INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA IN NEOCHIM PLC

NEOCHIM PLC is a company registered in the Commercial Register of the Registry Agency under UIC 836144932, with registered office and business address: Dimitrovgrad, Eastern Industrial Zone, Himkombinatska Str. The company has appointed a Data Protection Officer (DPO).

The contact telephone number: +359 391 65 501

NEOCHIM PLC processes personal data in order to implement contract or in the context of pre-contractual relations of employees of the company, employees of external companies with which the company has concluded contracts, clients and suppliers.

For employees of the company the processing of their personal data is carried out:

– for implementation of a contract or in the context of pre-contractual relations

– for implementation of the obligations of NEOCHIM PLC, arising under a law or other normative act

– after the consent by the employees of the company

– in view of the legitimate interest of NEOCHIM PLC

NEOCHIM PLC processes the following data for its employees:

ordinary data: full name, national identification number or foreigner’s personal number, permanent address, current address, telephone numbers, bank accounts, information of graduated education, employment, information of additional qualifications.

sensitive data: medical certificate data, data from expert decisions of the Labour Expert Medical Commission, sick notes, trade union affiliation, video surveillance, health-related data processed by the Occupational Medicine Service.

The personal data of the employees are kept according to the current legislation: payrolls – 50 years.

The personal data of the employees are provided by NEOCHIM PLC to state bodies, including the National Revenue Agency (NRA), the National Social Security Institute (NSSI), the National Health Insurance fund  (NHIF), the Labor Inspectorate, etc.; the private bailiffs – within the scope of their competence, as well as to  third parties – in cases where this is required by law or other normative act.

For customers and suppliers, their personal data are processed:

– for implementation of a contract or in the context of pre-contractual relations

– for implementation of obligations of Neochim PLC, arising under a law or other normative act

– after the consent from customers and suppliers

– in view of the legitimate interest of NEOCHIM PLC

In order to ensure adequate data protection of the company and its employees, we apply all necessary organizational and technical measures provided by the Law on Personal Data Protection. For maximum security when processing and storing personal data, we can use additional security mechanisms such as encryption.

NEOCHIM PLC processes the following data of customers and suppliers:

Identification data: – full name, identity document number

The personal data of customers and suppliers shall be stored until the expiry of the limitation periods for laying claims, set forth in the Law on Obligations and Contracts  (5 years), obligations to provide information to the court, competent state bodies and other grounds provided by the current legislation (5 years). Please note that we will not delete or make anonymous your personal data if it is necessary for pending court, administrative proceedings or proceedings for the examination of complaint of yours towards us.

Video surveillance is carried out on the territory of the company in order to observe the labor discipline, to improve labor productivity and to prevent the loss of intellectual and material property, to monitor the production process and equipment and to protect the life and health of the employees or other persons. The type of installed cameras are: digital (IP) and analogue, working mode: day / night – 24 hours. Sensitive personal data is collected – physical identity: video format. The data are provided to individuals and to government bodies, when it is provided for in a legal act, to other legal entities in case of claims. The organizational and technical protection measures taken are in compliance with the current legislation. Video surveillance records are stored for no more than two months, after expiry of the deadline they are automatically destroyed.

Rights of the subjects of the  data in relation to the processing of their personal data:

Right to information:

– subjects of the data have the right to information on whether their data are being processed, the categories of data and the recipients or categories of recipients to whom the data are disclosed

– subjects of the data are entitled to a message in an understandable form containing their personal data being processed and any available information about their source

Right to rectification:

In case that NEOCHIM PLC processes incomplete or wrong/inaccurate data, the data subjects are entitled at any time to request from NEOCHIM PLC:

– to erase, rectify or block their personal data, the processing of which does not meet the requirements of the law

– to notify third parties to whom personal data have been disclosed of any erasure, blocking or rectification, except where this proves impossible or involves disproportionate effort

Right to objection:

At any time, data subjects are entitled to:

– to make an objection to the processing of their personal data if there is a legitimate reason for doing so; when the objection is reasonable, the personal data of the individual may not be more processed

Right to restriction of processing:

Data subjects have the right to request a restriction of processing of their personal data if:

– they contest the accuracy of the personal data for the period during which the data must be verified

– they have objected to processing the data pending verification of whether the grounds of the administrator are legal

Right to data portability:

– data subjects may request NEOCHIM PLC to provide them personal data, they have provided, in an organized, orderly, structured, generally accepted electronic format if the processing is done automatically

Right to lodge a complaint:

– in case the data subjects think that NEOCHIM PLC violates the applicable regulations, please contact us to clarify the matter. Of course, you have the right to lodge a complaint with the Personal Data Protection Commission.

Upon failure to provide the abovementioned personal data, the statutory requirements of the Labor Code, the Social Security Code, the Health and Safety at Work Act, the Personal Income Tax Act, etc. cannot be met.

version 2