GDPR Terms

Mandatory information on the rights of individuals regarding the protection of personal data (Privacy notice)

General information

A new regulation on the protection of personal data (General Data Protection Regulation), adopted by the European Union, comes into force on May 25, 2018. The regulation aims to guarantee the protection of the data of individuals from all EU member states and to unify the regulations for their processing.

As a personal data controller for the provision of printing services, KNAL Ltd. meets all the requirements of the new regulation by only collecting personal data to the extent necessary for the provision of the service, and keeping it responsibly and legally.

What is personal data?

Personal data within the meaning of Article 2, Paragraph 1 of the Personal Data Protection Act are any information relating to a natural person who is identified or can be identified directly or indirectly by an identification number or by one or more specific features.

A few examples of personal data are: names, personal identification number, address, telephone number, place of birth, passport data of the person (physical identity); marital status and family ties (family identity); professional biography (employment); health status, psychological and/or mental state, sexual orientation (medical data); racial or ethnic origin, political, religious or philosophical beliefs (social identity); property status, financial status, participation and/or ownership of shares or securities in companies (economic identity), etc.

We collect personal data solely to provide products and services that you have requested and that you use with us, both to fulfill contractual and pre-contractual obligations, and to offer the highest quality comprehensive service on the market.

Information about the Personal Data Administrator

Name "KNAL" Ltd.

UIC/BULSTAT: 207908264 / BG207908264

Headquarters and management address: Sofia, PO Box 1407, 49 Emilian Stanev St., fl. 3 apt. 12

Address for exercising the activity: Sofia, PO Box 1407, 49 Emilian Stanev St., fl. 3 apt. 12

Correspondence details: Sofia, PO Box 1407, 49 Emilian Stanev St., 3rd floor, apt. 12

Email: [email protected]

Tel: +359 888820774

Information on the competent supervisory authority

Name: Personal Data Protection Commission

Headquarters and management address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Phone:02 915 3 518

Email: [email protected] , [email protected]

Website: www.cpdp.bg

"KNAL" Ltd. carries out its activities in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data.

Grounds for collecting, processing and storing your personal data

Art. 1. (1) KNAL collects and processes your personal data in connection with the provision of printing services and the conclusion of contracts with the company on the basis of Art. 6, para. 1, Regulation (EU) 2016/679, and in particular on the basis of the following:

• Explicit consent received from you as a customer;
• Fulfillment of KNAL's obligations under a contract with you;
• To take steps at your request to enter into a contract if you are a candidate for employment with us;
  • To perform a contract or take steps to enter into one with a business partner.
• Compliance with a legal obligation that applies to KNAL;
• For the purposes of the legitimate interest of KNAL.

(2) KNAL is a personal data controller with respect to your data as a user of our services. With respect to the personal data that you process using our services, KNAL acts in its capacity as a personal data processor.

Purposes and principles for collecting, processing and storing your personal data

Art. 2. (1) KNAL collects and processes the personal data that you provide to us in connection with the use of our printing services and for concluding a contract with the company, as well as for registering for participation in our events, or by applying for a job at KNAL, including for the following purposes:

• Sending an inquiry;
• individualization of a party to the contract;
• registration of a participant in an event organized by KNAL;
• accounting purposes;
• statistical purposes;
• information security protection;
• ensuring the implementation of the contract for the provision of the relevant service;
• sending information messages, notifications about changes in the service, etc.;
• improving and personalizing the service by offering you relevant offers for products, events and other services that may be of interest to you;
• providing customer service through our call center;

• individualization of the candidate;
• making contact with the candidate and conducting communication;
• conducting candidate selection.

(2) When concluding a contract with a business partner, we collect and process personal data about the names of the legal representative of the legal entity - party to the contract, for the purposes of individualizing the party to the contract and its implementation.

(3) The contact details of the legal representative or contact officer are official information and as such are not considered personal data.

(4) When concluding a contract with a partner - an individual, we collect and process personal data for the three names, a single civil registration number and data on an identity document (number, date of issue, issuer), for the purposes of individualizing the party to the contract and its implementation.

 

(5) KNAL adheres to the following principles when processing your personal data:

• legality, good faith and transparency;
• limitation of the purposes of processing;
• relevance to the purposes of processing and minimization of the data collected;
• accuracy and timeliness of data;
• storage limitation in order to achieve the objectives;
• integrity and confidentiality of processing and ensuring an appropriate level of security of personal data.

(6) When processing and storing personal data, KNAL may process and store personal data for the purpose of protecting its following legitimate interests:

• fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.
• Providing information to the Personal Data Protection Commission in connection with obligations provided for in the legal framework for personal data protection - Personal Data Protection Act, Regulation (EU) 2016/679 of April 27, 2016, etc.;
• obligations provided for in the Accountancy Act and the Tax and Social Security Procedure Code and other related regulatory acts, in connection with the keeping of proper and lawful accounting records;
• providing information to the court and third parties within the framework of proceedings before a court, in accordance with the requirements of the procedural and substantive legal acts applicable to the proceedings;

What types of personal data does KNAL collect, process and store?

Art. 3. (1) KNAL carries out the following operations with personal data for the following purposes:

• Sending a request from a user through the website and executing a contract for the provision of printing and other services - the purpose of this operation is to submit a request, which will be processed by us and a specific offer will be prepared and sent back to the client accordingly.
• Conclusion and execution of a commercial transaction with a client or partner – the purpose of this operation is the conclusion and execution of a contract with a commercial partner or client and its administration;
• Sending information messages - the purpose of this activity is to administer the process of sending messages to customers that relate to improvements or changes in services, according to the service provision contract.
• Sending a newsletter – the purpose of this operation is to administer the process of sending newsletters to customers who have stated that they wish to receive them;
• Conclusion and performance of an employment or civil contract : In order to select job candidates, we process the personal data that has been sent to us in the form of a CV and cover letter or other documents certifying education and qualifications.
• Conclusion and execution of a commercial transaction: For the conclusion and execution of a commercial transaction with a commercial company, we process only the three names of the legal representative or the person authorized by the company, as well as for the individual contractual partner.

 

(2) KNAL processes the following categories of personal data and information for the following purposes and on the following grounds:

• Data: Your individualizing data (name and surname, email, country, telephone, address, and in some cases a unique citizen number or personal number of a foreigner)
  • Purpose for which the data is collected:1) Sending a request from a user; 2) Establishing contact with the user and sending information to him, including, if desired, for sending newsletters and advertising messages;
  • Grounds for processing your personal data – By accepting the general terms and conditions and purchasing a service, a contractual relationship is created between KNAL and you, on the basis of which we process your personal data – Art. 6, para. 1, b. (b) GDPR.
• Other data that KNAL processes – When you log in to our website or your account, KNAL collects data about the IP address used.
  • Bank account information or other banking and payment information in connection with payments made to KNAL;
  • Customer number, code or other identifier created by KNAL for customer identification;
  • Another feedback we receive from you.
  • Purpose for which the data is collected:Improving the security of the service and localization of the interface, statistical and marketing research.
  • Grounds for data processing: Processing is necessary for the performance of a contract to which the data subject is a party - Art. 6, para. 1, b. (b) of the GDPR. Until the creation of a user profile, the IP address is collected on the basis of the legitimate interests of the controller - Art. 6, para. 1, b. (f) of the GDPR;
• Your data for issuing an invoice to an individual - If you wish to be issued an invoice in your capacity as an individual, you must provide your unique civil registration number.
  • Purpose for which the data is collected:Issuing an invoice for making payments under a concluded service contract.
  • Grounds for processing your personal data – By accepting the general terms and conditions of the website, or upon concluding a written contract, a contractual relationship is created between KNAL and you, on the basis of which we process your personal data – Art. 6, para. 1, b. (b) GDPR.

(3) KNAL does not collect and process personal data that relate to the following:

• reveal racial or ethnic origin;
• reveal political, religious or philosophical beliefs, or membership in trade unions;
• genetic and biometric data, data on health or data on sex life or sexual orientation.

(4) Personal data are collected by KNAL from the persons to whom they relate.

(5) The Company does not perform automated decision-making with data.

Period of storage of your personal data

Art. 4. (1) KNAL terminates the use of your personal data for the purposes related to the contractual relationship, after termination of the contract or after the expiration of its term, but we do not delete them before the expiration of one year from the termination of the contract or the expiration of its term or until the final settlement of all financial obligations and the expiration of the legally defined obligations for storing the data, such as obligations under the Electronic Communications Act for storing and providing information for the purposes of detecting and investigating crimes, obligations (6 months) under the Accountancy Act for storing and processing accounting data (11 years), expiration of the limitation periods for filing claims specified in the Obligations and Contracts Act (5 years), obligations to provide information to the court, competent state authorities, etc. grounds provided for in the current legislation (5 years).

(2) KNAL stores your personal data as a job candidate for a period not longer than the existence of a current job advertisement, published on our website or elsewhere. After the expiry of the advertisement period or the completion of the selection, KNAL takes the necessary care to delete and destroy all your data without undue delay or to anonymize them (i.e. to bring them into a form that does not reveal your identity), unless you give your explicit consent for your data to continue to be stored and processed in the future.

(3) KNAL stores the personal data of the legal representatives of the legal entities - parties to the contract or the natural persons - partners under a contract with the company indefinitely, for the purposes of protecting the legitimate interest of KNAL and fulfilling its legal obligations to state bodies and institutions.

 

Transfer of your personal data for processing

Art. 5. (1) KNAL may, at its own discretion, transfer part or all of your personal data to personal data processors for the fulfillment of the processing purposes in compliance with the requirements of Regulation (EU) 2016/679.

(2) KNAL notifies you in case of intention to transfer part or all of your personal data to third countries or international organizations.

Your rights in the collection, processing and storage of your personal data

Withdrawing consent to the processing of your personal data

Art. 6. (1) If you do not wish all or part of your personal data to continue to be processed by KNAL for specific or all processing purposes, you may withdraw your consent to processing at any time by contacting us via a free text request.

(2) KNAL may request that you verify your identity and identity with the person to whom the data relates.

Right of access

Art. 7. (1) You have the right to request and receive from KNAL confirmation whether personal data relating to you are being processed.

(2) You have the right to access the data related to it, as well as the information relating to the collection, processing and storage of your personal data.

(3) KNAL provides you, upon request, with a copy of the processed personal data relating to you, in electronic or other appropriate form.

(4) Providing access to the data is free of charge, but KNAL reserves the right to impose an administrative fee in case of repetitive or excessive requests.

Right to correction or completion

Art. 8. You may correct or complete inaccurate or incomplete personal data relating to you directly through your profile on the website or by submitting a request to the National Agency for the Protection of Personal Data.

Right to erasure ("to be forgotten")

Art. 9.(1) You have the right to request from KNAL the deletion of personal data relating to you, and KNAL has the obligation to delete them without undue delay where any of the following grounds apply:

• the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
• You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
• You object to the processing of personal data relating to you, including for direct marketing purposes, and there are no overriding legal grounds for the processing;
• the personal data has been processed unlawfully;
• the personal data must be erased for compliance with a legal obligation under EU law or the law of a Member State to which the CNAP is subject;
• the personal data were collected in connection with the provision of information society services.

(2) KNAL is not obliged to delete personal data if it stores and processes them:

• for exercising the right to freedom of expression and the right to information;
• for compliance with a legal obligation which requires processing provided for in EU law or Member State law to which the Administrator is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in him/her;
• for reasons of public interest in the field of public health;
• for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes;
• for the establishment, exercise or defense of legal claims.

(3) To exercise your right to be "forgotten", you must submit a written request to KNAL, as well as verify your identity and identity with the person to whom the data relates to KNAL, by presenting your ID card on site for identification purposes. (4) KNAL does not delete data that it has a legal obligation to store, including for protection in connection with legal claims made against it or to prove its rights.

Right to restriction

Art. 10. You have the right to request from KNAL to restrict the processing of data relating to you when:

• you contest the accuracy of the personal data, for a period that allows KNAL to verify the accuracy of the personal data;
• the processing is unlawful, but you do not want your personal data to be deleted, but only to have their use restricted;
• KNAL no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of your legal claims;
• You have objected to the processing pending verification of whether the legitimate grounds of the CPA override your interests.

Right to portability

Art. 11. (1) You may at any time download the data that is stored and processed for you in connection with the use of the services of KNAL, by request by email.

(2) You may request KNAL to directly transfer your personal data to a controller designated by you, when this is technically feasible.

Right to receive information

Art. 12. You may request the CNAP to inform you of all recipients to whom the personal data for which rectification, erasure or restriction of processing has been requested have been disclosed. The CNAP may refuse to provide this information if this would be impossible or would involve a disproportionate effort.

Right to object

Art. 13. You may object at any time to the processing of personal data by KNAL that relates to you, including if they are processed for the purposes of profiling or direct marketing.

Your rights in the event of a breach of your personal data security

Art. 14. (1) If KNAL establishes a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, we will notify you without undue delay of the breach, as well as of the measures that have been taken or are to be taken.

(2) KNAL is not obliged to notify you if:

• has taken appropriate technical and organizational measures to protect the data affected by the security breach;
• has subsequently taken measures to ensure that the breach will not result in a high risk to your rights;
• notification would require disproportionate effort.

Persons to whom your personal data is provided

Art. 15. (1) Persons processing data on behalf of KNAL:

• companies collecting and/or securing receivables – debt collection agencies, credit agencies that, through a surety or other means, service and collect receivables;
• Postal operators and courier service companies, with a view to sending parcels and the need to verify identity when delivering them;
• KNAL agents, who act as representatives of the company in the sale of services and products;
• persons who, by assignment, maintain equipment, software and hardware used for processing personal data and necessary for the normal functioning of the company's business and for performing various services for reporting, payment of services and products, technical support, etc.;
• authorities, institutions and persons to whom we are obliged to provide personal data under current legislation;
• banks for servicing payments made by you;

(2) Persons processing data on their own behalf

• assignees – a party to assignment agreements by which Mtel transfers (sells) your outstanding obligations;
• competent authorities which, by virtue of a regulatory act, have the authority to require the provision of information, including personal data, such as courts, prosecutor's offices, various regulatory authorities such as the Consumer Protection Commission, the Communications Regulation Commission, the Personal Data Protection Commission, authorities with powers to protect national security and public order;

Art. 16. The Administrator does not transfer your data to third countries.

Other provisions

Art. 17. In case of violation of your rights under the above or applicable personal data protection legislation, you have the right to file a complaint with the Personal Data Protection Commission as follows:

Name: Personal Data Protection Commission

Headquarters and management address: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Correspondence details: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Phone:02 915 3 518

Email: [email protected] , [email protected]

Website: www.cpdp.bg

Art. 18. You can exercise all your rights regarding the protection of your personal data through the forms attached to this information. Of course, these forms are not mandatory and you can make your requests in any form that contains a statement to this effect and identifies you as the data owner.

Art. 19. If the consent concerns a transfer, the Administrator shall describe the possible risks of the transfer of data to third countries in the absence of an adequate protection solution and appropriate remedies.

Art. 20(1). When you assign KNAL to process personal data of a third party for the purposes of using the service, KNAL acts as a processor of the personal data.

(2). In the cases under para. 1, KNAL acts solely on your instructions as a user of the service and only to the extent that it may have control over the personal data that you process. KNAL has no control over the content and data that you as a user of the service choose to upload to the service (including whether or not such data includes personal data). In this case, KNAL has no role in the decision-making process as to whether the user uses the service to process personal data, for what purposes and whether the same are protected. Accordingly, KNAL's liability in this case is limited to 1) compliance with the instructions of the user of the service in accordance with the contract and the general terms and conditions and 2) provision of information about the service.

 

Cookie Policy

The KNAL website uses cookies, which are essential for its proper functioning. By visiting our website, you accept the use of cookies.

Grounds for collecting, processing and storing your personal data

Types of cookies we use:

• Necessary cookies

These cookies are necessary for the website to function properly. For example, these cookies allow us to display information on our website in the correct language.

• Analytical cookies

Thanks to these cookies, we monitor the traffic on our website and can analyze how easily our users work with it (Google Analytics cookies). These cookies do not give us any information about your personal data. They show us which pages of our website you have viewed, whether you visited our website via a mobile or desktop device and other anonymous data. For Google Analytics, we also use anonymization of IP addresses using _anonymizelp. The maximum period for which we keep analytical data in Google Analytics is 50 months.

• Functional cookies

These cookies allow you to use the full functionality of our site, watch the videos on it, and more.

• Cookies for precise targeting

These cookies contain information about how you have used our site and may be set by our advertising partners. They do not store any personal information. Thanks to them, you will not be shown information that is not relevant to you. These are dynamic cookies from Facebook, Google, Adform, Adwise, etc.

You can adjust the settings for the cookies you receive from our site in the browser you use. Please note that if you restrict some types of cookies, our site may not work properly and you may not be able to use its full functionality.

 

What security measures have we taken at KNAL regarding the security of the personal data you store on our infrastructure?

The security of any type of information, including personal data, residing on our infrastructure is a priority for us as a company. Security is something we cannot afford to compromise on.
In addition to making every effort to fully comply with the new data protection regulation, our website and email server structure are protected by our hosting and internet providers. For maximum security in the processing, transmission and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, keeping records (log files) of data processing activities in automated processing systems, etc. KNAL regularly conducts training for its employees on personal data protection measures.
 

In order to implement the most up-to-date protection measures and to comply with applicable law, we will regularly update this Privacy Policy. If the changes we make are material, we may post a notice of the changes on our website. We encourage you to regularly review the current version of this Privacy Policy to be constantly informed about how we protect the personal data we collect.

This Privacy Policy was last updated on 23.05.2018.