PROCESSING OF PERSONAL DATA OF
CUSTOMERS OF STM GROUP EOOD
Dear potential and current customers,
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 (the Regulation), introduced new requirements in relation to processing of personal data of natural persons in the European Union.
The protection of your personal data is important for STM Group EOOD. That is why STM Group applies the necessary organizational and technical measures for the lawful, appropriate and transparent processing of your personal data. In this Privacy Statement for processing of personal data of STM Group EOOD customers, it is illustrated for what purposes and on what grounds we will process your personal data, as well as for how long STM Group EOOD will store this data. Also, the Statement contains directions about execution of your rights as data subjects in compliance with the Regulation.
1. For the company – controller of personal data
STM Group EOOD is a company, registered with the Commercial Registry to the Registry Agency with UIC 201915070, having its seat and registered address: Sofia, Iskar Municipality, 64, Christofor Columb Blvd., office buiding B2, officer 2016. STM Group EOOD is represented by its manager Irina Aleksandrova Velikova. The person, designated by STM Group EOOD to be responsible for personal data protection in STM Group EOOD, is Viktoria Slavtcheva, phone: 02/4949 324, e-mail: firstname.lastname@example.org.
STM Group EOOD is a controller of your personal data.
2. General statements
All your personal data, which you provide to STM Group EOOD, will be processed in compliance with the Regulation and the law, which means that:
- Your personal data will be collected and processed only for the purposes, for which you are hereby informed;
- Your personal data will not be disclosed to third parties, except for the cases when they are provided to sub-contractors of STM Group EOOD, which have concluded a contract with STM Group EOOD for guaranteeing executions of its obligations towards yourself, or when explicitly required by law. The management of STM Group EOOD guarantees that such third parties process the personal data only for the purposes and for the period, for which the data has been provided.
- You have access to your personal data at any time and you may check their accuracy, as well as require the inaccuracies to be rectified.
- STM Group EOOD undertakes to apply best safety and security measures for preventing third persons from potential misuse of the personal data which you have provided.
is 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.
“Processing of personal data”
means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
– Identified natural person or natural person who can be identified through information, representing personal data.
4. Data Subjects
The Privacy Statement herein is intended to inform you about the way according to which STM Group EOOD processes your personal data, when you are a potential or existing customer of STM Group EOOD, as well as when you are a legal representative or an employee of our potential or existing customer.
5. Your rights as subjects of personal data, processed by STM Group EOOD
As a subject of personal data, processed by STM Group EOOD, you are entitled to certain rights which can be exerted through sending of an e-mail to the employee, designated to be responsible for the protection of personal data in STM Group EOOD. The employee, designated to be responsible for the protection of personal data in STM Group EOOD, guarantees you equal access and opportunity for executing of the following rights:
Right of access
– upon your request as Data Subject, STM Group EOOD is obliged to provide you with information related to the categories of personal data, related to you, which are collected and processed by STM Group, as well as for the purposes and period for which the data is being processed, for the recipients or categories of recipients, to whom your personal data is disclosed, and for the sources wherefrom the data is received, except for the cases where the data is directly collected by you.
Right of rectification / restriction / erasure
– upon your request, STM Group EOOD is obliged to rectify, restrict or suspend the processing of your personal data, in cases where the processing is unlawful. STM Group EOOD shall inform each third party, to which your personal data has been disclosed, for all rectifications and erasures, made by STM Group EOOD, as well as for the cases where the processing of your personal data has been suspended.
Right of data portability
– in your capacity of Data Subject you have the right to request receiving the personal data related to you, which you have provided to STM Group EOOD, in a commonly used, structured and machine-readable format, and you have the right to transmit those data to another controller, without hindrance from STM Group EOOD, to whom as a controller you have provided your personal data, in cases where the processing of your personal data is based on your consent or on contractual obligation, and the processing is carried out by automated means.
Right to object
– in your capacity of Data Subject, you have the right to object to processing of your personal data, when the processing of your data is based on the legitimate interest of STM Group EOOD. STM Group EOOD will review the objection as soon as possible after its submission and will provide its statement in writing. After the objections is reviewed, as a principle STM Group EOOD will no longer process your personal data and will informed all concerned parties, to whom your personal data has been transferred, for the objection and for the measures undertaken in relation thereto. In some cases, however, STM Group EOOD will have compelling legal grounds to continue the processing of your personal data even after submission of objection (for examples, in cases of court proceedings, monitoring related to fraud suspicion, etc.). In such cases STM Group EOOD will contact you for explaining of the reasons based on which it will continue processing of your personal data.
Right to withdraw consent
for processing of your personal data, in case it is processed by STM Group EOOD on the basis of your explicit consent, which has been explicitly requested by STM Group EOOD and you have provided through a specific written statement. Withdrawal can be made through the same statement.
Right to lodge a complaint to the Commission for Personal Data Protection (CPDP)
– in your capacity of Data Subject, you have the right to lodge a complaint to the Commission for Personal Data Protection (CPDP) against any actions of STM Group EOOD related to processing of your personal data.
6. Personal data, processed by STM Group EPPD (according to purpose of processing)
For identification of customer or its legal representatives / employees, with whom STM Group EOOD is in professional contact – names, employer, position
For contact with customer – names, business phone (fixed or mobile), business e-mail address, business correspondence address
Public data – data for participation in commercial entities and non-profit organizations, publicly accessible through the Registry Agency; information made publicly available by you in internet sites, social networks and blogs
For ensuring the fulfillment of the services provided by STM Group EOOD in specific situations (for example, transportation from / to certain locations, requiring preliminary identification of persons in order access to be granted), when STM Group EOOD has the capacity of a data processor on behalf of a data controller – carrier – names, ID number, data from personal ID documents and/or driving license of persons, who are representatives / employees of the carrier, executing the relevant transportation service.
7. Recipients of personal data
The personal data of our potential and existing customers is processed by the employees of STM Group EOOD. Personal data of our potential and existing customers may be disclosed to third parties only in case there are undisputable lawful grounds and duly execution of authorization for requesting and disclosing them.
In some cases where STM Group EOOD the capacity of a data processor on behalf of a data controller – carrier, personal data of data subjects, who are employees of the carrier or persons, hired by the carrier, may be disclosed to third parties in order access to the place of loading / unloading to be granted to the driver/s of the transportation mean/s. In these cases the relevant carrier shall determine the grounds and purposes of personal data processing, and STM Group EOOD shall apply all nexeccasy measures for their protection according to the requirements of the Regulation.
8. Categories of persona data, grounds and purposes of personal data processing
8.1. Categories of processed personal data
In its capacity of controller of your personal data STM Group EOOD processes the following categories of personal data:
8.2. Grounds for personal data processing:
- Identification data (names, employer and position);
- Contact data – names, business phone (fixed or mobile), business e-mail address, business correspondence address
STM Group EOOD processes your personal data provided that one of the following conditions (grounds) is met:
- If the processing is necessary for the performance of a contract to which you or a company represented by you is party, or in order to take steps at your request prior to entering into a contract / execution of a service;
- If the processing is necessary for fulfilling of a special undertaking or is required by virtue of a special law, order or regulation, as well as with regard to measures and actions undertaken by STM Group EOOD for preventing, revealing, investigation and reporting of suspicious transactions and frauds;
- If you have given your explicit consent to the extent to which the nature of your relations with STM Group EOOD and the applicable legislation allow for;
- On the basis of the legitimate interest of STM Group EOOD.
In some cases STM Group EOOD may process your personal data on more than one ground.
8.3. Purposes of personal data processing
In its capacity of controller of your personal data, STM Group EOOD process your personal data for the following purposes:
9. Personal data storage period
- direct marketing – offering and sale of forwarding services, representing the main business activity of STM Group EOOD, whereupon we ensure you that STM Group EOOD has undertaken all necessary organizational and technical measures for the lawful, appropriate and transparent processing of the personal data of its potential and existing customers;
- execution of a contract for forwarding services between STM Group EOOD and you or a company, which you represent or you are an employee of.
Your personal data will not be stored longer than necessary. STM Group EOOD will keep your personal data for a period of 1 year after the date on which we had contacted you for the last time and you have unambiguously demonstrated lack of interest for the offered services. The processing of your personal data may be stopped even before this period ends, if you have deposited your explicit objection towards processing for direct marketing purposes.
If your personal data is processed within the relations for provision of forwarding cervices between STM Group EOOD and a company, which you represent or you are an employee of, your personal data will be processed until fulfillment of the agreed services.
10. Future amendments of the Privacy Statement of STM Group EOOD
It is possible the content of this Privacy Statement to be amended, if new legislative acts or amendments in the existing legislative acts are promulgated, as well as if new business practices are being taken. STM Group EOOD undertakes to timely inform you about all amendments.