Art. 2. (1) The right to privacy of personal data is a top priority of DISCORDIA. DISCORDIA strictly complies with the applicable provisions of national and European legislation regarding the protection and secure storage of the personal data of employees, contractors, and partners, as well as of individuals who have provided their personal data via the communication forms on the website with the address https://discordia.eu/ (hereinafter referred to as the “WEBSITE”).
(2) DISCORDIA complies with the basic principles established as mandatory in the processing of personal data: lawfulness, fairness and transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality, accountability.
Art. 3. The following terms used in the policy shall have the meanings as defined in the GDPR.
WHO PROCESSES YOUR PERSONAL DATA
Art. 4. The administrator of personal data is DISCORDIA AD, UIC 117015342, with registered head office and address: 1528 Sofia, 7, Iskarsko Shousse Blvd., TCE, Building 1, Floor 3
CONTACT DETAILS OF THE ADMIISTRATOR
Art. 5. The administrator has the following contact details:
Address: 1528 Sofia, 7, Iskarsko Shousse Blvd., TCE, Building 1, Floor 3
E-mail address: firstname.lastname@example.org;
Phone: +359 2 447 58 11
WHEN WE PROCESS PERSONAL DATA
Art. 6. DISCORDIA does not collect personal data on purpose and without restriction. DISCORDIA collects only those personal data that are necessary for the performance of the relevant lawful activities of the company. The activities related to the use of the WEBSITE, where personal data is processed, are related to the forms of communication on the WEBSITE as set out below.
INDIVIDUALS WHOSE PERSONAL DATA WE PROCESS
Art. 7. Through the WEBSITE, DISCORDIA processes personal data of the following categories of users:
- Registered users of the WEBSITE;
- Individuals who have provided their personal data through the Transport and Logistics Services Inquiry Form on the WEBSITE;
- Job applicants who have provided their personal data via the Job Application Form on the WEBSITE;
- Individuals who have provided their personal data via the General Contact Form on the WEBSITE.
CATEGORIES OF PERSONAL DATA WE PROCESS
Article 8. (1) In carrying out the activities related to the WEBSITE, DISCORDIA processes personal data provided directly by data subjects. In this sense, the data subjects themselves determine the amount of personal data to provide for the various purposes. DISCORDIA only stores the personal data that is necessary for the purposes of the processing, such as:
When registering on the SITE or using the communication forms on the SITE listed above, DISCORDIA only processes ordinary personal data such as names, email address and telephone number;
DISCORDIA also processes the personal data contained in the CVs of persons who have used the Job Application Form on the WEBSITE, e.g. data on education, marital status, place of residence, place of work, insurance history, etc.
PURPOSES OF PROCESSING
Art. 9. DISCORDIA processes personal data only for specific and legitimate purposes and does not further process them in a manner incompatible with the stated purposes. DISCORDIA processes personal data received through the WEBSITE for the following purposes:
Recruitment of employees under an employment relationship;
Provision of information about the company’s services, in the event of an inquiry;
Contacting persons who have expressed an interest in DISCORDIA’s services, with a view to the company’s commercial activities;
Contacting potential contractors or users through the communication forms on the WEBSITE, including when requesting consent to receive communications from the WEBSITE.
LEGAL GROUNDS FOR PROCESSING
Art. 10. In the activities related to the WEBSITE, DISCORDIA processes personal data of users on the basis of Article 6(1)(b) and (f) of the GDPR, namely:
(b) the processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the inquiry of the data subject before entering into a contract /for example, in the case of a inquiry for a transport service sent via the SITE/;
- f) the processing is necessary for the purposes of the legitimate interests of the administrator or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, in particular where the data subject is a child (for example – to manage enquiries received via the communication forms on the WEBSITE and to manage job applications received via the WEBSITE).
TO WHOM WE MAY TRANSFER OR DISCLOSE PERSONAL DATA
Art. 11. (1) In the performance of activities related to the WEBSITE, DISCORDIA may transmit or disclose personal data only to competent state authorities which, by virtue of a legal act, have the authority to require DISCORDIA to provide information, including personal data – court, investigative authorities (police, investigative, prosecutorial authorities), SANS, supervisory/regulatory authorities;
(2) DISCORDIA does not transfer personal data to other countries, including non-EU countries.
DATA STORAGE PERIOD
Art. 12. The duration of storage of personal data collected through the WEBSITE depends on the purposes of the processing for which they were collected. In any case, personal data shall be kept for a period no longer than the period provided for in the relevant legal act. The following retention periods are set for personal data collected through the WEBSITE:
12.1 Personal data provided via the Job Application Form on the SITE are stored for a period of up to 6 (six) months in accordance with Art. 25k, para. (6) (1) of the PDPA, unless the applicant has given his/her express written consent to storage for a longer period;
12.2 Personal data provided via the Transport-Logistics Services Request Form on the WEBSITE are stored until the communication with the person concerned is discontinued, unless the parties take action to conclude a contract;
12.3 Personal data provided via the General Contact Form for enquiries on the WEBSITE are stored for the period from the receipt of the enquiry, request or question until the purpose of processing is achieved and/or the legal basis for processing the personal data concerned ceases to exist;
12.4 Personal data of users registered on the WEBSITE is stored until the registration is terminated;
PERSONAL DATA SECURITY
Art. 13. DISCORDIA implements all appropriate technical and organizational measures to ensure the security of personal data, including minimizing the amount of personal data processed necessary to achieve the relevant purposes; promptly restoring the availability of and access to personal data in the event of a physical or technical incident; making employees explicitly liable for confidentiality; and other measures. In addition, the WEBSITE uses SSL SwissSign certificates, which provide effective encryption of users’ data during transmission to the WEBSITE’s web server, identification of the provider – DISCORDIA, and also authenticate the WEBSITE to protect it from phishing.
RIGHTS OF DATA SUBJECTS
Art. 14. Any usew whose data is processed by DISCORDIA has the following rights:
- the right to access his/hers personal data, including to obtain a copy thereof;
- the right to rectification or completion of inaccurate or incomplete personal data;
- the right to erasure of personal data which are processed without a legal basis;
- the right to restriction of processing – in the event of a legal dispute between DISCORDIA and the person – pending its resolution or for the establishment, exercise or defense of legal claims;
- the right to object – at any time and on grounds relating to the particular situation of the data subject, provided that there are no compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or legal process;
- the right to data portability – only if the personal data are processed automatically on the basis of consent or contract;
- the right not to be subject to a wholly automated decision involving profiling which produces legal effects concerning the data subject or significantly affects him or her.
In accordance with the GDPR and the PDPA, the above rights may be exercised by submitting a written request electronically. The application shall be made in person by the data subject or by a person authorized by him. DISCORDIA shall act on the data subject’s request within 30 days of its submission.
DATA SUBJECTS’ RIGHTS PROTECTION
Art. 15. In accordance with the Personal Data Protection Act and Regulation (EU) 2016/679, any individual who considers that his or her right to the protection of personal data has been violated may file a complaint with the Commission for Personal Data Protection at. 1592 Sofia Blvd. “1595, Proff. www.cpdp.bg.