Last updated: 25 May 2018
We recognize the importance of protecting your personal data and are committed to processing it responsibly and in compliance with the EU General Data Protection Regulation (GDPR) and the Bulgarian data protection law, as amended from time to time.
This Privacy Statement explains the personal data we process, how we process it, and for what purposes.
This Privacy Statement applies to the processing of personal information of existing and potential clients and their representatives; suppliers and business partners and their representatives; job applicants; visitors of our premises; visitors of our website; attendees of our events.
1. Who we are?
VOP OOD is a limited liability company, duly incorporated and existing under the laws of the Republic of Bulgaria, registered in the Commercial Register with the Registry Agency of the Republic of Bulgaria, Unified Identification Code 040276647, having its seat and registered address at: 1 Tchekanitsa Region, Mikroelektronika Industrial Area, Botevgrad 2140, Bulgaria (“VOP” or “we”).
The main activity of VOP is development, production and selling intelligent dental equipment on the market.
2. Which types of personal data do we process?
We may obtain different categories of personal data, as follows:
2.1. Personal data
The personal data we commonly collect to conduct our business activities is described below.
a. Contact details such as name, company, position, business or personal postal address, telephone number and email.
b. Professional details such as job and career experience, educational background and professional qualifications.
c. Financial information such as bank details.
d. CCTV at our sites may collect images of visitors. CCTV footage are stored for a period of 30 days.
2.2. Special categories of personal data.
We ask that you do not send us, and do not share any special categories of personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).
2.3. Child data
We do not intentionally collect information from individuals under 16 years of age. Our website is not intentionally designed for children under the age of 16.
3. Where do we source your personal data?
We collect personal data directly from individuals they refer to or indirectly about individuals from a variety of sources, including our clients, partners and suppliers.
VOP collects personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, including inquiries, or visit our website, attend events we organize or participate in, visit our office or store, apply for open positions at our company. We may also obtain personal data directly when, for example, we are establishing a business relationship, delivering goods and services.
We obtain personal data indirectly about individuals from a variety of sources, including our clients, partners and suppliers. We may attach personal data to our records to better understand and serve our business clients, satisfy a legal obligation, or pursue our legitimate interests.
When we enter into contractual relationships with our business clients, partners and suppliers, we usually obtain personal information about their representatives and contact persons.
We may collect and process personal data about candidates from an employment agency, and other parties including former employers and colleagues.
We may obtain personal data from public sources (such as Commercial Register), news articles, Internet searches, as well as social and professional networking sites (e.g., LinkedIn, Google, Facebook or Twitter).
4. What lawful reasons do we have for processing personal data?
We may rely on the following lawful reasons when we collect and process personal data to operate our business and provide our products and services:
We may process personal data in order to perform our contractual obligations.
We may rely on your freely given consent at the time you provided your personal data to us.
4.3. Legitimate interests
We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
a. Conducting our business;
b. Delivering goods and services to our clients;
c. Entering into and implementation of contracts with our suppliers and partners.
d. Direct marketing, including delivering information about our goods and services, promotions, events, greetings;
e. Offering information, goods and services to individuals who visit our website, including answering inquiries.
f. Preventing fraud or criminal activity and safeguarding our property;
g. Executing legal obligations and public interests.
4.4. Legal obligations
We may collect and process your personal data in order to comply with our legal or regulatory obligations.
4.5. Public interests
We may process personal data in order to meet public interest obligations or mandates.
5. Why do we need personal data?
We collect and process personal data to:
a. Deliver our goods and services.
b. Promote our goods and services to existing and prospective clients.
c. Send invitations and provide access to guests attending the events we organize or take part in.
d. Purchase goods and services from our suppliers.
e. Personalize online landing pages and communications we think would be of interest based on interactions with us.
f. Administer, maintain and ensure the security of our website.
g. Seek qualified candidates for open job positions at our company.
h. Process online requests.
i. Travel arrangement assistance.
j. Comply with legal and regulatory obligations.
6. Do we share personal data with third parties?
We may occasionally share personal data with trusted third parties which for example support our business activity. These recipients are contractually bound to protect the data we entrust to them. We may engage with several or all of the following categories of recipients:
a. Parties that support us to conduct our business (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services).
b. Our professional advisers, including lawyers, auditors and insurers.
c. Payment services providers.
d. Marketing services providers.
e. Courts, law enforcement or other government bodies or to other third parties as required by, and in accordance with, applicable law or regulation.
f. Recruitment services providers.
7. Do we transfer your personal data outside the European Economic Area?
We typically do not store and process personal data outside the European Economic Area (EEA). However, if it is necessary to transfer personal data outside the EEA for any legitimate reason, we will ensure the protection and security of your personal data by means of contracts, containing standard data protection clauses which are in a form approved by the European Commission.
9. How to access and control your personal data?
Your data protection rights are:
9.1. Right of access
You can ask us to confirm whether we are processing personal data about you, and if so, to provide more specific information.
9.2. Right to rectification
You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
9.3. Right to erasure (“right to be forgotten”)
You can ask us to erase your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
9.4. Right to restriction of processing
You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
9.5. Right to data portability
In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
9.6. Right to object
You can object to our use of your personal data where the processing is based on legitimate interests (for example direct marketing purposes) or performance of a task carried out in the public interest, including profiling based on these grounds. We may need to keep some minimal information to comply with your request.
9.7. Automated individual decision-making
You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
9.8. Right to withdraw consent
You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. You may withdraw your consent at any time by contacting us at email@example.com.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
10. How is your personal information secured?
We have implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.
We aim to ensure that access to your personal data is limited only to those who need to know it. Those individuals who have access to the data are bound by confidentiality obligation.
11. For what period do we retain personal information?
We will not retain personal information longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims.
12. Do we link to other websites?
Our website may contain links to other sites that are not governed by this Privacy Statement such as Facebook and Twitter. Please review the destination websites’ privacy policies before submitting personal data on those sites. Whilst we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other sites.
13. How to contact VOP if you have questions, comments or complaints?
If you have questions or comments about this Privacy Statement or how we handle personal data, you may contact us at:
Postal address: 1 Tchekanitsa Region, Mikroelektronika Industrial Area, Botevgrad 2140, Bulgaria
We aim to respond within 30 days from the date we receive privacy-related communications.
14. Dispute resolution or filing a complaint
You have the right to lodge a complaint with the Commission for Personal Data Protection to report concerns you may have about our data handling practices at:
Postal address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
Telephone:+359 (2) 91-53-518,
15. Do we update this Privacy Statement?
We update this Privacy Statement when necessary to provide greater transparency or in response to:
a. Feedback from clients, regulators, industry, or other stakeholders;
b. Changes in our goods and services; or
c. Changes in our data processing activities or policies.
When we post changes to this Privacy Statement, we will revise the “last updated” date at the top of the statement. If there are material changes to the statement, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Privacy Statement to learn how we are protecting your personal data.