PERSONAL DATA CONTROLLER
Huvepharma EOOD, a limited liability company duly incorporated and existing under the laws of the Republic of Bulgaria, with Unified Identity Code (UIC) 203631745, having its seat and registered address at 3a, Nikolay Haytov Str., 5th floor, 1113 Sofia, Bulgaria, registered with the Bulgarian Commission for Personal Data Protection as a personal data controller under number 417386 (“Huvepharma[SR1] ”).
Purposes of Data Collection
Huvepharma is collecting and processing your personal data with the primary purpose to comply with the Bulgarian and EU legislation concerning the requirements for advertising of some kind of veterinary medicinal products. In most instances, you can visit our website without providing any personal data. However, in order to provide you with access to the EU section of the company`s website (www.huvepharma.com) and with the opportunity to use all its features, Huvepharma has to be assured that you are a medical specialist - qualified vet or pharmacist (“Qualified Person”). Only upon declaring that you are a Qualified Person and providing the personal data requested, Huvepharma could open your account and allow you to access all the information about Huvepharma Veterinary Medicinal Products (“Huvepharma VMPs”), distributed and sold in the territory of EU. In addition, subject to your consent and until revocation of the same, Huvepharma may process your personal data for advertising purposes including the purpose of direct marketing.
The processing of personal data by Huvepharma is regulated in accordance with the Bulgarian Law on Personal Data Protection (last amended on 15 Feb 2013) and the Regulation UE 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data[SR2] .
CATEGORIES OF DATA COLLECTED
Huvepharma will be processing the following categories of personal data: full name (as per your valid ID card or passport) and email address. Your personal data shall be kept and processed by Huvepharma as long as you delete your account and stop using the website. You are not required to provide your personal data. However, if you choose not to, we may not be able to fully provide you with the requested information.
You have the right to access your personal data processed by Huvepharma and to obtain an extract of it at no cost on your side. When exercising of your right of access you may require: (i) confirmation if the data referring to you are processed, information about the purpose of this processing, about the categories of the data and the recipients or the categories of recipients to whom the data will be disclosed; (ii) a message to you in comprehensible form, containing your personal data, which are processed, as well as any available information about their source; (iii) information about the logic of each automated processing of personal data referring to you, if applicable (iv) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period[SR3] . You are also entitled to require, at any time, from Huvepharma to erase, rectify or block your personal data which processing does not comply with the provisions of the Applicable Law. You may rectify or erase incorrect, incomplete or irrelevant data at no cost on your side.
You have the right to obtain: (i) the data portability; (ii) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data which need not be kept for the purposes for which data were collected or subsequently processed.
You have the right to object, in whole or in part: (i) for legitimate reasons the processing of personal data concerning you, even to the scope of the collection; (ii) the processing of personal data concerning you for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication.
To exercise any of the abovementioned rights you have to submit a written application to Huvepharma`s registered address accompanied with a proof of your identity (certified copy of your valid ID card or passport). Huvepharma shall keep a register of all applications received and shall respond within fourteen (14) days from its submission. This term may be extended up to thirty (30) days in the cases when the collection of all requested data objectively requires a longer period and this would impede seriously the activities of Huvepharma.
PROTECTION OF YOUR PERSONAL DATA
Huvepharma takes appropriate technical and organizational measures process the personal data so provided lawfully (in full conformity with the applicable legislation in force) and in good faith, as well as to protect your data against accidental or unlawful destruction, or against accidental loss, unauthorized access, alteration or dissemination, as well as against other unlawful forms of processing. The types of data protection are physical, personnel, documentary protection, protection of automated information systems and/or networks and cryptographic protection. Some of the measures are as follows: restriction of the number of individuals having access to the data on a need-to-know base; use of access codes, locking offices with computers and data files, other appropriate measures of physical protection; training of the respective personnel about their obligations under the law, Huvepharma instruction, policies and guidelines on the personal data protection, and requesting each employee`s explicit consent to assume an obligation of non-disclosure of personal data; regular checks for ascertaining that no unlawful use is made. As the processing of your personal data involves the transmission of data by electronic means, the protective measures secured by Huvepharma take into account the modern technological achievements and ensure a level of security adequate to the potential risks that the data is exposed and the nature of the data to be protected.
PERSONAL DATA DISCLOSURE
Your personal data will not be communicated to third parties, but, if necessary, they can be communicated to:
- all subjects whose access is recognized by legislative measures;
- our collaborators, employees, within their duties and/or any contractual obligations with them, regarding trade relations with stakeholders;
- post offices, shippers and couriers for the delivery of documents and/or materials;
- to all those public and/or private individuals and/or legal entities (legal offices, administrative and tax consultancy work for the compilation of payroll, judicial offices, Chambers of Commerce, Chambers and Offices work, etc..), if disclosure is necessary or appropriate to carrying out our activities and in the manner and for the purposes described above;
- banks for the management of receipts and payments arising out of contracts
[SR4] Please note that in certain cases Huvepharma shall be obliged to disclose your personal data to the public authorities: if this is required by the law; pursuant to a court, regulatory or other official act, ruling or decision; based on the agreements between Huvepharma and other personal data controllers/ processors; following your personal instructions or the instructions of your authorized representative(s). You hereby give your explicit, written, informed and unambiguous consent so that your personal data to be disclosed to Hosting.bg and any third party acting in its capacity of data processor based on an agreement signed with Huvepharma.
In case you are not satisfied with our response to a complaint, you may notify the Bulgarian Commission for Personal Data Protection (https://www.cpdp.bg/en/index.php), whose address is: 2, Prof. Tsvetan Lazarov Blvd., 1592 Sofia, Bulgaria.
I hereby acknowledge that I am duly informed and fully aware of all the rights provided by the Bulgarian Law on Personal Data Protection (last amended on 15 Feb 2013) and the Regulation UE 2016/679, including but not limited to: (i) the objectives, methods and means of processing of my personal data, as well as the voluntary nature of their provision, the volume and the persons to whom they can be provided; (ii) the right of access; (iii) the right of rectification; (iv) the right of objection against the processing of my personal data for the purposes of the direct marketing, (v) the right to be notified before my personal data to be disclosed for the first time to third parties or used on their behalf for the purposes of the direct marketing; and (vi) the right of objection against such disclosure or use.
[SR1]Art. 13 Reg. 679/2016 requires that the personal data controller provide to the data subject also the contact details of the controller
[SR2]The New Regulation 2016/679 will enter into force on 24th May 2016 and shall apply from 25th May 2018. The Directive will be replaced by the Regulation.
[SR3]Art. 13 n. 2 a) Reg. 2016/679
[SR4]Art. 13 e) Reg. 2016/679 states that the data controller provides the information regarding “the recipients or categories of recipients of the personal data, if any;”.
I report some examples of categories of recipients.
[SR5]I suggest you to put the link to the form