GENERAL POLICY

on

confidentiality and personal data protection

of KT INTERNATIONAL SA

 

General policy on confidentiality and personal data protection

 

The purpose of this “General policy on confidentiality and personal data protection” is to inform you of how we process your data and what personal data we are likely to collect from you, for what purpose, for what period of time and what your rights are.

 

  1. INFORMATION ABOUT US

KT INTERNATIONAL SA is a licensed manufacturter of tobacco products, which has been written into the Commercial Register of the Registry Agency under UIC: 825212392, with the following head office, registered address and address of the tax warehouse: the Republic of Bulgaria, city of Plovdiv, 1 Rogoshko shose Str.

  1. OUR ATTITUDE TOWARDS YOUR PERSONAL DATA

KT INTERNATIONAL SA is a personal data administrator and as such it collectes, processes and stores personal data.

KT INTERNATIONAL SA places great emphasis on personal data protection and collects and processes personal data only by strictly observing the requirements of the local and the European legislation.

The security of the data you have entrusted to us is extremely important for us. It plays a major role for the success of our business and for our public image as well.

We are aware of the fact that the processing of your data is related to a certain reason and cannot be performed unrestrictedly.

  1. SECURITY

KT INTERNATIONAL SA takes measures to ensure the protection of your personal data from any accidental loss and unregulated access, usage, modification or disclosure. We have policies and procedures intended to protect the information from being lost, misused and illegally disclosed. Moreover, we take additional measures to ensure information security, including access control, strict physical protection and reliable practices for collecting, storing and processing information.

  1. PRINCIPLES, OBJECTIVES AND GROUNDS

 

    1. In accordance with the basic principles observed by KT INTERNATIONAL SA, the personal data are:

  • processed lawfully, conscientiously and in a transparent manner regarding the subject of the data;

  • are collected for certain explicitly stated and legitimate purposes and are not further processed in a way that is not compatible with these purposes;

  • are appropriate, related to and restricted to the necessary minimum regarding the purposes for which they are being processed;

  • are correct and kept up-to-date; KT INTERNATIONAL SA has taken all reasonable measures to guarantee the timely deletion or correction of all incorrect personal data, taking into consideration the purpose for which they are being processed;

  • are stored in a form that allows the identification of the subject of the data, for a period no longer than the period necessary for achieving the purposes for which the personal data are being processed;

4.2. Depending on the respective objectives and grounds, KT INTERNATIONAL SA processes the data below individually or in combination:

 

  • After receiving your explicit consent. The consent is a separate reason for the processing of your personal data and the purpose of the processing has been specified in it;

  • For the implementation of a contract or in the context of precontractual relations with potential clients/partners of KT INTERNATIONAL SA;

  • For the execution of marketing activities aimed at clients/consumers of the products of KT INTERNATIONAL SA;

  • For the implementation of legal obligations;

  • For the execution of the obligations and the exercising of the special rights of KT INTERNATIONAL SA or your own rights by virtue of the labour and insurance law or the law in the sphere of social security and social protection, including the staff recruitment procedures;

  • For providing access to the tax warehouse of the company;

  • For the sake of your legitimate interest.

 

 

  1. WHAT INFORMATION DO WE COLLECT AND WHY?

 

    1. For the purpose of allowing access to the tax warehouse of KT INTERNATIONAL SA.

Your consent shall be required prior to being allowed to enter the territory of the tax warehouse of KT INTERNATIONAL SA by means of a procedure for personal data provision.

The personal data provided by you will be processed and stored by KT INTERNATIONAL SA for a limited period of time, for the purpose of defending the legitimate interests of the company and the observance of its legal obligations when control over the activity of KT INTERNATIONAL SA, in its capacity as a licensed manufacturer of tobacco products and owner of a tax warehouse, is being exercised by the state authorities and institutions, some of which are: the Customs Agency, the Ministry of the Interior, the National Revenue Agency, the National Social Security Institute and others.

 

    1. For the implementation of a contract/commercial commitment or precontractual relations

KT INTERNATIONAL SA processes the personal data of subjects that are a party under a Contract or another commercial commitment with the company, for the purpose of implementing the contract/commitment, for the purpose of identifying the physical entity with representative powers, for the purpose of conducting payment operations and also for the purpose of using the rights under the contracts signed with you.

 

KT INTERNATIONAL SA processes personal data in case of precontractual relations for the purpose of identification when making proposals for concluding contracts. If the precontractual relations do not lead to any commercial commitment, KT INTERNATIONAL SA shall delete the provided data without storing them unless it is legally obliged to do so.

 

KT INTERNATIONAL SA processes personal data of subjects that are a party under a contract or have another commercial commitment with the company on legal grounds.

In accordance with the Measures Against Money Laundering Act, KT INTERNATIONAL SA is obliged to identify the representative authorities to all its potential and/or future Clients/Partners.

 

To this end, KT INTERNATIONAL SA has prepared methods and mechanisms for collecting the necessary personal data.

 

    1. For organizing and conducting Marketing activities

 

For the purpose of organizing and conducting Marketing activities, KT INTERNATIONAL SA processes the personal data of the categories of people participating in the activity.

 

The process of giving a consent, the purposes and the method of processing are described in the Rules and Mechanisms for conducting the respective activity, which are provided in a place/platform/website accessible for the particiants for each individual case.

 

The provided personal data are usually used for some of the following purposes:

Name and surname in order to identify a winning participant.

The date of birth in order to establish that the winner has turned 18.

An address so that the prize will be sent to the winner (if there is such a prize).

 

    1. For people appointed under employment contracts at KT INTERNATIONAL SA and staff recruitment

 

KT INTERNATIONAL SA has adopted special rules regarding the processing of the personal data of the people appointed under an employment contract, in particular regarding the conditions in which the personal data, within the context of the employment contract, can be processed after receiving the consent of the employed person, for the purpose of recruiting staff, implementing the employment contract, executing obligations stipulated by a law or by means of collective agreements, the management, the planning and the organization of the work, the healthy and safe labour conditions and also for the purpose of terminating the employment contract.

 

    1. For the execution of legal obligations

 

KT INTERNATIONAL SA processes your data for the following inexhaustive list of purposes regulated in the normative acts:

 

  • Provision of information about a client, an employed person, a visitor, a participant in a marketing activity upon an inquiry/request/inspection of a competent authority;

  • Issue of invoices;

  • In order for the competent authorities to exercise tax and insurance control;

  • In order for the competent authorities to exercise control over the activity of the company in its capacity as a licensed manufacturer of tobacco products.

 

  1. WHAT DATA DO WE PROCESS?

Depending on the purposes and the grounds, KT INTERNATIONAL SA collects, processes and stores some of the following types of personal data:

Identification data:

 

  • full name,

  • nationality/citizenship;

  • Personal ID No./date of birth;

  • Personal Identity Card/Passport number;

  • date of validity of the identification document;

  • photograph;

 

Other data:

    • e-mail address, letters, information about your orders, appeals, requests, complaints;

    • another type of feedback we receive from you;

    • personal contact details – contact address, telephone number and contact information

    • video recordings on the territory of the tax warehouse

    • number of a bank account or another bank and payment information related to the payments made to KT INTERNATIONAL SA

    • diplomas, certificates, permits, medical certificates, requests and/or documents of the people employed by the company which have been received during the staff recruitment procedure.

The data provided by you in relation to inquiries sent to us via our website or sent to our contact address are stored by us solely for the purpose of replying to your questions and responding to your problems. We will delete the data kept in relation to that after the storage is no longer necessary or we will restrict the processing if there are any legal obligations for storing.

 

  1. HOW LONG DO WE STORE YOUR DATA?

 

The period of time for which we store your personal data depends of the purposes of the processing for which they have been collected.

    1. Data related to a contractual relation and/or the implementation of certain legal obligations:

As a rule, we cease using your personal data for the purposes related to the contractual relation/commercial commitment upon the termination of the contract/commitment but we do not delete them before the expiration of 5 years after the termination or the final settlement of all the financial obligations and the expiration of the statutory obligations for storing data as obligations, some of which are:

  • By virtue of the Accounting Act, for storage and processing of accounting data (10 years) and for pay ledgers – 50 years as of the 1st January of the reporting period following the reporting period to which they refer;

  • For the expiration of the validity terms for filing claims (5 years) stipulated in the Obligations and Contracts Act;

  • For the storage of your data based on the Measures Against Money Laundering Act (5 years);

You need to consider the fact that we will not delete any of your personal data if they are necessary for any pending criminal, administrative proceedings or any proceedings related to the hearing of your claim submitted to us.

    1. Data related to a visit to the tax warehouse of KT INTERNATIONAL SA:

KT INTERNATIONAL stores your data for a period of 1 year as of the date of providing access to the territory of the tax warehouse of the company.

 

Your personal data collected by means of video recording from the surveillance devices are stored in the “Video surveillance” register for a period of two months after being made. Their deletion shall be certified by the head of the security.

 

    1. Data related to marketing activities:

 

KT INTERNATIONAL SA shall store your data for a period of 1 year after the end of the activity.

    1. Data related to employment contracts and staff recruitment.

KT INTERNATIONAL SA shall store your data related to your employment record for a period of 5 years after the termination of the employment contract unless for certain documents there is a normative act stipulating a different period of storage, in which case the respective statutory term shall apply.

KT INTERNATIONAL stores your data related to staff recruitment for a period of one year as of the date of publishing/announcing the job for which you have applied.

IMPORTANT!

With reference to any obligations for providing information to the court, competent state authorities and other grounds stipulated in the active legislation and also for the purpose of defending its legitimate interests, KT INTERNATIONAL SA can store your data regardless of the purposes of their processing for which they have been collected and for a longer period of time as for each individual case KT INTERNATIONAL SA shall provide the necessary justification of the need of a longer period of storage.

 

  1. WHAT ARE THE CATEGORIES OF THIRD PARTIES GAINING ACCESS TO AND PROCESSING YOUR PERSONAL DATA?

 

    1. Other administrators and/or entities processing personal data that, on the grounds of a contract signed with KT INTERNATIONAL SA, process/store your personal data on their behalf or on behalf of KT INTERNATIONAL SA or have direct/indirect access to your personal data.

 

    1. Transport/courier companies for the purpose of implementing contractual/legal obligations for sending/delivering products/raw materials/waste originating from KT INTERNATIONAL SA or the execution of marketing activities.


 

    1. People who have been assigned by KT INTERNATIONAL SA to maintain the equipment and the software used in the company.


 

    1. The banks servicing the payments made by/to KT INTERNATIONAL SA;


 

    1. Security companies holding a licence for conducting private security activities, processing the video recordings at the tax warehouse of KT INTERNATIONAL SA and/or maintaining other registers in the process of executing checkpoint activities at the same site;

 

    1. Competent authorities/third parties that, by virtue of a normative act or a contract concluded on the grounds of a normative act, have the right to require/obtain from KT INTERNATIONAL SA the provision of information containing personal data, such as the Bulgarian Court or a court of another country, various supervisory/regulatory authorities like the Customs Agency, the Commission for Consumer Protection, the Commission for Protection of Competition, the Labour Inspectorate, the Labour Medicine Service and others.

 

  1. YOUR RIGHTS

    1. Right of information

You have the right to request information from us at any time regarding your data stored by us as well as information about their origin, recipients or categories of recipients to which they are given and the purpose of their storage.


9.2. Right of withdrawal

If you have given permission for the use of your data, you can withdraw that permission regarding the future at any time without stating any reasons for that. The only thing you have to do is send a request for withdrawal by post to the address: city of Plovdiv, 1 Rogoshko shose Str., administrative building of KT INTERNATIONAL SA, for the registry office.

KT INTERNATIONAL SA may continue to process your data after the withdrawal of your consent in case:

  • this processing is necessary for observing a statutory obligation applied towards KT INTERNATIONAL SA;

  • this processing is necessary for the sake of the legitimate interests of KT INTERNATIONAL SA,

of which you shall be informed to the contact address you have provided.


9.3. Right of correction

If your data stored by KT INTERNATIONAL are incorrect, you can ask us to correct them at any time.

 

9.4. Right of restriction of the processing

You have the right to request KT INTERNATIONAL SA to restrict the processing in case one of the following is valid:

  • you dispute the correctness of your personal data, for a period of time that will allow KT INTERNATIONAL SA to check the accuracy of your personal data;

 

  •  

  • KT INTERNATIONAL SA illegally processes your data and you do not want your data to be deleted but request a restriction of their usage instead;

 

  •  

  • KT INTERNATIONAL SA no longer needs your personal data for processing but you request them for the purpose of establishing, filing or defending legal claims;

 

  •  

  • You have objected to the processing, expecting an inspection to be conducted in order to establish whether the legal grounds of KT INTERNATIONAL SA prevail you interests.

 

9.5. Right of deletion

You have the right of deletion of the data about you that KT INTERNATIONAL SA stores. The deletion of your personal data can be done at any time by completing a form which you will receive after you contact us using the contact details below. Your data are usually deleted immediately, at the latest 30 days after you exercise this right as a subject of the data. If necessary, this term can be extended by two months, taking into account the complexity and the number of the requests. If the deletion contradicts any statutory, contractual, criminal-law or commercial-law obligations for storage or any other reasons stipulated by law, you will receive a message from us informing you about our inability to delete your data and the reasons for that.

Upon the deletion of your data, it will no longer be possible to provide information.

 

9.6. Right to transfer the data

If you request your personal data from us, we will submit or transfer the data to you or to another administrator in a structured, widely used and machine-readable format. We will perform a direct transfer of the data only if it is technically possible.

 

9.7. Right to object

You have the right to object to the processing of data at any time and without stating a reason for that.


9.8. Right to file a complaint

You have the right to file a complaint about the processing of your personal data to the competent control authotity if you think that your rights related to the protection of your personal information have been violated.

 

  1. VIOLATIONS AND INFORMATION ABOUT VIOLATIONS

10.1. “Violation of the personal data security” means violation of the security which leads to accidental or unlawful destruction, loss, modification, unauthorized disclosure or access to personal data which are given, stored or processed in any other way by KT INTERNATIONAL SA.

10.2. In case of a violation of the personal data security in which a risk may be posed to the rights and the freedom of physical entities, without any delay and when possible – no later than 72 hours after becoming aware of it, KT INTERNATIONAL SA shall inform the Commission for Personal Data Protection.

10.3. In case the violation poses a risk to the rights and freedom of the physical entities, KT INTERNATIONAL SA shall take measures to inform the people concerned in order to minimize any possible unfavourable consequences.

  1. CHANGES IN THE CURRENT POLICY ON PERSONAL DATA PROTECTION

In order to apply the latest measures for protection and observe the active legislation, we will regularly update this Policy on personal data protection.

We kindly ask you to review regularly the current version of this Policy on personal data protection and keep up-to-date on how we take care of the protection of your personal data.

 

CONTACTS:

Should you have any questions regarding the personal data protection, do not hesitate to send them to the following address in writing:

 

Bulgaria, city of Plovdiv, 1 Rogoshko shose,

administrative building of KT INTERNATIONAL SA, for the registry office.