With regard to the requirements of the General Data Protection Regulation 2016/679 (GDPR), Sterna Consult Ltd., UIC 201741246, headquarters address: 10 Tsarevo Str., Plovdiv, Tel.: +359 (0) 887 54 98 59, e-mail: firstname.lastname@example.org, in its capacity of a Personal Data Administrator, applies the following policy for storing, processing and protection of personal data, in order to provide services and products according to the company’s area of activity, as well as to offer complex services of the highest quality.
We apply a personal data protection policy for data collected from you through our website www.sternaconsult.com and paper forms filled in by you or by a representative of yours, through e-mail correspondence, contract signing or pre-contractual relationships and other lawful methods for collecting personal data.
Personal data within the meaning of Article 2 (1) of the Personal Data Protection Act means any information relating to an individual, identified or identifiable, directly or indirectly, by an identification number or by one or more specific features.
Principles for the collection, processing and storing of personal data
In the processing of personal data, Sterna Consult applies the principles of:
- Lawfulness, good faith and transparency;
- Limitation of processing goals;
- Data minimization;
- Data accuracy and precision;
- Limitation of storage periods;
- Integrity and confidentiality of data processing;
- Appropriate level of security;
We process your personal data for the following purposes:
Contacts with customers and partners;
Provision of a service you have requested from us (a request for a quote, consultancy or an environmental service, etc.);
Employment and contractual relationships - contracts or in the context of pre-contractual relationships;
Registration or participation in training, information and consultancy events;
Mailing news related to upcoming or past events, with your prior explicit consent;
Sending messages about our services and products, with your prior explicit consent;
Sending messages about services and products of our partners, with your prior explicit consent;
Fulfillment of the obligations under the Accountancy Act, the Tax and Social Insurance Procedure Code and other related statutory acts, with regard to correct and lawful bookkeeping and accounting;
Compliance with legal and regulatory requirements and regulations related to the realization of the company's activity.
Categories of personal data stored and processed by Sterna Consult:
- Ordinary personal data - names, address, e-mail, mobile/landline telephone number;
- Data to be submitted for contract signature:
- Network data - data for the provision of electronic communications services;
- Other data - workplace, position within the company, education and qualification diplomas and certificates, CVs, references, letters, applications, e-mails, etc.;
- Data collected automatically when visiting our website.
Legal grounds for processing personal data
Sterna Consult relies on the following legal grounds for the storing and processing of personal data: consent, performance of a contract, legal obligation for the administrator, performance of a task of public interest and legitimate interest of the company or a third party.
Institutions/bodies/individuals, other than Sterna Consult, to which the stored personal data may be disclosed and/or provided:
Considering the specific activity of the company, the processed and stored personal data may be provided and disclosed to third entities and parties, directly related to and/or involved in our activities, including:
- Public bodies and institutions - ministries, judicial and supervisory bodies, local authorities, administrative and financing institutions of the European Union;
- Individuals processing personal data on their behalf - postal operators, telecommunication operators, banks, occupational medicine services, etc.
- Individuals processing personal data on behalf of Sterna Consult - a natural person appointed by the company, processing and storing personal data on behalf of the company; an accounting company, an IT company supporting the information system of Sterna Consult, subcontractors of Sterna Consult, etc .;
- Our partners, working on assignments of Sterna Consult on the basis of contractual relations, who have signed agreements on the confidentiality of information and the protection of personal data. Sterna Consult takes all measures to guarantee that these persons apply the same protection to your personal data as our own employees, and comply with the Policy of Sterna Consult on storing, processing and protection of personal data.
When implementing some of its services, Sterna Consult works with partners and customers from other EU and EEA countries, based on contractual relations. In such cases, personal data is provided only with the explicit consent of the clients/partners and only for the purposes described above and in compliance with national and the European personal data legislation.
Personal data storing period
The personal data provided by partners and clients are kept only for the period corresponding to the purposes described above or for a period established by law. If there is no such legal term, we assume that your personal data will be stored within a reasonable time period determined on the basis of additional criteria. The criteria for determining the storing period are consistent with our willingness to provide you with high-quality services as well as normal development of our partnership relations. Our goal is to secure that the storing of your personal data requires minimum actions on your part in terms of re-registration or re-submission of data. When the personal data we collect are no longer necessary for the purposes mentioned, we erase, anonymize or destroy them in another appropriate manner.
Measures to ensure the protection of personal data
Sterna Consult applies the optimal organizational and technical measures and tools to protect your personal data, in accordance with the effective national and European legislation. For the sake of maximum security in the processing, transfer and storing of personal data, we also use, where necessary, additional protection mechanisms such as encryption, pseudonymisation, etc.
Rights of data subjects
Pursuant to the Personal Data Protection Act in Bulgaria and the effective EU legislation on personal data, data subjects have:
- The right of access and information with regard to the stored personal data without adversely affecting the rights of other entities. You have the right to request access to your personal data at any time, as well as to be informed of the type of personal data we process and the purposes we use it for. In our privacy and confidentiality policy, we have described how we store and process personal data. You can access your data by emailing us at email@example.com or by checking the functionalities of your personal account.
- The right to rectification or supplementation
- The right to erasure (also known as right to be forgotten)
In some cases, we are legally obliged to store your personal data. In these cases, it will not be possible to erase your personal data from our systems.
- The right to restrict processing of personal data
- The right to personal data transfer
- The right to notify the authorities of a personal data breach and to lodge a complaint
You also have the right to file a complaint with the Commission for Personal Data Protection (CPDP) - 2 Tsvetan Lazarov Blvd., Sofia 1592, tel.: +359 (0) 2 915 3518, www.cpdp.bg.
Notification of a personal data breach
In the event of a breach of the security of the stored and processed personal data, Sterna Consult will notify the Commission for Personal Data Protection within the legally established deadline following detection of the violation. In addition, the company will take all possible feasible technical and organizational measures to protect your personal data.
If you have further questions, please contact us via e-mail at firstname.lastname@example.org, tel.: +359 (0) 887 549 859 or by post to: 10-A Tsarevo Str., Plovdiv, Bulgaria.
Date of last update: May 2018