Privacy Policy and General Data Protection Regulation

CONFIDENTIALITY OF PERSONAL DATA
 

     For Spartak JSC, it is extremely important to protect your personal data when using the services of our company and we want to inform you how, for what purposes and for what terms your personal data are being processed. We collect, process and store personal data in the course of our business and, as a personal data processor, we strictly fulfill all of our obligations arising from General Data Protection Regulation (GDPR)2016/679 of European Parliament and Council of Europe, in relation to the processing of personal data and on the free movement of such data.

Personal data is any information or piece of information that identifies or could be used for your identification.

We may collect, process and store your personal data to the extent that is necessary in our activities and when we have a legal basis for it and/or the processing meets our legitimate purposes.

We may collect the following personal data:

• Identifying information: name, surname, family name and PIN;

• Personal data related to your social identity: information on education, professional qualifications, job and professional biography;

• Contact information: post address, telephone number, e-mail address;

• Financial information: tax ID, tax status, bank account details. If you are our shareholder, we process your personal data in relation to this legal relationship such as: identification data, number of shares and dividend amount;

• Data from your relationship with us: sent to emails or letters, shared with us at meetings or in a telephone conversation, through our website.

We do not collect personal data related to your racial or ethnic origin, religious, political or philosophical beliefs, membership of political parties or organizations, genetic data or data related to your sexual life or orientation unless we have a legal obligation to do so.

Our grounds for collecting and processing your personal data are related to:

• Implementation of regulatory requirements of the existing legislation – e.g. obligations to NRA, NSSI, Central Depository, etc.;

• Performing tasks of public interest;

• Existing, modification and termination of contract relationships, for the preparation of any documents in this connection (contracts, additional agreements, protocols, references, certificates, etc.);

• Accomplishing our legitimate interests;

• Your given consent.

If we process your data for purposes other than those listed above, we will inform you and, if necessary, request your consent.

We disclose your personal data only to:

• Judicial authorities, control administrative bodies, government agencies and other public authorities and organizations, on request and to the extent permitted by law;

• Some specialists from regulated business areas - such as notaries, auditors, lawyers, in cases where we need to implement and / or protect our legitimate rights and interests;

• Providers who provide services on our behalf, such as couriers, IT companies supporting our servers, etc.;

We require everyone with whom we share your data to respect the security of your personal data and to treat them in accordance with the law and the goals set.

Our website uses Google Analytics, a Google Analytics web service. ("Google"). Google Analytics uses so-called cookies, text files that are stored on your computer, and analyzes the use of the site.

Cookies collected for your use of the site are generally delivered to a Google server in the U.S. and stored there. In the case of activating IP anonymity for this web page, your IP address is abridged by Google in advance within EU Member States and other countries that have ratified the European Economic Area Agreement. Your full IP address is transmitted only in extraordinary cases on a US server where it is abridged. Google uses this information on the order of the owner of this website to analyze your usage to prepare activity reports on the website and to perform other site-specific and website-related services assigned to it by the owner.

Your Google Analytics IP address is not linked to other Google data. You can prevent cookies from being saved using the appropriate settings in your browser software. You can also prevent the data generated by cookies associated with your use of the site (including your IP address) from being transmitted to Google, as well as processing this data from Google by downloading and installing the appropriate plug-in for your browser.

We have put in place appropriate measures to protect your personal data from accidental or unlawful destruction, unauthorized access, alteration or dissemination as well as other illegal forms of processing.

Our employees, suppliers and other third parties who have a legitimate right to access your personal data or process your personal data are subject to a confidentiality obligation.

We comply with established policies to prevent any alleged violation of data privacy and will notify you and the competent authorities of an infringement when we are legally obliged to do so.

We store your personal data only as long as necessary to meet the purposes for which it was collected. We may be legally and contractually obliged to store personal data for a longer period.

The General Privacy Policy guarantees you a certain set of rights that you may exercise in relation to your personal data processed by us. You have the right of:

• Access: you may receive information relating to the processing of your personal data and a copy of that personal data;

• Correction: when you believe your personal data is inaccurate or incomplete, you may require that this personal data be corrected accordingly;

• Deletion: You may require the deletion of your personal data to the extent permitted by law, unless the company demonstrates that there are legal grounds for the processing;

• Restriction: You may require that your personal data be restrained to the extent permitted by law;

• Objection: You may object to the processing of your personal data on grounds related to a particular situation;

• Withdrawal of consent: If you have given your consent to the processing of your personal data, you have the right to withdraw it any time;

• Data portability: When legally applicable, you have the right to have your personal data returned to you or, when technically possible, sent to a third party;

• In accordance with the applicable requirements, in addition to your rights above, if you think your rights are violated, you may turn to the Personal Data Protection Commission, which is the competent governmental authority.

Headquarters and address of management: Sofia 1592, 2, Prof. Tsvetan Lazarov Blv

Phone: +359 2915 3518

E-mail: kzld@cpdp.bg

Web site: www.cpdp.bg

Spartak JSC, UIC 812116102, is a joint-stock company within the meaning of the Commercial Law, with headquarters and address of management: Burgas, 3 Odrin Str.

In our company there are SPARTAK's internal rules for the data protection measures, in accordance with Regulation (GDPR) 2016/679, regulating in detail the mechanisms for the collection, storage, processing, destruction or archiving of personal data; the technical and organizational measures for their protection; the rights of the individuals whose personal data we process; a description of the records kept and the storage terms; the responsibilities of the staff handling personal data.

Address for correspondence: Burgas, 3, Odrin Str.