PRIVACY POLICY

Last updated: 26.06.2018

Thank you for visiting our Website. This Policy is intended to inform you of the way we process your personal data collected via this Website.

  1.Controller

Geotrading AD (hereinafter referred to as Geotrading or the Controller) is a data controller. The company is registered with the Bulgarian Commercial Register under UIC 202533127, having its seat and registered office at: Sofia 1606, 9 Lyulin planina Street, and correspondence address: Sofia 1517, 108 Besarabia Street.
In order to be as useful as possible through its Website, in certain cases Geotrading shall process personal data of users of the Website and as such it is a Controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation).
The security of your information is an important part of Geotrading's by-laws. As a Controller, Geotrading AD shall handle with priority the issues relating to the protection of your personal data collected when you visit our Website and during the processing and storage procedures in compliance with legal requirements.

  2.Contact the Controller

You can contact the Controller in one of the following ways:

  1. Personal data collected about you. Purposes and grounds for their processing

Using the information on our Website does not imply the provision of personal data on your part.
The Website contains the following functionality using which Geotrading may collect and process your personal data:

  3.1. Submitting an inquiry

The personal data collected and processed by Geotrading through the inquiry option of the Feedback Form: Your full name, e-mail address and other data you have decided to provide us with in your inquiry. The personal data mentioned above shall also be collected if you submit an inquiry to the emails listed in the Contacts section.
Your personal data shall be collected and processed:

  • For the purpose of sending an answer to the inquiry you have submitted.

The legal basis for processing your personal data in this case is your explicit voluntary consent, which we assume you have given by submitting the inquiry.
Geotrading shall process your personal data only for the time required to prepare and send a response to your inquiry and for a period of 3 months after our last correspondence with you, unless you become our customer, supplier or business partner, in which case the processing of your personal data shall be governed by the terms of the agreement signed between us;

  • We may also use this data for direct marketing purposes – to inform you of the products and services offered by Geotrading or to invite you to events organised by us.

In this case, the basis for processing your personal data shall be protecting Geotrading's legitimate business interests to present and promote its products and services.
Geotrading shall process your personal data for this purpose until you object to, or unsubscribe from receiving our direct marketing messages at the following e-mail: office@geotrading.bg.

  3.2. Job Application

You can apply for a job in Geotrading through the Careers section by submitting your CV and motivation letter and/or references at the e-mail address: hr@geotrading.bg. In these cases, Geotrading shall process the personal data you provide (for example, full name, PIN, background, education, employment, address, e-mail address, telephone number, as well as any other information you have decided to include in your CV) for the following purposes:

  • To offer you an appropriate position in Geotrading, if there is one currently available.

In this case, the basis for the processing your personal data shall be taking steps, at your request, with a view to the possible conclusion of a contract. Personal data
If you are not offered a job in Geotrading, your personal data provided with your CV shall be destroyed.

  3.3. Events and campaigns organised by/with the participation of Geotrading

Forums, exhibitions and other public events

As part of its business activities, Geotrading organises and/or participates with its own stalls in various forums, trade fairs and other public events aimed at promoting the products and services offered by the company or fulfilling the purposes of the company's corporate social responsibility policy.
Selected photos and/or video footage from these events shall be published on the company's Website, in PR materials published in the media, in advertising materials, catalogues, publications, audio-visual works and the like, relating to the activities of Geotrading AD or of other Group Companies, in accordance with the commercial policy and advertising strategy set by the management of the company.

It may be possible to identify employees of the company (and/or of other Group Companies), as well as third parties, from these photos. In some cases, the photos are accompanied by an explanatory text, which includes the names of some of the persons involved.
When events are organised by the Company or when it participates in exhibitions, the territory within which there may be photographing and video recording is specified. At the entrance of the specified territory, written information shall be provided about the video recording of the event/exhibition and that by participating in the event or entering the specified territory the person concerned voluntarily provides his/her personal data that may be obtained through the video recording of his/her image.

Children's holidays

As part of the implementation of its corporate and social responsibility policy, the Company organises children's holidays on various occasions intended for the children of employees of the company or of other Group Companies.
Photos from these events are published on the company's Website. The photos also include images of the children involved in the celebration, and are sometimes accompanied by text containing the children's names. The collection and processing of these personal data of the children shall be carried out with the explicit consent of their legal representatives – a parent/ guardian, and for children over the age of 14 but under the age of 18 – with the consent of the child and the parent/ guardian.

In the above cases of Geotrading organising/participating in events and holidays, the personal data of the participants in the event may be provided to/ processed by the photographers and video operators contracted, who are covering the event, to the companies providing promotional services to Geotrading, to the company maintaining the Website and to various media.

In the cases described above, the processing of personal data shall be carried out by Geotrading for the following purposes:

  • to promote the products and services offered by the company;
  • to implement the corporate social responsibility policy adopted by the company.

The grounds for processing personal data in these cases are: protection of the legitimate interests of the company (to present and promote their products and services, its corporate social responsibility policy) and the consent of the children's parents.

Processing shall be carried out for as long as necessary for the above purposes of the company, but in any case for a period not longer than 5 years.

3.4. Other data collected

Besides the above personal data collected by Geotrading, in cases of use of certain functions of the Website, the following data may be additionally processed:

  • Geotrading uses cookies and other tracking technologies that collect information from you when you interacting with our Website in order to improve its performance and functionality.

Cookies are small text files that may be saved on your computer or mobile device when you visit a website. A cookie will help the Website or other websites to recognise your device the next time you visit it. Web beacons or other similar files can do the same. In this Policy, we use the term cookies to refer to all the files collecting information in this manner.

You can find more information about cookies and how to opt out of using cookies on your device in our Cookie Policy.

  4.Consequences of nondisclosure of personal data

When you intend to submit an inquiry to us, the provision of your data is entirely voluntary, but when you intend to apply for a job with us, the provision of your data is necessary.
If you do not wish to provide your personal data, you will not be able to receive your desired services – we will not be able to respond to your inquiry or offer you a position at Geotrading.

  5.Disclosing your personal data

Geotrading may disclose your personal data to the following categories of recipients:

  • state authorities to whom we are obliged to provide personal data under by a law;
  • the company contracted by Geotrading to maintain this Website;
  • the company contracted by Geotrading to promote its business;
  • persons providing photographic services during events organised by Geotrading.

  6.Your rights regarding the processing of personal data

In connection with the processing of your personal data by Geotrading, you have various rights protecting your interests. All rights listed below can be exercised upon submission of a request to Geotrading using the contact details provided in the Contact the Controller section. Geotrading shall make provision to respond to your request without undue delay.

  • Right to access:

You have the fundamental right to receive confirmation from Geotrading at any time as to whether your personal data are being processed and for what purposes they are being processed, the categories of personal data being processed, the recipients of your personal data, the processing time, any automatic decision-making effected, and your rights concerning processing.

  • Right to rectification:

If you consider that your personal data being processed are inaccurate, you have the right to request that Geotrading rectify them, as well as to request that your incomplete data be completed.

  • Right to erasure:

As a subject whose personal data are processed by Geotrading, you have the right to request the Controller to erase them in the following cases:

  1. a) the personal data are no longer necessary in relation to the purposes for which they have been collected or otherwise processed;
  2. b) you withdraw the consent on which the processing of your personal data is based;
  3. c) your personal data have been unlawfully processed;
  4. d) you have objected to the processing of your personal data and there are no overriding legitimate grounds for processing;
  5. e) personal data must be erased in order to comply with the law of the European Union or the Republic of Bulgaria.
  • Right to restriction of processing:

Another right of yours related to Geotrading processing your personal data is to request, insofar as the legal requirements have been met, that Geotrading restrict the processing of your personal data in the following cases:

  1. a) you dispute the accuracy of the personal data – for a period enabling Geotrading to verify the accuracy of your personal data;
  2. b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
  3. c) Geotrading no longer needs your personal data for the purposes of processing, but you require the restriction of their processing for the purposes of establishing, exercising or defending legal claims.
  • Right to object to processing:

Insofar as your personal data is subject to processing by Geotrading, you have the right to object at any time to such processing. In this case, Geotrading shall suspend the processing of your personal data unless there is any other legal basis for further processing such as compliance with legal requirements or other legitimate interests that require further processing.

  • Right to withdraw your consent:

The processing of your personal data by Geotrading ,where based on your explicit consent, may be terminated by withdrawal of your consent. This right of yours has immediate effect without prejudice to the lawfulness of any processing based on consent before its withdrawal.

  • Right to data portability:

You have the right to receive a copy of the personal data you have provided to Geotrading, including, where possible, in electronic form. Where the processing of your data is based on consent or a contractual obligation and is carried out by automated means, you may request Geotrading to collect your personal data in a structured, commonly used and machine-readable format. In this regard, you may also request Geotrading to transmit these data directly to another controller at your direction.

  • Right to lodge a complaint with a supervisory authority:

If you consider that your personal data are processed unlawfully or your rights in relation to them have been infringed, you have the right to lodge a complaint with the competent Bulgarian supervisory authority – the Commission for Personal Data Protection (CPDP). You can contact CPDP using the following contact details:

Address: Sofia 1592, 2 Professor Tsvetan Lazarov Boulevard
Telephone: 02/91-53-518
E-mail: kzld@cpdp.bg 

  8.Changes to this Policy

Geotrading may change this Privacy Policy from time to time in order to comply with any legislative changes or practices and policies implemented by Geotrading. When making such changes, we also change the date of the last update indicated at the beginning of this Policy. In the event that we make any changes to the Policy, we will duly notify you of that, so that you can become acquainted with the current terms of processing of your personal data.