is kept for a limited time.
Analytical cookies allow us to get information about how the users use our website, whether users are working with it easily, and what part of the content attracts the most interest. The information is used only for statistical purposes and is not intended to be used for personally identifying users. Analytical tools are provided by Google Analytics and Adobe Analytics, and the information gathered for your IP address is not associated with any other information stored by Google and Adobe.
These cookies do not store personal information, but only collect information about how you used our website. They can be triggered by our advertising partners to show you relevant ads and information. They do not store personal information directly but are based on the unique ID of your browser and internet device
More information about cookie management
http://www.allaboutcookies.org/faqs/cookies.html is a useful resource with very detailed information about cookies and how to manage them.
You can delete all the cookies already stored on your computer, and you can also set your browser to block them. However, if you do so, you may need to manually set up some settings each time you visit a site, and some services and features may not work.
If you wish to disable cookies, you can do so by deleting them from the settings of your own browser and by installing the Google Analytics Opt-out Browser Add-on.