Ulpia GmbH. is processing and protecting the personal data collected in the course of fulfillment of its activity in an honest and lawful way, always complying with the purposes for which the data are being collected.
The officers processing personal data for the purposes and with regards to the subject of activity of the trade company, for signing contracts for services and in fulfillment of the obligations thereof respect the following principles in the processing of personal data as part of their employment obligations:
The employees processing personal data are initially and periodically trained for data privacy and are kept familiar with the applicable legislation.
The terms stated below have the following meanings:
Personal data means any information relating to an identified natural person or natural person that can be identified directly or indirectly, in particular by an identifier such as name, identification number, location data, online identifier or one or more of the features specific to physical, physiological, genetic, psychic, mental, economic, cultural or social identity of that individual.
Applicable law means the legislation of the European Union and the Republic of Bulgaria which is relevant to the protection of personal data.
Data subject means a natural person who can be identified, directly or indirectly, in particular by any identifier such as name, identification number, location data, online identifier or one or more features, specific for the physical, physiological, genetic, psychic, mental, economic, cultural or social identity of that individual.
Regulation (EU) 2016/679 means Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 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 (General Data Protection Regulation), published in the Official Journal of the European Union on May 4, 2016.
The data subjects have the following rights regarding their personal data:
Upon request, Ulpia GmbH. shall provide the following information to the data subject:
The explanation on the data processed shall comprise the following information:
The data processing explanation shall contain the information that Ulpia GmbH. submits to the data subjects by means of the Privacy Notice.
Upon request of the personal data subject, Ulpia GmbH. may provide a copy of the personal data that is being processed.
When providing a copy of personal data, Ulpia GmbH. should not disclose the following data categories:
Providing access to personal data subject cannot adversely affect the rights and freedoms of third parties or lead to a breach of a regulatory obligation of Ulpia GmbH.
Where access requests are clearly unfounded or excessive, especially because they are repeated in multiple occasions, Ulpia GmbH. may charge a reasonable fee based on the administrative costs made for providing the information or to refuse to respond to the request for access.
Ulpia GmbH. shall assess on a case-by-case basis whether a claim is clearly unfounded or excessive.
Upon refusal to provide access to personal data, Ulpia GmbH. shall advance arguments for its refusal and shall notify the data subject about her/his right to file a claim with the CPDP.
Data subjects may ask their personal data processed by Ulpia GmbH. Ltd to be rectified if the latter are inaccurate or incomplete.
When a request of rectification of personal data is satisfied, Ulpia GmbH. shall notify the other recipients to whom the data have been disclosed so that they could reflect the changes.
Upon request, Ulpia GmbH. is obliged to delete personal data if one of the following reasons exists:
Ulpia GmbH is not obliged to delete the personal data as far as their processing is necessary for:
The data subject has the right to request a limitation of processing when one of the following applies:
Ulpia GmbH. may process personal data the processing of which is limited only to the following purposes:
When a data subject has asked a limitation of the processing and if any of the above reasons is available, Ulpia GmbH. Ltd shall notify her/him before the processing restriction is lifted.
The data subject is entitled to receive the personal data concerning her/him, and which she/he has provided to Ulpia GmbH. in a structured, widely used and machine readable format.
Upon request, these data may be transferred to another controller designated by the data subject when this is technically feasible.
The personal data subject may exercise the right to portability in the following cases:
The right to portability cannot adversely affect the rights and freedoms of others.
The data subject has the right to object to the processing of his or her personal data by Ulpia GmbH. if the data are processed on any of the following grounds:
Ulpia GmbH. shall terminate the processing of the personal data unless it proves that there are convincing legal grounds to continue doing it which take precedence over the interests, rights and freedoms of the data subject or to determine, exercise or defend legal claims.
When personal data are processed for the purposes of direct marketing, the data subject is entitled at any time to object to the processing of personal data for that purpose, including with regards of profiling related to direct marketing.
When the data subject opposes processing for direct marketing purposes, the processing of personal data for these purposes is terminated.
Personal data subjects may exercise the rights under this Policy by submitting a request for exercising the applicable right.
Requests to exercise the rights of data subjects may be submitted in the following way:
By e-mail to the following email address: prvacy.controller@ulpia.gmbh
The request for exercising the rights relating to the protection of personal data should contain the following information:
Ulpia GmbH. shall provide information on the actions taken in connection with an application to exercise the rights of the entities within one month from the date the application is received.
If necessary, this period may be extended further by two more months, taking into account the complexity and number of requests from a particular person. Ulpia GmbH. shall notify the person of any such extension within one month from the receipt of the request, indicating the reasons for the delay.
Ulpia GmbH. is not obliged to respond to a request if it is not able to identify the data subject.
Ulpia GmbH. may ask for the provision of additional information necessary to confirm the identity of the data subject where there are reasonable concerns about the identity of the natural person submitting the request.
Where the request is made by electronic means, the information shall, if possible, be provided by electronic means, unless the data subject has requested otherwise.
This Policy is adopted by Order of the Director of Ulpia GmbH. and shall enter into force on May 25, 2020.
With this Privacy Notice Ulpia GmbH. gives notification on how the personal data provided to him are collected, used, shared and protected.
Ulpia GmbH. is processing personal data in a lawful, conscientious and transparent way. They are collected for specific, explicitly stated and legitimate purposes and are not further processed in a way incompatible with these purposes. Personal data are appropriate and relevant, as well as limited to what is necessary in relation to the purposes for which they are processed (‘data minimization’), they are accurate and up-to-date. They are processed in a way that ensures an adequate level of security of personal data. They are kept in good faith and in accordance with the statutory deadlines.
For the purposes of this notification, “personal data” means any information relating to an identified natural person or natural person that can be identified directly or indirectly, in particular by an identifier such as name, identification number, location data, online identifier or one or more features specific to the physical, physiological, genetic, psychical, mental, economic, cultural or social identity of that individual.
Personal data collected in connection with the conclusion of another contract are kept for 5 (five) years once the calendar year in which the contract expires is over provided that there are no judicial and/or other claims. In the case of court and/or other claims, the retention period is 3 (three) years after their completion. In some cases, when the processing is legally justified and by decision of the relevant body, this type of information may be stored for up to 7 (seven) years.
The personal data collected on the above grounds are used only for the purposes stated in this privacy notice or for additional compatible purposes in line with the Law.
The personal data collected may be provided to any government authority in connection with its activity and competencies, as well as to service providers, lawyers, etc. (full list as detailed in the original document).
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