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PRIVACY POLICY OF “VETPROM” JSC

Who is responsible for the processing of your personal data?

An administrator of your personal data within the meaning of Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”) is Vetprom JSC (hereinafter referred to as “Vetprom”), UIC 823073378.

What your personal data do we process?

Through our web site and/or online applications we process the following personal data about you:

  • Name: First name, father’s name and surname;
  • Contacts:  Electronic mail, address and telephone;
  • IP address

 

Why do we process your personal data?

The processing of your data is necessary for the provision of services by us under a contractual relationship, legitimate interest or expressly agreed by you.

For what purposes will we use your data?

The personal data you provide us will be used for administering the service, including but not limited to:

  • Registration and usage of Vetprom web sites;
  • Provision of services;

Profiling

Your personal data will NOT be subject to profiling through information processing systems.

With whom can we share your personal information?

Vetprom respects and protects the privacy of your personal information. Subject to legal requirements, Vetprom may disclose your personal data to the following persons:

  • Service Providers: For technical support of information systems and operational support for our operations, Vetprom may disclose personal data. Such disclosure only occurs when there is good reason to do so and, on the basis of a written agreement, the recipients provide an adequate level of protection.

For what period do we store your personal data?

Vetprom stores your personal data that it administers for providing the serviceuntil the user decides to terminate the registration.

If consent is withdrawn, personal data will be deleted from the Vetprom systems within 1 month. The one-month period begins to run from the date of identification of the person who has withdrawn consent to approved channels of communication with Vetprom.

Your rights with respect to your personal data

Subject to Bulgarian law, you have the following rights to your personal data processed by Vetprom:

    1. access your personal data that Vetprom processes and get a copy thereof;
    2. in the case of incompleteness or inaccuracies in the data that Vetprom processes, your personal data will be corrected;
    3. request that your data be deleted when the conditions are met. Such cases are if the target for which the data is collected is achieved; you have withdrawn your consent when the processing is based on consent and there is no other legal basis for processing; your data is being processed unlawfully, and others;
    4. In the cases specified by the law, require the processing of your personal data to be limited;
    5. In cases where your data is processed on the basis of a legitimate interest (listed above in this notice), you may object to the processing of your personal data on this basis;
    6. Exercise your data portability rights and request that your data be provided in a structured, widely used and machine-readable format;
    7. withdraw your consent when the processing of your personal data is based on consent.

    Detailed information about the terms and conditions under which you can exercise your rights can be found in the Vetprom Privacy Policy on our website www.vetprom.bg.

    You also have the right to file a complaint with the Personal Data Protection Commission when the relevant prerequisites are in place.

How to contact us?

You can contact the following address: Bulgaria, Radomir 2400, 26, Otets Paisiy str.: gdpr@vpharma.bg, contact person: Veselina Ognianova Kuylekova, phone: +35977782493

Cookies Policy of Vetprom JSC

We use cookies or similar instruments on our sites and systems to improve their presentation and your experience. This policy explains how we do this.

What are cookies like?

HTTP cookie, usually called simply “cookies” is a package of information sent by a web server to Internet browser, for instance Internet Explorer, Microsoft Edge, Safari, Opera, Mozilla Firefox, Google Chrome and so on, and after that returned by the browser each time when it has access to this server. A certain cookie remains in your device for use at a next session, when it may be erased in the meantime. In event that you use more than one browser, each of them has separate space for storage of cookies. The cookies do not refer to a certain person but to a combination of a device and an Internet browser. Therefore, a person who uses several browsers and/or devices has a separate set of cookies for each combination of a device and a browser. On the other hand the cookies do not make a difference amongst a multitude of users sharing the same device and a browser, unless they have different user’s profiles.

Cookies perform a multitude of various functions. For instance, they help us to remember your user name or preferences and to analyze how well our sites present themselves.

 

What data do we collect?

 

We collect information about the following objectives: elimination of problems, administration of our web sites and systems, analysis of tendencies, collection of demographic information, observation of the applicable law and realization of cooperation in the activities of the law enforcement authorities. We may also share this information with our authorized third parties – providers of services and advertisers, aimed at determining the overall efficiency of our online advertising, contents and programming.

 

Other devices for tracing down

 

We may use other standard technologies as tags of pixels (Facebook) and other Internet markings (“web beacons”), to trace down how you use our web sites and promotions or we may allow third parties – providers of services to use these devices on our behalf. The tags of pixels and other Internet markings (“web beacons”) are small graphic images located in individual parts of our Web sites or in our e-mails and let us find out whether you have performed a certain action. When you receive access to these sites or open or click over an e-mail, the tags of pixels or other Internet markings (“web beacons”) send a notification (which does not contain personal data) about this action. The tags of pixels allow us to understand the users, to calculate and segment the user’s traffic, to measure conversions on our Web sites as well as to retarget (remarket) advertisements. We may also use tags of pixels and other Internet markings (“web beacons”), which our Shareholders or Marketing partners present to us for the same purposes.

 

Does anyone else use cookies on our site?

 

When you visit our Web sites, we and/or our authorized Third Parties – Providers of Services and Advertisers may automatically collect such information through the use of electronic instruments as Cookies and other Internet markings (“web beacons”) or indication (“tagging”) of pixels.

We use or let third parties use cookies on our sites. We use Google Analytics and similar systems to observe the traffic on our sites and software platforms.

We may use cookies of third parties which could help us in the research of the market, exercise of monitoring over the revenues, improvement of the functionality and keeping a watch over the observation of our rules.

How you could disable Cookies?

All the modern browsers let you change the settings for cookies. You may usually find these settings in menu “options” or “preferences” on your browser. To allow you to be clear about these settings, the following links may help you or you may use the button “Help” from the menus on your browser for more details:

Cookie settings in Internet Explorer

Cookie settings in Firefox

Cookie settings in Chrome

Cookie settings in Safari web and iOS.

If you are most concerned about third-party ad cookies generated by advertisers, you can disable them from here: Your Online Choices site.

Please, have in mind that if you decide to stop the cookies, some sections of our sites and/or software platforms may not work appropriately.

Does Vetprom JSC use cookies which contain my personal data?

No, the cookies we use are anonymous and do not contain any personal information.

 

More information

If you have any questions with regard to this Cookies Policy, contact us on e-mail: gdpr@vpharma.bg

Rules for Exercise of Rights of Data Subjects

These Terms and Conditions (“Rules”) define the terms and conditions under which natural persons whose personal data are processed by Vetprom JSC, UIC 823073378 (“Vetprom”, “the Company”) may exercise their rights under the law protecting the personal data.

These Rules (“Rules“) shall regulate the conditions and the procedure in accordance with which the natural persons whose personal data are processed by Vetprom JSC, (Unified Identification Code UIC 823073378) , (“Vetprom the “Company“), may exercise their rights in conformity with the legislation for personal data protection.

Part 1: General Principles

1.1. Vetprom processes and protects the personal data collected at the implementation of the activities of the Company, honestly, in conformity with the law and in accordance with the objectives, which the data are collected for.

1.2. The employees who as a part of their labor obligations process personal data for the purposes of the production and sale of medicinal products or servicing customers – natural persons, as well as the employees who process personal data related to the human resources, counteragents and natural persons – shareholders of Vetprom, shall observe the following principles at the processing of personal data:

  1. i) The personal data shall be processed in conformity with the law and bona fide.
  2. ii) The personal data shall be collected for specific, exactly determined and in conformity with the law objectives and shall not be processed additionally in a manner incompatible with these purposes.

iii) The personal data, which are collected and processed at the management of the human resources are commensurate, related to and not exceeding the objectives they are processed for.

  1. iv) The personal data are accurate and they shall be updated in events of need.
  2. v) The personal data shall be erased or rectified when it is established that they are inaccurate or disproportionate with regard to the purposes they are processed for.
  3. vi) The personal data shall be maintained in a kind which shall allow the identification of the relevant natural persons for a period not longer than the needed for the purposes these data were collected for.

1.3. The employees, who process personal data, pass through initial and periodic training for confidentiality of the data and get acquainted with the applicable legislation.

Part 2: Definitions

The definitions enumerated herein below shall have the following meaning:

”Personal data“means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual;

“Applicable legislation“means the legislation of the European Union and of the Republic of Bulgaria which is relevant for the personal data protection;

”Profiling“ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements;

“Data subject“ means a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that  individual;

”Regulation (EU) 2016/679“means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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), promulgated in the Official Journal of the European Union on 4 May 2016.

Part 3: Rights of personal data subjects

The data subjects shall have the following rights with regard to their personal data:

  1. i) Right of access;
  2. ii) Right to correction;

iii) Right to data portability;

  1. iv) Right to erasure (right “to be forgotten“);
  2. v)  Right to request restriction of processing;
  3. vi)  Right to object to personal data processing;

vii) Right of the personal data subject not to be subject to a decision based solely on automated processing, whether profiling is included or not.

Right of access

2.1. At request, Vetprom shall present the following information to the personal data subject:

  1. i) Information whether Vetprom processes or does not process the personal data of the subject;
  2. ii) A copy of the personal data of the subject which are processed by Vetprom, and

iii) Explanation about the data processed

2.2. The explanation pursuant to Art. 2.1. (iii) shall include the following information about the personal data processed by Vetprom:

  1. i) the purposes of the processing;
  2. ii) the categories of personal data concerned;

iii) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;

  1. iv) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  2. v) the existence of the right to request from the controller correction or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  3. vi) the right to complain to a supervisory authority;

vii) where the personal data are not collected from the data subject, any available information as to their source;

viii) the existence of automated decision-making, including profiling or not, and information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

  1. ix) Where personal data are transferred to a third country or to an international organization, the data subject shall have the right to be informed of the appropriate warranties related to the transfer.

The explanation about the processed data contains the information which Vetprom presents to the data subjects through privacy notifications.

At request by the personal data subject, Vetprom may present a copy of the personal data, which are being processed.

At the provision of a copy of personal data, Vetprom shall not disclose the following categories of data:

  1. i) Personal data of third persons unless the same have expressed their explicit consent for the purpose;
  2. ii) Data which constitute trade secrecy, intellectual property or confidential information;

iii) Other information which is protected in conformity with the applicable legislation

The provision of access of personal data subject may not exert adverse impact over the rights and freedoms of third persons or result in breach of a legislative obligation of Vetprom.

4.1. Where requests for access are manifestly unfounded or excessive, particularly because of their repeatability, Vetprom may charge a reasonable fee based on the administrative costs of providing the information or refuse to respond to the request for access.

4.2. Vetprom assesses on a case-by-case basis whether a request is manifestly unfounded or excessive.

4.3. When refusing access to personal data, Vetprom argues his refusal and informs the data subject of his right to file a complaint with the Personal Data Protection Commission (CPDP).

Right of correction

4.1. Data subjects may request that their personal data processed by Vetprom should be corrected in event that the latter are inaccurate or incomplete.

4.2. With a satisfied request for correction of personal data, Vetprom shall notify the other recipients, whom the data were disclosed to (for instance state authorities, providers of services), so that they may reflect the alterations.

Right to erasure (right “to be forgotten“)

  • At request, Vetprom shall be obligated to erase personal data, if any of the following grounds are available at hand:
  1. i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  2. ii) the data subject withdraws consent on which the processing is based and there is no other legal ground for the processing;

iii) the data subject objects to the processing and there are no overriding legitimate grounds for the processing

  1. iv) the data subject objects to the processing of personal data for the purposes of the direct marketing;
  2. v) the personal data have been unlawfully processed;
  3. vi) the personal data have to be erased for compliance with a legal obligation of Vetprom;

vii) the personal data have been collected in relation to the offer of information society services referred to in Article 8, Paragraph 1 of Regulation (EU) 2016/679

Vetprom shall not be obligated to erase the personal data, in so far as the processing is needed:

  1. i) For exercising the right of freedom of expression and information;
  2. ii) For observation of a legal obligation of Vetprom;

iii) For reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9, Paragraph 2 as well as Article 9, Paragraph 3 of Regulation (EU) 2016/679;

  1. iv) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89, Paragraph 1 of Regulation (EU) 2016/679 in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  2. v) for the establishment, exercise or defense of legal claims.

Right of restriction of the processing

  • The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
  1. i) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  2. ii) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

iii) Vetprom no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;

  1. iv) the data subject has objected to processing on the grounds of the legitimate interest of Vetprom pending the verification whether the legitimate grounds of the controller override those of the data subject.

Right of restriction of the processing

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

  1. i) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
  2. ii) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

iii) Vetprom no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims;

  1. iv) the data subject has objected to processing on the grounds of the legitimate interest of Vetprom pending the verification whether the legitimate grounds of the controller override those of the data subject.

When a data subject who has requested restriction of processing and there are any of the grounds pursuant to Art. 7.1. hereinabove available at hand, Vetprom shall inform him before the restriction of processing is lifted.

Right to data portability

8.1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to Vetprom in a structured, commonly used and machine-readable format.

8.2. At request these data may be transmitted to another controller indicated by the data subject where this is technically feasible.

 

8.3. The data subject may exercise the right to portability in the following events:

  1. i) Where the processing is made on the grounds of the consent of the data subject;
  2. ii) Where processing is made on the grounds of a contractual obligation;

iii) The processing is carried out by automated means

8.4. The right to portability shall not adversely affect the rights and freedoms of others.

Right to object

  • The data subject shall have the right to object to the processing of his or her personal data by Vetprom, if the data are processed on the basis of one of the following grounds:
  1. i) The processing is necessary for the performance of a task carried out for reasons of public interest or at the exercise of official powers granted to the controller;
  2. ii) The processing is needed for objectives related to the legitimate interests of Vetprom or of a third party;

iii) The data processing includes profiling

  • Vetprom shall terminate the processing of the personal data, unless it proves that there are convincing legal grounds for its continuation overriding the interests, the rights and the freedoms of the data subject or for the establishment, exercise or defense of legal claims.

Right to object to personal data processing for the purposes of the direct marketing

10.1. Where personal data are processed for the purposes of the direct marketing, the data subject shall be entitled at any time to make an objection to the processing of personal data for the purpose, inclusive of with regard to profiling related to direct marketing.

10.2. Where the data subject objects to processing for the purposes of the direct marketing, the processing of personal data for these purposes shall be terminated

Right of human interference at automated decision-making

11.1. In the events when Vetprom makes automated individual decisions, whether with the help of profiling or not, which generate legal consequences for natural persons or concern them to a significant degree in a similar manner, these persons may request reconsideration of the decision with human interference as well as express their point of view.

11.2. Vetprom shall present to individual-subject to automated decision-making substantial information about the logic used as well as with regard to the significance and the anticipated consequences of this processing for the person.

 

 

Part 4: Procedure for exercise of the rights of the data subjects

12.1 The data subjects may exercise the rights in conformity with these Rules submitting a request for the exercise of the relevant right.

12.2. Requests for exercise of the rights of the data subjects may be submitted in the following manner:

  1. i) In an electronic manner at the following e-mail address: gdpr@vpharma.bg
  2. ii) At Vetprom office

iii) By mail – at the address of the Head Office of Vetprom: Bulgaria, Radomir 2400, 26 Otets Paisiy str

12.3. The request for exercise of rights related to the protection of the personal data shall contain the following information:

  1. i)    Identification of the person – name and PIN (when applicable)
  2. ii)    Feedback contacts – address, telephone, electronic mail

iii)    Request – description of the request and indication of the manner of receipt of an answer/correspondence related to the request.

12.3. Vetprom provides information about the actions undertaken in connection with a request for exercise of the rights of the subjects, within a term of one month from the receipt of the request.

12.4. In events of need this term may be extended by another two months taking into consideration the complexity and the number of the requests from a certain person. Vetprom shall notify the person about each such extension within a term of one month from the receipt of the request indicating also the reasons for the delay.

12.5. Vetprom is not obliged to answer requests in the events if the Company is not in a position to identify the data subject.

12.6. Vetprom may request the provision of additional information needed for the confirmation of the identity of the data subject when there are well-grounded apprehensions in connection with the identity of the natural person who submits such a request.

12.7. When the request was submitted by electronic means, if possible, the information shall be provided by electronic means unless the data subject requested otherwise.

12.8. These Rules shall enter into force from 25.05.2018.

Notification of privacy

Here, “VETPROM” JSC, UIC 82303378 (“VETPROM”, “We”) provides information about Your personal data that can be processed when selecting candidates for work organized by Vetprom.

This notification is intended to help you understand why and how we can use your information. The lists and examples below are illustrative, non-exhaustive and not fully representative of any candidate within Vetprom.

What your personal data do we process?

“Personal data” means any information about you, which you could be identified from, inclusive of information which may be protected in conformity with the applicable national and European legislation.

The personal data of the visitors which Vetprom usually processes are as follows:

Personal Data Specific Validation
Personal Information Name, Surname, Date of Birth, Consent expressed by you by submitting your application for the specific position
Contacts Email, physical address, telephone number
Education Education/ Qualification
Professional background Acquired professional experience, duration and abilities
Other data provided by submitting your application Recommendations from previous employers, certificates and others

Purposes which we process your personal data for

The personal data provided by you shall be used for :

  • making a selection of candidates
  • future signing of an employment contract if your application is successful.

Data submitted with a job application for a particular position will only be processed for the specific position based on your agreement demonstrated by submitting an application. Subject to your explicit consent, your application may be retained and reviewed for future positions announced by Vetprom.

With whom can we share your personal information?

Vetprom respects and keeps the confidentiality of your personal data. With observation of the legal requirements Vetprom may disclose your personal data to the following persons:

Providers of services: When we use providers of services related to technical maintenance of internal information systems and operational maintenance of our activity, it is possible that the Company should disclose personal data. Similar disclosure of data shall be made only with the availability of a well-grounded reason for the purpose and on the grounds of an agreement in writing of the recipients to provide an adequate level of protection;

For what period do we store your personal data?

Applications submitted for a specific position will be destroyed after the selection procedure has been completed. The application (s) of the successful applicant (s) with whom Vetprom has entered into a contract will be retained in the employment file for the purposes of the employment relationship and under conditions further specified by Vetprom in the Policy regarding the periods for the storage of personal data.

Applications that have been agreed to be processed for future positions will be processed for a period of 1 year following the year of application or until the withdrawal of the consent for processing if it has been withdrawn before the expiry of the one-year period.

Your rights with respect to your personal data

Subject to the Bulgarian law, you have the following rights with respect to your personal data processed by Vetprom:

  1. to access your personal data that Vetprom processes and get a copy thereof;
  2. incompleteness or inaccuracy in the data that Vetpro processing handles, to correct your personal data;
  3. request that your data to be deleted when the conditions are met. Such cases are if the target for which the data is collected is achieved; you have withdrawn your consent when the processing is based on consent and there is no other legal basis for processing; your data is being processed unlawfully, and others;
  4. in the cases specified by the law, require the processing of your personal data to be limited;
  5. in cases determined by law, to object to the processing of your personal data;
  6. exercise your data portability rights and request that your data be provided in a structured, widely used and machine-readable format;
  7. to withdraw the consent you provide when processing your personal data is based on consent.

Detailed information on the terms and conditions under which you can exercise your rights can be found in the Vetprom Privacy Policy of our www.vpharma.bg.

You also have the right to file a complaint with the Personal Data Protection Commission when the relevant prerequisites are in place.

How to contact us?

You can contact the following address: Bulgaria, Radomir 2400, 26 Otets Paisiy str., Email: gdpr@vpharma.bg, contact person: Veselina Ognianova Kuylekova, phone: +359 77782493

CONTACTS

Contact details

Radomir, 2400,St. „Otets Paisiy“ 26

Tel:+359 (777) 82493

Fax: +359 (777) 82391

Email: office@vpharma.bg

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