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Protection of personal data

Mandatory information on the rights of the persons as regards data protection

(Privacy notice)

 

Information about the company that processes your data:

Name: INBIOTECH Ltd.
UIC/BULSTAT: 040293034
Headquarters and registered address: 1000 Sofia, Oborishte District, 5 Triaditsa Str., ent. A, fl. 4
Postal address: Sofia, 1504, Bulgaria 7, Sheinovo Street;
Telephone: +359 2/ 987 95 37
E-mail: office@inbiotech-bg.com
Website: www.inbiotech-bg.com
 
 

Information on the competent supervisory authority for the protection of personal data

Name: Personal Data Protection Commission
Headquarters and registered address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Postal address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Telephone: +359 2/ 915 3 518
Internet site: www.cpdp.bg
 

INBIOTECH Ltd. (hereinafter referred to as "the Controller" or "the Company") operates 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 year on the protection of individuals with regard to the processing of personal data and on the free movement of such data. This information is intended to inform you about all aspects of the processing of your personal data by the Company and the rights you have related to such processing.

Grounds for collecting, processing and storing your personal data

Art. 1. INBIOTECH Ltd. collects and processes Your personal data in relation to the use of the website https://inbiotech-bg.com, processing inquiries sent through the form of the website, Your application for employment with us and concluding contracts with partners of the company on the grounds of Art. 6, para. 1 and Art. 9, para. 2, Regulation (EU) 2016/679 (GDPR), and in particular on the following grounds:

  • Your explicit consent has been obtained;
  • Fulfillment of the obligations of the Controller under contract with You or taking steps to conclude one;
  • Compliance with a legal obligation that applies to the Controller;
  • For the purposes of the legitimate interests of the Controller or a third party.
     

Purpose and principles in the collection, processing and storage of your personal data

Art. 2. (1) We collect and process the personal data You provide to us in relation to the use of the https://inbiotech-bg.com website, the processing of requests sent via the website form, Your application for employment with us and the conclusion of contracts with company partners, including for the following purposes:

  • individualization of a party to the contract;
  • accounting purposes;
  • statistical purposes;
  • protection of information security;
  • sending a response to a query;
  • selection of job applicants;
  • use of the company website;
  • certification of the quality of the person requesting access to certain information.
     

 (2) We respect the following principles in the processing of Your personal information:

  • lawfulness, fairness and transparency;
  • purpose limitation;
  • adequacy to the purposes of processing and minimizing the data collected;
  • data accuracy and up to date;
  • storage limitation in order to achieve the purposes;
  • integrity and confidentiality of the processing and guaranteeing an appropriate level of personal data security.

(3) In the processing and storage of personal data, the Controller may process and store personal data for the purpose of protecting his or her legitimate interests, including for the performance of his / her duties to public authorities.

What type of personal data is collected, processed and stored by our company

Art. 3. The Company performs the following operations with the personal data You provide for the following purposes:

  • Signing and executing a contract with a partner - the purpose of this operation is to conclude and execute a contract with a partner and for its administration. In some cases, the purpose of the operation may also be to protect the legitimate interests of the contracting company. Given the limited scope of personal data collected and the fact that some of it is collected from publicly available sources, an impact assessment is not necessary for this operation.
  • Conclusion and execution of a labor or civil contract - the purpose of this operation is to conduct recruitment for the appointment of employees or persons under a civil contract, to conclude the relevant contract and for its administration and execution by the company.Impact assessment conclusion: Based on the impact assessment carried out, the operation “Conclusion and execution of a civil or labour contract” is eligible and provides sufficient guarantees to protect the data subjects' rights and legitimate interests in accordance with GDPR requirements.
  • Processing of requests sent via website form - the purpose of this operation is to contact the requester by telephone or email for the purpose of identifying the data subject as requester and sending a response to a request. Given the limited scope of personal data collected, it is not necessary to carry out an impact assessment of the operation.
  • Review of characteristics of prescription medicines - the purpose of this operation is to provide the content of the characteristics of the medicinal products to subjects who have confirmed that they are medical persons. Given the limited scope of personal data collected, it is not necessary to carry out an impact assessment of the operation.
  • Use of the Company's Website - the purpose of this operation is to maintain and use the Company's website. Given the limited scope of personal data collected, it is not necessary to carry out an impact assessment of the operation.

Art. 4. (1) The controller shall process the following categories of personal data and information for the following purposes and on the following grounds:

  • Data for job applicants: (for the selection of job applicants we process the names, telephone, email address and personal data You have sent to us in Your CV);
  1. Purpose for which the data is collected: 1) Individualization of the applicant; 2) Contacting the applicant and conducting communication; 3) Selection of candidates.
  2. Grounds for processing Your personal data - Processing is necessary for the performance of a contract to which the data subject is a party or for taking steps at the request of the data subject before concluding a contract - Art. 6, para. 1, point (b) GDPR.

The further processing of Your personal data for the purpose of permanent application for a position in the company is carried out on the basis of Your explicit consent - Art. 6, para. 1, letter (a) GDPR.

  • Data for contracting with a partner - legal entity: (names of legal representatives of legal entities and names and a unified identification number number of legal entities' proxies)
  1. Purpose for which the data is collected: 1) Identification of the natural person as a legal representative of a legal entity or a trader for the purpose of concluding and executing a contract and drafting tax and accounting documents, and 2) Identifying the proxy with a view to certifying his/her representative power.
  2. Grounds for processing your personal data - Processing is necessary for the performance of a contract to which the data subject is a party, or for taking steps at the request of the data subject before concluding a contract - Art. 6, para. 1, letter (b) GDPR.
  • Data for contracting with a partner – natural person: (names, unified identification number, address, telephone number, email address)
  1. Purpose for which the data is collected: 1) Identify the person as a partner, 2) Make contact with him/her and 3) Execute the contract.
  2. Grounds for processing your personal data - Processing is necessary for the performance of a contract to which the data subject is a party, or for taking steps at the request of the data subject before concluding a contract - Art. 6, para. 1, letter (b) GDPR.
  • Data for sending a response to a query sent through the company website: (names, telephone, e-mail address)
  1. Purpose for which the data is collected: 1) Identifying the requester and 2) Contacting the requester via the site format and sending a response to the request.
  2. Ground for processing your personal data - Your data for sending a response to a request made through the Company's website is processed on the basis of your explicit consent - Art. 6, para. 1, letter (a) GDPR.
  • IP address data - Improving service security and interface localization, statistical and marketing surveys;
  1. Purpose for which the data is collected: The Company processes personal data for the IP address of an individual, a visitor to the site for the purpose of improving the security of the service and identifying the user as a person using the services from Bulgaria or from another country.
  2. Grounds for data processing: The IP address is collected without identifying a specific individual, i.e. the data is collected in an anonymous format, on the grounds of fulfilling the legitimate interests of the controller - Art. 6, para. 1, letter (f) GDPR.
  3. Collection of this information is necessary for the technical functioning of the site.

(2) The controller does not collect or process personal data relating to the following:

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

(3) The personal data is collected by the Controller from the persons to whom they relate.

(4) The company does not carry out automated decision making with data.

(5) The company does not collect and process data for persons under 14 years of age, except with the explicit consent of their parents or legal representatives.

 

The storage period of your personal data

Art. 5. (1) INBIOTECH Ltd. shall keep Your personal data as a candidate for a job for no longer than 6 months from the moment of the final completion of the recruitment and selection procedures. Upon expiry of the period, INBIOTECH Ltd. takes the necessary care to delete and destroy all Your data without undue delay or to anonymize (i.e. to make it in a form that does not reveal your identity), unless you give Your own explicit consent for Your data to continue to be stored and processed in the future.

(2) In the event that an unapproved candidate for employment has provided original or notarized copies of documents certifying physical and mental fitness, qualification, experience or other circumstance, the Company shall return these documents to the applicant within 6 months from the completion of the selection.

(3) The data of the partners of the company shall be kept for a period of 5 years after termination of the contract or for a longer period, in case of legal or administrative dispute, in order to protect the legitimate interests of the Company. The data contained in the tax and accounting documents is stored for the relevant period provided by law.

(4) The Company shall retain the personal data of persons who have made a request through the form of the Company's website, until the explicit withdrawal of the given consent by the individual or 1 year from the last communication with the requester.

(5) The Controller shall notify You in the event that the data retention period needs to be extended for the purpose of fulfilling a regulatory obligation or for the legitimate interests of the Controller or otherwise.

 

Transfer of Your personal data for processing

Art. 6. (1) The Controller may, at his own discretion, to transfer some or all of Your personal data to personal data processor for the fulfillment of the processing objectives that You have agreed to, subject to the requirements of Regulation (EU) 2016/679 (GDPR) .

(2) The Controller shall notify You in the event that it intends to transfer some or all of Your personal data to third countries or international organizations.

 

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

 

Withdrawal of consent to the processing of Your personal data

Art. 7. (1) If you do not want all or part of Your personal data processed on the basis of consent to continue to be processed by INBIOTECH Ltd. for specific or for all purposes of processing, you may at any time withdraw the consent for processing by sending a free text request or the completed form in Appendix No. 1 by email.

(2) The Controller may request that you verify your identity and to identify with the data subject.

(3) Withdrawal of consent does not affect the ground of the processing of personal data provided by You up to the moment of withdrawal of consent.

(4) The Company may continue to process part or all of Your data if there is a legal obligation to do so or for the purpose of safeguarding its legitimate interests.

Right of access

Art. 8. (1) You have the right to request and receive confirmation from the Controller whether personal data related to You is processed.

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

(3) The Controller shall provide You, upon request, with a copy of the personal data processed relating to You in electronic or other appropriate form.

(4) The provision of access to the data is free of charge, but the Controller reserves the right to impose an administrative fee in case of repetition or excessive requests.

 

Right to rectification and completion

Art. 9. You have the right to ask the Controller to:

  • rectify inaccurate personal data relating to You;
  • fill in incomplete personal data related to You.

 

Right to erasure (‘right to be forgotten’)

Art. 10. (1) You have the right to request from the Administrator the deletion of part or all of your personal data, and the Administrator has the obligation to delete them without undue delay, if any of the following reasons exist:

  • personal data is no longer needed for purposes for which is was otherwise collected or processed;
  • You withdraw Your consent on which the processing of the data 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 the purposes of direct marketing and there are no legitimate grounds for processing to take precedence;
  • personal data is processed illegally;
  • personal data must be deleted in order to comply with a legal obligation under EU or Member State law that applies to the Controller;
  • personal data was collected in relation to the provision of information society services.


 (2) The Controller shall not be obliged to delete personal data stored and processed:

  • to exercise the right to freedom of expression and the right to information;
  • for compliance with a legal obligation requiring processing as provided for in EU or Member State law applicable to
  • the Controller or for the performance of a public interest task or in the exercise of official powers conferred on it;
  • for reasons of public interest in the field of public health;
  • for purposes of archiving in the public interest, for scientific or historical research or for statistical purposes;
    to establish, pursue or defend legal claims.

(3) In case of exercising Your right to be forgotten, the Company will delete all Your data, except for the following information:

  • the information needed to verify that Your right to be forgotten is fulfilled - email;
  • technical information about the functioning of the website, which information cannot in any way be related to Your personality;

(4) In order to exercise Your right to be forgotten, it is necessary to send a request in free text or in the completed form in Appendix No. 2 by email.

(5) The Controller may request that You verify Your identity and identify with the data subject.

(6) The Controller shall not delete the data which it has a legal obligation to keep, including for protection in relation to legal claims against it or for proving its rights.

 

Right to restriction

Art. 11. You have the right to request the Controller to restrict the processing of related data when:

  • challenge the accuracy of personal data for a period allowing the Controller to verify the accuracy of personal data;
  • the processing is unlawful, but You do not want the personal data to be erased, and only its use to be restricted;
  • The Controller no longer needs personal data for the purposes of processing, but You require it to establish, exercise or defend Your legal claims;
  • You objected to the pending review of whether the Controller's legitimate grounds outweighed Your interests.
     

Right to portability

Art. 12. (1) If you have consented to the processing of Your personal data or the processing is necessary for the performance of the contract with the Controller, or if Your data is processed in an automated manner, You may, after legitimizing yourself before the Controller:

  • request the Controller to provide You with Your personal data in a readable format and transfer it to another Controller;
  • request the Controller to directly transfer Your personal data to the Controller designated by You, where technically feasible.

(2) You may at any time download or receive in a machine-readable format the data stored and processed for You in connection with the use of the services of the Controller by sending a request in free text or in the completed form in Appendix No. 3 via e-mail.

 

Right to receive information

Art. 13. You may request the Controller to inform You of any recipients to whom the personal data for which rectification, deletion or restriction of processing has been requested, have been disclosed. The Controller may refuse to provide this information if this would be impossible or would require a disproportionate effort.

 

Right to object

Art. 14. You may object at any time to the processing of personal data by the Controller that relate to You, including if it is processed for profiling or direct marketing purposes.

 

Your rights in breach of your personal data security

Art. 15. (1) If the Controller detects a breach of Your personal data security, which may pose a high risk to Your rights and freedoms, it shall notify You without undue delay of the breach, as well as of the measures taken or to be taken.

(2) The Controller shall not be obliged to notify you if it:

  • has taken appropriate technical and organizational measures with respect to data affected by a security breach;
  • subsequently took measures to ensure that the violation would not pose a high risk to Your rights;
  • notification would require a disproportionate effort.
     

Persons to whom your personal data is provided

Art. 16. For the purposes of processing Your personal data and executing the concluded contract, the Controller may make Your data available to third parties processing personal data that comply with all requirements of legality and security in the processing and storage of Your personal data.

Art. 17. The Controller does not transfer Your data to third countries.

Art. 18. In the event of a 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 registered address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Postal address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Telephone: +359 2/ 915 3 518
Internet site: www.cpdp.bg
 

Art. 19. You may exercise all Your rights to protect Your personal information by completing and emailing the forms attached to this information. Of course, these forms are optional and you can submit your requests in any form that contains a statement to that effect and identifies you as the data owner.

Art. 20. If the consent concerns a transfer, the Controller shall describe the possible risks of transferring the data to third countries in the absence of adequate protection and adequate remedies.

 

Appendix No. 1

Consent withdrawal form for processing purposes

Your name*:

Contact data (e-mail, telephone)*:

 

To

 
 
Name: INBIOTECH Ltd.
UIC/BULSTAT: 040293034
Headquarters and registered address: 1000 Sofia, Oborishte District, 5 Triaditsa Str., ent. A, fl. 4
Postal address: Sofia, 1504, Bulgaria 7, Sheinovo Street;
Telephone: +359 2/ 987 95 37
E-mail: office@inbiotech-bg.com
Website: www.inbiotech-bg.com
 
 

☐ I withdraw my consent to the collection, processing and storage of the following personal data provided by me:

☐All personal data provided by me

☐Only the following data …………………………………………………………….

for the following purposes:

☐The following purposes: …………………………………….

………………………………………………………….

☐All purposes

☐ I declare that I am aware of the company’s terms and conditions on providing the service after withdrawal of consent.

In the event of a violation of your rights under the aforementioned 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 registered address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Postal address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Telephone: +359 2/ 915 3 518
Internet site: www.cpdp.bg
 

 

Signature of the person:………………………….


 

Appendix No. 2

Request to be "forgotten" - to delete personal data related to me

 

Your name*:

Contact details (e-mail, telephone)*:

 

To

 
 
Name: INBIOTECH Ltd.
UIC/BULSTAT:040293034
Headquarters and registered address: 1000 Sofia, Oborishte District, 5 Triaditsa Str., ent. A, fl. 4
Postal address: Sofia, 1504, Bulgaria 7, Sheinovo Street;
Telephone: +359 2/ 987 95 37
E-mail: office@inbiotech-bg.com
Website: www.inbiotech-bg.com
 
 

I request that all personal data you collect, process and store, provided by me or by third parties who are associated with me, according to the indicated identification, be deleted from your databases.

I declare that I am aware that some or all of my personal data may continue to be processed and stored by the controller for the purposes of fulfilling his legal obligations.

In the event of a violation of your rights under the aforementioned 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 registered address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Postal address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Telephone: +359 2/ 915 3 518
Internet site: www.cpdp.bg
 

 

Signature of the person:………………………….


 

Appendix No.  3

Request for transfer of personal data

 

Your name*:

Contact details (e-mail, telephone)*:

 

To

 
 
Name: INBIOTECH Ltd.
UIC/BULSTAT: 040293034
Headquarters and registered address: 1000 Sofia, Oborishte District, 5 Triaditsa Str., ent. A, fl. 4
Postal address: Sofia, 1504, Bulgaria 7, Sheinovo Street;
Telephone: +359 2/ 987 95 37
E-mail: office@inbiotech-bg.com
Website: www.inbiotech-bg.com
 
 

Please send all personal data related to me that is collected, processed and stored in your databases to:

☐ e-mail: .................................................................................................................................................

☐ Controller – receiving the data:

Name: .....................................................................................................................................................
 
Identification number (UIC, BULSTAT, reg. number with PDPC): .....................................................
 
E-mail: ......................................................................................................................................................
 
API interface: ............................................................................................................................................
 
Please provide my personal data in the following format:

....................................................................................................................................................................

I request my personal data in the selected format to be passed on to me / the controller specified by me:

☐To the specified e-mail or via API ………..

☐On physical optical or electronic media (CD, DVD, USB) at Your address.

In the event of a violation of your rights under the aforementioned 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 registered address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Postal address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Telephone: +359 2/ 915 3 518
Internet site: www.cpdp.bg
 

 

Signature of the person:………………………….


 

Appendix No. 4

Request for data rectification

 

Your name*:

Contact data (e-mail, telephone)*:

 

To

 
 
Name: INBIOTECH Ltd.
UIC/BULSTAT: 040293034
Headquarters and registered address: 1000 Sofia, Oborishte District, 5 Triaditsa Str., ent. A, fl. 4
Postal address: Sofia, 1504, Bulgaria 7, Sheinovo Street;
Telephone: +359 2/ 987 95 37
E-mail: office@inbiotech-bg.com
Website: www.inbiotech-bg.com
 
 

I request that the following personal data you collect, process and store, provided by me or by third parties that are associated with me, be rectified as follows:

Data to be rectified:

………………

Please rectify as follows:

……………….

 

In the event of a violation of your rights under the aforementioned 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 registered address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Postal address: 1592 Sofia, Prof. Tsvetan Lazarov No. 2
Telephone: +359 2/ 915 3 518
Internet site: www.cpdp.bg
 

Signature of the person:………………………….