„SPEEDY“ AD (referred to as “Speedy”, “we”, “us”, in this policy) takes seriously its responsibility to protect the privacy of the consumers and to secure all personal information, which is made available to it in connection with its day-to-day activities. Personal data mean any specific information relating to you, which allows us to identify you. In example, such information might be your real name, your address, telephone number or payment data, your passwords for access to our Web site and likewise. Data, which directly or in combination with other data, cannot be related to your identity, are not treated as personal data.
- What personal data we collect and process about you in connection with your relationship with us as a customer of our services or as a user of our Web site and online applications;
- How do we use your personal data;
- How and how long we keep your personal data;
- Who we transfer/disclose your personal data to;
- What are your rights as a data subject and how you can exercise these rights;
PERSONAL DATA CONTROLLER
The data controller of your personal data is „SPEEDY“ AD, UIC 131371780, registered address: Sofia 1138, Mladost region, 22 Abagar St., Sofia City Logistic Park, Administrative building Speedy, 5th floor, represented by Valeri Mektouptchiyan, email: [email protected], tel.: 028173999
Speedy collects and processes all personal data in compliance with the personal data protection laws applicable in Bulgaria and the European Union.
WHAT PERSONAL DATA WE COLLECT AND PROCESS AND WHAT DO WE USE YOUR PERSONAL DATA FOR
Personal data are data, through which an individual can be identified.
Each time you connect with us or visit our Web site, you provide to us your personal data. In order for you to be able to use our services, we need to collect and process your personal data. Speedy works intently in good faith to minimize the data that it processes, and to protect them to the maximum extent.
We collect and process the following personal data:
- When you are visiting our Web site, our Web servers will record and store temporarily for security purposes the connecting data of the computer connecting to the Web site, the Web pages visited on the Web site, the date and length of the visit, the identification data of the type of browser and operating system used, and the Web site, through which the connection to our Web site is made
- When you are making contact with us via telephone, the conversations will be recorded and stored temporarily for purposes of security and improvement of the quality of our service.
- When we receive an inquiry from you submitted through any of our contact forms, the contact information will be used by us to contact you and provide the information or assistance needed.
- When you order services, which Speedy provides in the capacity of a postal operator, we collect and process the following personal data:
- data for the sender and the recipient of each parcel or service (as well as for the ordering person whenever different from the sender or the recipient): name, contact mobile and landline phone number, address for collection or receipt of the parcel or other service, e-mail address. The information is necessary as it allows us to execute the requested service, to prepare and issue the documentation relating to the transportation of the parcels, to make contact with you at any time if it is necessary for the successful, accurate and timely performance of the service, and to review and respond to inquiries, complaints and other requests;
- UCN, ID document data, bank account or other payment details. This data is collected whenever the service or the applicable law requires accurate identification of the customer /upon receipt or payment of an amount in cash under Cash on Delivery or Postal Money Transfer services, upon payment of compensations on the basis of claims, etc./, as well as whenever an accounting or other document should be issued in connection with the service, which contains UCN or other ID document data of the customer pursuant to the requirement of the law. This data will also be used to identify and prevent illegal acts.
- The use of certain features on Speedy Web site require registration and access passwords. Upon registration you provide the following personal data: full name, UCN, address, phone number, email address. This data will be used for purposes of the performance of the services you order.
- We collect and process history of all orders made and all services rendered for the purposes of statistical and marketing analysis, testing of systems, maintenance and development, as well as for reviewing and responding to complaints, disputes or claims.
- Some of the data, which you make available to us in connection with the delivery of a parcel, may be provided to the authorities of the States through which or to which the parcel is transported, for purposes of customs clearance or security checks, in accordance with the legislation of the respective States. The information usually includes: the name and address of the sender, the name and address of the recipient, description of the parcel, number of packages, weight, content and value of the parcel.
- Some of the data, which you make available to us, Speedy may use in order to respond to information requests from national regulators (CRC, CCP, CPDP) in connection with complaints or other proceedings brought before these authorities, or to provide to other State authorities or law enforcement agencies for the purposes of administrative controls, security controls, prevention and detection of offences and crimes.
In certain cases you will be asked to present to a Speedy officer an ID document for inspection in order to verify that you are the person authorized to receive performance of the ordered service (e.g. upon delivery of registered postal service, upon receipt or payment of an amount in cash under Cash on Delivery or Postal Money Transfer services, in case of doubt that the service involves a minor, etc.). Neither copies of ID documents, nor data contained therein will be collected or stored by Speedy, unless the law expressly requires from Speedy to carry out identification of the customers by collecting and storing a copy of their ID document or of the data contained in that document (e.g., under the Law on the Measures Against Money Laundering).
We will process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we collected and needed to use your personal data for:
In most of the cases we will need to process your data in order to establish contractual relationship between you as a customer and us as a postal operator for the provision of a service /e.g. courier service, Postal Money Transfer, etc./.
It is also possible that we will process your personal data for one of the following purposes:
- to comply with a legal obligation (e.g. for identification of clients pursuant to the Law on the Measures Against Money Laundering, for compliance with customs regulations applicable to international parcels or parcels containing excise goods, for compliance with accounting requirements pursuant to the Accounting Act, VATA, CITA, etc.);
- you have consented to us using your personal data (e.g. for marketing purposes);
- it is in our legitimate interests as a postal operator (e.g. for administrative purposes).
We would like to use your e-mail address and your phone number, to send you information about our up-to-date services, promotions, discounts and bonuses. This information usually reflects our latest projects and ideas to improve the services and the satisfaction of our customers, which is why we want to make it available to you. We will do so only if you give us your consent to send you this information from time to time via email, SMS, phone or in all these ways. Your consent is voluntary and we will not refuse to render our services, if you don’t provide it to us.
We will not use your contact data in order to market products or services of a third party.
You can revoke your consent at any time by a written statement delivered to the Data Protection Officer: by e-mail communication or by a notice filed at any Speedy office.
PERSONAL DATA OF THIRD PARTIES
We only process and use data, which you have made available to us voluntarily, and we rely that all such data is owned and transferred by you in compliance with the law.
This means that each customer shall be responsible not to provide to Speedy data belonging to third parties, in violation of their rights for protection of personal data, since Speedy has no access to these individuals and has no practical ability to control whether their personal data is transferred with their knowledge or consent, given in accordance with the legal requirements
Therefore, each customer shall be fully responsible if providing to us personal data of third parties without their knowledge or without their consent in accordance with the requirements of the applicable legislation on the protection of personal data, regardless of the type of the data or the reasons for which they have been provided: name, phone number, e-mail address, address of collection or delivery of a parcel and any other.
We do not provide services to minors, nor allow persons under the age of 18 to carry out registration on our Web site or to use its functionality. If you are under the age of 18, please, get help from an adult in order to use our services.
Parcels, which are addressed to minors, shall be delivered to their parents or guardians upon presentation of documents certifying their capacity (e.g. a birth certificate or a judgment of competent court), and subject to inspection of the ID document of the representative.
If we become aware that we have collected personal data from or belonging to a person under 18 years of age, we will promptly delete it, unless we are legally obliged to store this information.
Please contact us if you believe that we have collected unwittingly or by mistake information from or belonging to a person under 18 years of age.
SHARING YOUR PERSONAL DATA AND SUBCONTRACTORS
Speedy does not share, sell, disclose or otherwise distribute your personal data to third parties and will not do so in the future, unless it is required by law, it is necessary for the purposes of the contract between you and Speedy, or you expressly consented to this.
Without contradiction to the above, we may need to provide your personal data, i.e. names, addresses and telephone numbers for contact with the sender and the recipient of a parcel, to our subcontractors and partners in the course of the performance of your service. In order to deliver domestic and international parcels, Speedy partners with number of subcontractors having adequate logistical infrastructure and professional experience, both on the territory of Bulgaria, and in each State, from/to which it makes parcel deliveries. This is a necessary condition for Speedy to provide services with parameters, territorial scope, volume and quality adequate to the market trends and consumer demand.
In addition, Speedy works with subcontractors – professionals in their field, who provide additional security for your data and at a certain time may have access to Speedy systems and databases, including: for security purposes, for the maintenance of the infrastructure and the postal servers, for the provision of secure servers and connectivity.
In other cases, your data may be provided to our trusted suppliers - accountants, auditors, legal and other advisers in connection with the accounting of our activities, the audit of our financial statements, our obligations to national and EU regulators, our legal affairs and the exercising of our legal rights in connection with our contractual relationship with you.
PERIOD OF STORAGE AND DELETION OF PERSONAL DATA
We will not retain your data for longer than it is necessary to fulfil the purpose they are being processed for. To determine the appropriate retention period, we consider the volume, nature and sensitivity of the personal data, the purposes for which we process them and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain your personal data in order to meet our legal obligations (e.g. to respond to a claim of yours, to protect our legal rights in the event of a legal suit being filed against us or to fulfil our legal obligation to keep accounting records for purposes of statutory tax audits).
If your personal data are contained in accounting documents, in hard or soft copy, which documents may be requested from Speedy for the purposes of statutory tax audit, the data will be stored for a period of 10 years.
Your personal data provided during registration on the Web site of Speedy, will be kept and processed for the duration of the registration, until you request deregistration and deletion of your account.
Your personal data supplied in connection with a Speedy service, will be kept for the period of time during which you can file complaints or other claims against us and we may need to exercise our rights of defence.
Your personal information submitted through any of our contact forms, including in the event of non-completed Web site registration, will be kept for a period of 6 months for security purposes and for easier subsequent communication with the customer, unless there are grounds for application of a longer period of time.
When you have consented to our use of your personal data for marketing purposes, we will keep and process such personal data until you withdraw your consent.
When we have no longer legal grounds to keep your personal data (e.g. we no longer have a legitimate interest to keep your personal data, or the statutory period for data storage has expired, or you have withdrawn your consent for the data processing), we will securely delete or destroy it.
Speedy has undertaken a wide range of technical and organizational measures to protect your personal data against loss or other forms of unlawful processing. Your personal data (as needed) are available only to employees or subcontractors (and their personnel), who need the access to perform their obligations arising out of our relationship with you. These persons are trained how to process your personal data and have undertaken to do so in strict compliance with the policy, standards and guidelines of Speedy with regard to the protection of personal data.
Under certain circumstances, you have the right by law to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request rectification of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so by law.
If you want to exercise any of these right you can do so by sending your request to the Data Protection Office of Speedy. To have the opportunity to provide you with complete assistance, please provide us with the correct information about you and specify your request.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, you should be aware that when your requests are clearly unfounded or excessive, especially if made repeatedly, we may:
1. charge you with a reasonable fee, taking into consideration the administrative cost associated with the provision of the information, with the communication or with the undertaking of the requested action, or
2. we may refuse to act.
We will make reasonable efforts to honor your request within 30 days of receipt of your request. If necessary, this period may be extended by another two months, taking into account the complexity and number of the requests.
We can ask from you specific information that will enable us to verify your identity and to respect your right to access the information (or any of your other rights). This is an appropriate additional security measure, ensuring that your personal information will not be disclosed to persons who are not entitled to receive it.
If you think we have violated your rights in relation to your personal information, you can file complain to the Supervisory Authority of Bulgaria, which is the Commission for Personal Data Protection. More information can be found at: www.cpdp.bg. Also, you can submit your complaint in the country where you live, in the country where your workplace is as well as in the country where you consider your rights violated.
DATA PROTECTION OFFICER OF SPEEDY
Data Protection Officer: Emil Nikolov, address: 1138 Sofia, 22 Abagar str., Sofia City Logistic Park, email: [email protected]
Request form for exercising rights in relation to personal data protection