Privacy Policy

INFORMATION NOTICE ABOUT PROTECTION OF PERSONAL DATA

Protection of personal data is a crucial aspect for the Monbat business group, which has adopted common principles for the entire Group in this regard. On account of the entry into force of Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (“the Regulation”), this Information Notice provides you with detailed information relating to the protection of your personal data by Monbat PLC and its subsidiaries.

The purpose of this Information Notice is to advise you what personal data about you we use, the reasons we use and share such data, for how long we store the data, and how you may exercise your rights.

1. PERSONAL DATA BEING PROCESSED

We collect and process your personal data to the extent required in the framework of our operations and in order to achieve a high standard for our products and services. We may collect various types of personal data about you, including:

• identifying information (such as, name, ID card and passport number, nationality, place and date of birth, sex, photo, IР address);
• identifying information of any attorneys-in-fact;
• contact information (such as, mail address and e-mail address, phone number);
• tax status (such as, tax ID number, tax status);
• bank data (such as, bank account particulars);
• data associated with your habits and preferences:

a. data associated with your use of our products and services, as marketed on our websites;  
b. data from your interactions with us: our websites, social network profiles, emails;

• data from video surveillance implemented;
• in case you are our shareholder/bondholder, we process your personal data associated with that legal relation, such as: identification data, number of shares/bonds, dividend value and income value
  
  We never collect any personal data associated with your racial or ethnic origin, political beliefs, religious or philosophical convictions, membership in trade organizations, genetic data or data relating to your sex life or orientation, or criminal record data, unless we have a legal duty to do so. The data about you that we process may be provided directly about you or be obtained from other sources in order to verify our databases for the purpose of performance of our contractual and statutory duties, such as:
• publications/database whereto access is granted by an official authority (such as, State Gazette, the registers kept by the Registry Agency; Central Depositary, etc.);
  
• our corporate customers or service providers;
• websites/social network pages, which contain any information publicly disclosed by you.

2. GROUNDS FOR PERSONAL DATA PROCESSING

а. To perform our statutory and regulatory duties

We process your personal data in order to perform some statutory and regulatory duties – such as, to the National Revenue Agency, the Central Depositary, the Financial Supervision Commission, and the Bulgarian Stock Exchange. We may provide information at the official query of a duly authorized public or judiciary authority. On account of our capacity of a public company, if you are a person with access to inside information, within the meaning of Regulation (EU) 596/2014, your data are processed in pursuance of our statutory duties to keep a record of such persons.

b. To perform a contract entered into with you or take steps, at your request, prior to entry into contract

We use your personal data in order to enter into and perform our contracts with you, as well as in order to:

• provide you with information concerning our product and services;
• assist you and respond to your demands;
• determine whether we may offer you a given product or service and under what terms;
• perform our duties as a public company (such as, dividend distribution).

c. Materialize our legitimate interests
We use your personal data in order to deploy and develop our products or services via advertising, as well as in order to materialize and protect our legitimate rights and interests.

d. A consent provided by you
In case we carry out further processing for purposes other than those listed above, we will advise you to such effect and will obtain your consent, when required.

3. RECIPIENTS OF PERSONAL DATA

For the purpose of achievement of the above purposes, we only disclose your personal data to:

• Companies from the Monbat business group in order to be able to provide you with the entire scope of our Group products and services;
• Providers performing services on our behalf – accounting offices, couriers, IT companies, which maintain our servers, etc.;
• Judicial bodies, administrative control bodies, government agencies, and any other public authorities and organizations, upon request and up to the legally authorized extent;
• Some experts from regulated professions, such as attorneys-at-law, notaries public, or auditors, in the cases where materialization and/or protection of our legitimate rights and interests is required;
• In the case of an existing legal relation between you and Monbat PLC, in its capacity of a public company, your personal data are provided to the Central Depositary, the Financial Supervision Commission, and the Bulgarian Stock Exchange, and other entities, as authorized by law.

4. TRANSFER OF PERSONAL DATA OUTSIDE EEA

In some cases we may transfer your data to another EU or EEA country, in compliance with all requirements to the protection of such data, and upon implementation of contractual protection clauses with the receiving party. Transfer of data outside the European Economic Area may only take place when the European Commission has recognized a certain non-EEA country as one that provides an adequate level of data protection or upon application of European Commission-approved Standard Contractual Clauses ensuring personal data protection.

5. PERSONAL DATA STORAGE PERIODS

We process and store your personal data for a certain period of time, which is determined by:

• the time periods required for compliance with Bulgarian and EU law;
• any other time period as regards our operational requirements in view of the protection of our legitimate rights and interests:

а. Personal data under our contracts with customers are stored for a period of 10 years following the contractual relation’s end or for another period, as stipulated by law.

b. The accounting documentation is stored by our servicing accounting office for a period of 10 years, in pursuance of statutory requirements.

6. WHAT YOU RIGHTS ARE AND HOW YOU MAY EXERCISE THEM

Pursuant to the personal data protection legislation, you have certain rights in regards to your personal data, as follows:

• Access: you may receive information relating to the processing of your personal data, and a copy of that personal data.
• Correction: where you believe your personal data to be inaccurate or incomplete, you may request that those personal data be correspondingly correct.
• Erasure: you may request erasure of your personal data, to the extent authorized by law, unless our company is able to prove the existence of legal grounds for the processing, which prevail over the interests of the data subjects, or for the materialization, exercise, and protection of our company’s legitimate rights and interests.
• Limitation: you may request that the processing of your personal data be limited down to the extent authorized by law.
• Objection: you may object against the processing of your personal data, on grounds relating to your specific situation. You have the absolute right to object to the processing of your personal data for direct marketing purposes, which includes the profiling associated with such direct marketing.
• Withdrawal of consent: where you have given your consent for the processing of your personal data, you are entitled to withdraw it at any time.
• Data transferability: when it is legally applicable, you are entitled to a return of your personal data, which you have provided to us, or, where it is technically impossible, they may be provided to a third party.

In accordance with the above requirements, further your rights above, you may also address, on account of occurred infringements of your rights, the Commission for Personal Data Protection at: 1592 Sofia, 2, Tsvetan Lazarov Blvd., , tel.: 02/91-53-518 or to the competent court of law.

7. MISCELLANEOUS

You may read more information about our confidentiality and security policies in our Cookies Policy.

8. CONTACTS

Where questions relating to the use of your personal data pursuant to this Notice emerge, you may contact us at +359 2 962 11 50 or via the contact form.