Privacy Policy

"NOVA TRADE Ltd 115144922 ("NOVA TRADE" or "We") takes its obligations under the General Data Protection Regulation (Regulation (EU) 2016/679) and the relevant Bulgarian legislation seriously and strives to comply with the highest applicable standards and established best practices in the processing of personal data. The competent lead supervisory authority with regard to the protection of personal data processed by NOVA Trade is the Personal Data Protection Commission of the Republic of Bulgaria.
Definitions
Data Controller:
The organisation or individual who determines the purposes and means of the processing of personal data.
The organisation or individual who processes personal data on behalf of the data controller.
An identified or identifiable living individual.
A breach of security resulting, for example, in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure, access, transfer, storage of personal data.
Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person means a person who can be identified, directly or indirectly, by information such as, for example, a name, an identification number, location data, one or more factors specific to the physical, physiological, genetic, economic, cultural or social identity of that natural person.
personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the sole purpose of identifying a natural person, data concerning health or data concerning the sex life or sexual orientation of a natural person.
Any operation or set of operations performed upon personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
From 25 May 2018, the General Data Protection Regulation ("GDPR") will apply in the Member States of the European Union. From this date, NOVA TRADE shall comply with the GDPR and the principles for the processing of personal data.

The six principles for processing personal data enshrined in the GDPR state that personal data should be:
  • processed lawfully, fairly and in a transparent manner in relation to individuals
  • collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes
  • appropriate, related to and limited to what is necessary in relation to the purposes for which they are processed
  • accurate and kept up to date where necessary
  • kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which the personal data are processed
  • processed in a manner which ensures an adequate level of security of personal data

The GDPR gives individuals the following rights in relation to their personal data:
  • the right to information (this right is implemented by providing clear and easily understandable privacy notices that explain how and for what purposes Doverie uses your personal data, as well as what your rights are in relation to the personal data processed)
  • the right of access to the personal data processed and to information about their processing
  • the right to rectification of personal data where it is inaccurate or incomplete
  • the right to restrict processing, subject to the conditions set out in applicable law
  • the right to erasure of personal data where Doverie has no legal basis to continue processing the data
  • the right to portability of your data between different service providers
  • the right to object to certain processing activities, such as direct marketing
  • the right not to be subject to decisions having significant influence on you taken solely by automated means

The GDPR provides six legal grounds on which personal data may be processed:
  • the data subject has given his or her informed consent to the processing of personal data for a particular purpose
  • the processing is necessary for entering into or performance of a contract with the data subject
  • the processing is necessary to comply with a legal obligation
  • the processing is necessary to protect the vital interests of the data subject or another natural person
  • the processing is necessary for the performance of a task carried out in the public interest
  • the processing is necessary for the legitimate interest of the controller or of a third party, unless that interest is overridden by the fundamental rights and freedoms of the data subject
"NOVA TRADE shall take all necessary steps to bring its activities into compliance with the European and national legislation on personal data protection and shall apply the following principles in its exercise:
  • NOVA TRADE employees are familiar with the applicable rules and trained to process personal data with the utmost care and compliance with established best practices.
  • In conducting its soft drinks and mineral water bottling business, NOVA TRADE only works with established organisations and avoids working with companies that it believes may compromise the security of individuals' personal data.
  • NOVA TRADE adopts best practices in the implementation and administration of security systems and monitors technological developments regarding possible security risks to the company's network.
  • NOVA TRADE observes the security of the computer systems and the personal data contained therein, including the possibilities of access to individual types of personal data by its employees. NOVA Trade shall only provide access to such personal data as is necessary for the performance of the employee's job.
  • NOVA TRADE maintains appropriate administrative, technical and organizational measures designed to help protect the security and privacy of employees' personal data and to protect it from accidental or unlawful destruction, accidental loss, unauthorized correction, disclosure or access, misuse and any other unlawful form of processing.
  • Access control and CCTV is isolated throughout the enterprise; Premises where personal data is processed and stored are restricted to employees processing that data;
  • To fulfill its obligations to protect the personal data of its employees, NOVA Trade has provided secure servers located on the company's territory, which can be accessed only by the Information Technology Department - Head and Specialist.

Personal data relates to both facts and opinions/assessments expressed about an individual. The personal data that NOVA Trade processes can be conventionally divided into four categories:
  • NOVA Trade staff and associates, job applicants and former employees;
  • individuals who are clients of NOVA TRADE under contracts for the purchase and sale of finished products, cars, etc;
  • Individuals (e.g., attorneys, auditors, other independent consultants) and agents, contact persons, employees of clients, partners and suppliers of goods/services with whom NOVA TRADE has or is considering entering into a contractual or de facto relationship (e.g., legal representative of clients - legal entities, transportation and freight forwarding service providers, telecommunications service providers, software and/or hardware solutions and infrastructure).

"NOVA TRADE processes personal data related to employment or civil law relationships or data of job applicants. In general, NOVA TRADE processes this data for the purpose of preparing and executing employment or other contracts, and to comply with its legal obligations as an employer. For more information, please consult the privacy notice: employees and persons under civil law relationship of NOVA TRADE via this link.
"NOVA TRADE processes data about natural persons - individual customers under purchase and sale contracts. We process the data of our customers - individuals on the basis of the necessity to perform the contract concluded with them. For more information, please read the NOTICE OF CONFIDENTIALITY when negotiating and concluding transactions of individuals with NOVA Trade via this link.
- for more information, please read the privacy notice - commercial contracts of NOVA Trade via this link.

From time to time, NOVA TRADE may share personal data of its customers or employees/representatives of its customers, partners or suppliers with government authorities, as well as with other individuals or entities - for example, software and/or hardware solution providers and/or infrastructure, based on a legal obligation or its legitimate interest as the case may be.
"NOVA TRADE does not process sensitive personal data of its customers - individuals or employees / representatives of customers, partners and suppliers.
"NOVA TRADE stores different types of personal data contained in different documents for a strictly defined period of time. The specified storage periods are always in accordance with the purposes for which the personal data are processed. These periods are regulated in NOVA Trade's Document Retention and Destruction Policy.
In case of requests for the exercise of the rights of data subjects, NOVA Trade shall communicate with the individual in a concise, transparent, understandable and easily accessible form, in clear and plain language, especially with regard to persons under 18 years of age.

When exercising the rights of data subjects, NOVA Trade has an obligation to properly identify the individual in order to prevent the risk of unauthorized access to personal data.

Information concerning the actions of NOVA Trade taken in response to a request for the exercise of rights shall be provided to the natural persons without undue delay and in any case within one month of receipt of the request. Any information in exercising the rights of data subjects shall be provided by NOVA Trade free of charge, except where requests are manifestly unfounded or excessive.

More information about your rights related to the processing of personal data by NOVA Trade can be obtained through our Policy on the rights of data subjects.
"NOVA TRADE maintains secure computer systems through which personal data is processed. Adequate controls are applied to our systems to segregate and manage data.

"NOVA Trade has strict policies and procedures applicable to its staff to minimise the risks of processing personal data.

"NOVA Trade has adopted procedures for the effective recognition, reporting and investigation of personal data breaches. In the event of a personal data breach, NOVA TRADE will take immediate action to contain the effects of the breach, as well as to inform the affected data subjects and the data protection supervisory authority.
"NOVA TRADE will promptly update, amend and supplement this Policy at any time in the future when legal requirements or other circumstances so require.

If you would like more information regarding the processing of personal data carried out by NOVA TRADE, please contact us or our Data Protection Officer using the following contact details:

In case you have any questions or complaints about this privacy notice or the ways and purposes for which we use your personal data, you can contact our Data Protection Officer at the following address. 4190, Plovdiv Municipality, Plovdiv, Municipality of the Republic of Bulgaria, 4190 Sojdeniye str. 032 277400 or by e-mail: personaldata@novatrade.bg.