PRIVACY AND PROTECTION POLICY OF PERSONAL DATA C „АНДРОМЕДА ООД“ с ЕИК 114508860, гр.Плевен
I. Introduction
„АНДРОМЕДА ООД“ (hereinafter referred to as "short') „АНДРОМЕДА ООД“, the company) is a commercial company registered in the Commercial Register of the Registry Agency with EIC: 114508860, with headquarters and management address: Pleven, 87 Ruse Str. and Website http://www.iromeda.bg/.
„АНДРОМЕДА ООДcarry out activities in the field of sale, rental and management of residential, business, luxury properties and land; architectural solutions and interior design; expert assessments, market research and financial analysis, legal advice, representation and other related real estate.
„АНДРОМЕДА ООД“is a personal data controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as the "CPA') and the Personal Data Protection Act (hereinafter referred to as the "CPA').
With the current Privacy and Privacy Policy (hereinafter referred to as "Policy') „АНДРОМЕДА ООД“take into account the privacy of the individual and endeavour to protect against the unlawful processing of personal data of natural persons. In accordance with the Bulgarian legislation, the Council of Ministers took the necessary technical and organisational measures to protect the personal data of individuals.
Getting acquainted with this Policy before the use of our services is imperative, as its provision is related to the collection of certain categories of personal data required by „АНДРОМЕДА ООД“ за пълноценното предоставяне на услугите.
1. Policy objectives and scope
With the current Privacy and Privacy Policy (Name of the AGENCY) it aims to inform individuals about:
- the purposes and means of processing personal data;
- the recipients or categories of recipients to which the data may be disclosed;
- the basis for the processing of personal data /the mandatory or voluntary nature of the provision of the data/ and the consequences of refusal to provide them;
- information on the right of access, the right to correct and delete the data collected.
2. Terms and definitions:
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5. Administrators jointly define the purposes and means of processing personal data, they are joint Administrators;
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10. A regulation defines a child as anyone under the age of 16 although this may be reduced to 13 of the law of the Member State. Processing of a child's personal data is only legal if a parent or guardian has given consent. The administrator shall make reasonable efforts to verify in such cases that the holder of the parental responsibility for the child has given or authorised to give his consent.
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13. As regards the processor, its main place of establishment in the EU will be its administrative centre. If the administrator is headquartered outside the EU, he must appoint his representative in the jurisdiction in which the administrator works to act on behalf of the Administrator and to deal with supervisory authorities.
14. At the same time, public authorities that may receive personal data in the context of a specific investigation in accordance with Union or Member State law shall not be considered to be ;
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3. Legal basis for the processing of personal data, personal data sources and period for which the personal data collected are stored:
„АНДРОМЕДА ООД“ process personal data on the following grounds:
- Based on the free, informed and explicit consent of the data subject;
- In the event of a legal obligation to process the data;
- When concluding or implementing a contract, and for actions prior to the conclusion of a contract;
- Where necessary to protect the vital interests of the natural person or the legitimate interest of the Administrator, provided that he does not conflict with the legitimate interests of the natural person
„АНДРОМЕДА ООД“ processes personal data provided by employees, customers, contracting entities,suppliers, counterparties and other natural persons, to which the data related to the provision of services by the object of their activity, as well as the preparation and conclusion of contracts.
„АНДРОМЕДА ООД“ processes and personal data not received from the natural person to whom they relate but are provided by a third party in connection with a specific service, such as the person who provided that data to the „АНДРОМЕДА ООД“undertakes:
1. provide the third party with data for the Administrator;
2. notify the third party of the purposes, categories of data provided and categories of recipients of those data;
3. provide information on the right of access and the correction of personal data to the person concerned.
Option 1: The personal data collected shall be stored for a period of 5 (five) years from the date of termination of the contract for the provision of the service concerned.
Option 2: Personal data shall be stored for a period necessary under the objectives for which they have been collected or for a period laid down in a regulatory act.
In the event of consent by the data subject for direct marketing, the personal data shall be stored until the latter is written off or requested to be written off.
4. Means, principles and purposes of processing:
4.1. „АНДРОМЕДА ООД“ process personal data through a set of actions that may be carried out by automatic or other non-automatic means such as collection, recording, organisation, storage, adaptation or modification, recovery, consultation, use, disclosure by transmission, distribution, provision, updating or combination, blocking, deletion and destruction.
„АНДРОМЕДА ООД“ processes personal data on its own or through the award of processing data by means of a written contract, specifying the objectives and volume of the obligations conferred by the processor administrator, in the presence of a relevant legal basis, as required by the TLAS/ZLD. Processing on behalf of „АНДРОМЕДА ООД“for example, the employees of the Administrator, whose rights and obligations, in relation to the processing of personal data of natural persons are duly regulated in internal acts of the Administrator and in the labour characteristics of the employees concerned. There are also third parties outside the administration structure who are entrusted with the processing of personal data on behalf of the Administrator.
4.2. Those processing actions shall be carried out in accordance with the following principles:
- the legality of the processing of personal data;
- the appropriateness of the processing of personal data;
- proportionality of the processing of personal data;
- actuality of the personal data processed;
4.3. In respect of the performance of statutoryly established obligations and pre-contracting and contractual relations, in the course of its activities, (IME OF THE AGENCY) processes personal data of its employees, clients and third parties for the following purposes:
– администриране на трудовоправни отношения: лични данни на лица, кандидатстващи за работа и служители по повод съществуващо трудово правоотношение (обработването на данни е най-често вследствие на изпълнение на нормативно установени задължения на Администратора на лични данни, произтичащи от спецификата на изискванията на законодателството, регламентиращо дейността му, финансово-счетоводната дейност, пенсионна, здравна и социално-осигурителна дейност, дейността по управление на човешките ресурси, автоматичния обмен на информация в областта на данъчното облагане и други);
– администриране на договорни отношения: лични данни на лица преди договор за услуга и настоящи клиенти (включително когато е дадено изрично съгласие или обработването е необходимо за изпълнение на задължения по договор, по който физическото лице, за което се отнасят данните, е страна, както и за действия, предхождащи сключването на договор и предприети по искане на лицето).
PROPERTY: In establishing lasting commercial relations with individuals, „АНДРОМЕДА ООД“, according to the provisions of Art. 4, item 15, b. On the basis of Art. 2, para. 1 of the Rules for the Implementation of the ZMI in relation to Art. 6, para 1, item 2 of the ZMI, the identification of the clients and the verification of the identity of individuals shall be carried out by presenting an official document of identity and removing a copy of it. The administrator is obliged to collect and process information representing personal data for natural persons under Art. 4 in conjunction with Art. 10 and Art. 11 of the Law on Measures for Prevention of Money Laundering.
5. Categories of processed personal data and registers
5.1. Categories of personal data which „АНДРОМЕДА ООД“ process for carrying out its activities:
1. Related to the physical identity of the natural persons ;
2. Economic identity-related ;
3. Social identity related education, employment, citizenship;
4. Related to family identity - family status, family ties, etc.;
5. Other personal data which may be provided to obtain a service „АНДРОМЕДА ООД“.
5.2. The personal data processed are structured in the following registers:
- Register ;
- Register ;
6. Rights of data subjects:
6.1 Right to information
Each data subject has the right to request information about the type of personal data processed by „АНДРОМЕДА ООД“that concern him personally. Such information should be provided independently of where personal data are processed. The data subject may make any such request for information to the department/ employee Angel Ivanov of the Administrator. The dedicated department (s) shall assist the entity by providing it, where possible, the personal data processed for it in its desired format, which must be structured, in a widely used and adapted machine-reading format. This information shall be provided to the entity as accepted by „АНДРОМЕДА ООД“. Procedure for providing information to the personal data subject.
The data subject shall be entitled to information for the purposes of processing his or her personal data, which shall be provided to him during the collection of his or her personal data and in subsequent changes to the purposes of processing.
6.2 Request for correction
If the personal data stored are incorrect or incomplete, the data subject may require that they be corrected. Data subjects are responsible for providing correct personal data to the Administrator. In addition, the data subject should inform the Administrator of any relevant changes in his personal data (such as changes in the address or the name of the entity).
6.3 Limited use
At any time during the processing of personal data, the data subject may request the Administrator to restrict the use of his personal data for part or all the purposes of the processing to which the data subject has consented.
6.4 Refusal of a request for information, correction or restriction of the processing of personal data
If the request for information, correction or restriction of processing is refused, the data subject will be informed of the reason for the refusal concerned. The refusal shall be made as requested by the entity and should be reasoned.
6.5 Right to delete (suppose to be forgotten)
Each person has the right to request the Administrator to delete the personal data related to him and the Administrator has the obligation to delete them without undue delay. When exercising that right by the data subject, the controller shall indicate to the entity how the deletion will affect their relationship in the future.
6.6. Right to object
Any data subject shall have the right to object to the processing of personal data relating to him. The controller shall terminate the processing of personal data unless it proves that there is a legal basis for continuing the processing.
In addition, any data subject has the right to object if his personal data are used for advertising purposes (direct marketing) or for market or public opinion research purposes. In that case, personal data should be blocked and should not be used for the relevant purposes.
6.7. Withdrawal of consent to the processing of personal data
The data subject shall have the right to withdraw his consent to the processing of his personal data at any time with a separate request addressed to the Administrator. The administrator shall show the entity how the deletion will affect their relationship in the future.
6.8. Questions and complaints / remedies
The data subject shall have the right to submit complaints/claims to the Administrator on matters relating to the processing of his personal data to which the controller reacts in accordance with an accepted procedure (Procedure for communication of complaints and requests by the data subject).
6.9. The right to consent to the processing of his personal data
For the existence of an agreement The controller shall only accept where the data subject has been fully informed of the intended processing and has expressed his consent without exerting pressure on him. The consent received under pressure or on the basis of misleading information is not a valid basis for processing personal data.
The consent cannot be derived from the lack of response to a message to the data subject. There must be active communication between the Administrator and the subject to have consent. The controller should be able to demonstrate that consent has been obtained for processing activities.
In most cases, consent to processing personal data is received by the Administrator routine using standard consent documents, for example, when a new client signs a contract or during the recruitment of new staff.
When processing children's personal data, the administrator should be authorised by parents (parents, guardians, etc.). This requirement applies to children under the age of 16 (unless the Member State has provided for a lower age limit which cannot be lower than 13 years).
6.10. Right of representation
The data subject may authorise another person to exercise the rights under item 1.1. to item 1.9 of this policy. The authorisation should be explicitly and done in writing. In any exercise of the rights of the data subject, the controller shall submit a copy of his power of attorney to the Administrator or to the processor on behalf of the Administrator.
II. Personal data security:
„АНДРОМЕДА ООД“ ensure the security of personal data in accordance with the principles set out in the TLAS/HALD by taking appropriate and sufficient administrative, technical and organisational measures to ensure data protection against loss, theft, abuse and unauthorised access, disclosure, change or destruction.
7. General principles relating to the processing and security of personal data:
7.1. Admissibility of processing of data
Processing of personal data is only permissible if the data subject agrees with this if there is a legal obligation to process the data, when concluding or implementing a contract, where necessary to protect the vital interests of the natural person or the legitimate interest of the Administrator, provided that it does not conflict with the legitimate interests of the natural person. Admissibility of the processing of personal data is a prerequisite for the transfer of personal data.
The consent should be declared in writing or on the basis of other legally permissible means and the data subject should be informed in advance of the purpose of processing and the possibility of transferring personal data to third parties. The provision of consent shall be highlighted when included in other declarations so as to make it clear to the data subject.
7.2. Purpose envisaged
Personal data may only be collected for comprehensively listed purposes and cannot be processed for purposes other than those provided for. The purpose of data collection and processing must be tailored by the Administrator for further processing and storage of such data. Changes to the purpose shall be admissible only with the consent of the data subject or if permitted by the local legislation of the country from which the personal data are received.
7.3. Data savings
Processing of personal data must be necessary for the intended purpose. The available options for anonymisation or the introduction of pseudonymisation for personal data must be used at an early stage as far as possible and cost-effective for the intended protection purpose.
7.4. Data quality
Personal data must be factually correct and, to the extent necessary, relevant. The administrator shall take appropriate and reasonable measures to correct or delete incorrect or incomplete data.
7.5. Data security
The data controller shall establish appropriate technical and organisational measures to ensure the necessary data security. These measures relate in particular to computers (servers and jobs), networks and communication links and applications, which are incorporated into the IT security management system. Appropriate measures shall be taken to protect this data from deletion by mistake, unauthorised deletion or loss. Full information is provided in Directive (EU) 2016/1148 of the European Parliament and of the Council of 6 July 2016 on measures for a high common level of security of networks and information systems in the Union.
7.6. Confidentiality of data processing
Only authorised personnel who have undertaken to comply with data confidentiality requirements shall be entitled to participate in the processing of personal data. Employees are prohibited from using such data for personal purposes or from providing it to unauthorised companies and third parties. Unauthorized in this context also means the use of personal data by employees who do not need access to such data in order to fulfil their official responsibilities. The obligation of confidentiality shall also continue after termination of the employment/civil/service relationship with the Administrator.
8. Administrative and technical measures to protect personal data:
„АНДРОМЕДА ООД“use administrative and technical measures to protect personal data that it processes through its employees or provides for the processing of third parties These measures are expressed as follows:
8.1.All employees of the Administrator shall be responsible for ensuring the security of the data they process and for keeping the data secure and not revealing themselves under any circumstances to third parties, unless the Administrator has granted such rights to those third parties on the basis of a written contract or confidentiality clause;
8.2.All personal data should be accessible only to those personnel/hackers whose obligations include the processing of specific data and access only takes place in accordance with the internal access control rules adopted Subcutaneous use Procedure concerning rules and rights regarding the control of access to personal data by technical means).
8.3.In order to ensure sufficient protection of processed personal data, „АНДРОМЕДА ООД“use the following technical measures (virus protection, firewall, encryption/encryption option);
8.4.The controller shall adopt internal rules setting out the sensitivity levels of the personal data processed (information) on the basis of which separate categories of personal data are created which are processed for specific purposes. Individual categories of personal data shall be specified in the personal data registers. The internal rules shall determine both the order of access to those registers and persons entitled to access them, respectively, process the personal data stored therein;
8.5.The controller shall, by internal act, determine the procedure for controlling the separation of personal data. Those rules shall contain measures to ensure that data collected for different purposes can be processed separately from authorised staff/persons;
8.6.The administrator shall take measures to ensure the protection of personal information against accidental destruction or loss;
8.7.The controller shall determine procedures for the recovery of personal data after a physical or technical incident. In order to fulfil these obligations, the Administrator shall provide the necessary technical means (servers, computer network, cloud space) for which protective measures under point 8.3 of this Section are taken.
9. Administrative and organisational measures for the protection of personal data:
9.1.„АНДРОМЕДА ООД“ adopt procedural rules laying down measures and procedures for the physical access and protection of personal data which are binding on all personnel processing personal data;
9.2.The controller shall designate protected areas for the storage of the physical personal data carriers to which access is determined under the procedural rules under point 9.1 of this Section;
9.3.The administrator shall implement the following measures to limit access to physical data media (e.g. high-level door protection locks on the Administrator's office, as well as on doors providing access to the office building; lock cabinets where paper media of the established registers are located);
9.4.The administrator shall establish a policy of the Clean Office with which all personnel who process personal data are introduced and implemented. Records on paper must not be left where they can be accessible to unauthorised persons and cannot be removed from designated protected premises without express permission. As soon as the paper documents are no longer necessary for the ongoing processing of personal data, they should be archived in the appropriate order, and if there is no reason for their backup, they should be destroyed in accordance with a procedure established for that purpose;
9.5.Personal data may only be deleted or destroyed in accordance with the procedure adopted by the Administrator (Procedure for storing and destroying data). Records in paper format whose processing period has expired should be cut (cut) and destroyed as Data on hard drives of unused personal computers must be deleted or destroyed according to the procedures in place;
9.6.The processing of personal data outside the premises of the Administrator shall be carried out in accordance with the relevant procedural rules and shall be admissible with the express written consent of the controller or processor.
10. Data Protection Officer
„АНДРОМЕДА ООД“appoints a Personal Data Protection Officer (PAT). The officer in charge is an employee of the Administrator. The role of this person is to monitor compliance with this Policy in the enterprise of the Administrator and to ensure that the processing of personal data can be demonstrated in accordance with personal data protection legislation.
The CALD shall develop and implement the requirements for the protection of personal data under the provisions of this Policy. The CAD shall carry out security and risk management in relation to compliance with this Policy.
The OCD is responsible for administering and processing requests and inquiries made by the data subject to the Administrator. The CALD shall provide the necessary explanations to the Administrator's staff regarding the protection of personal data.
The CAD shall periodically draw up and submit reports to the Administrator regarding the implementation of this Policy, the regulatory provisions governing the protection of personal data and the compliance of the personal data protection in the undertaking with the regulatory requirements in this area.
III. Storage, destruction and inventory of personal data:
11.Storage
11.1.„АНДРОМЕДА ООД“does not store personal data in a form that allows the identification of entities for a period longer than is necessary to carry out the processing for which the consent of the data subject is given for the purposes for which they have been collected. Keeping personal data for a longer period shall also be admissible without the explicit consent of the data subject if provided for in a regulatory act of domestic or European Union law;
11.2.The controller may store data for a longer period than necessary to carry out the processing for which consent is given and where personal data will be processed for the purposes of public backup, scientific or historical research and statistical purposes and only in the performance of appropriate technical and organisational measures to ensure the rights and freedoms of the data subject;
11.3.The period of storage of each category of personal data separated in a separate register shall be determined in a procedure adopted by the Administrator (Procedure for storing and destroying data). This procedure sets out the criteria used to determine the storage period, including any legal obligations in place to the Administrator regarding data storage.
11.4.The procedure for storing and destroying data and the rules for destroying information on physical media shall apply in all cases.
12. Destruction
Personal data must be destroyed securely in accordance with the principle of ensuring an appropriate level of security. Compliance with the procedure shall be mandatory in order to ensure protection against unauthorised or unlawful processing and against accidental loss, destruction or damage to the data by applying appropriate technical or organisational measures.
13. Inventory
13.1.The controller shall establish a process of data inventory as part of its approach to addressing the possible risks of processing personal data collected. The data inventory and their processing shall assess the impact of the personal data risk, the methodology and elements of which are regulated by a methodology adopted by the Administrator Methodology for carrying out an impact assessment on the protection of personal data. The identification of risks under this methodology shall also apply to the processing undertaken by other organisations on behalf of the Administrator;
13.2.The administrator shall manage all risks identified in the impact assessment in order to reduce the likelihood of non-compliance with the rules introduced with the TLAS/ TLAS. Where processing can lead to a high risk to the rights and freedoms of natural persons, in particular with the use of new technologies and taking into account the nature, scope, context and purposes of processing before proceeding to processing, the controller should assess the impact of the envisaged processing operations on the protection of personal data. An overall impact assessment may consider a set of similar processing operations which constitute similar high risks;
13.3.Where, as a result of the Impact Assessment, it is clear that the controller will process personal data which, due to high risk, could cause damage to data subjects, the decision whether or not the processing is ongoing must be transmitted for review by the OSD;
13.4.If the AALD has serious concerns either regarding the potential harm or danger or the amount of relevant data, it should prepare a report to the supervisory authority (CALD);
13.5. The CAD shall review the initial inventory data periodically, review the information entered in the Register of the processing activities, with a view to any changes in the activities of the Administrator.
IV. Provision of personal data to third parties
14.1.The controller of personal data may disclose the processed personal data only to the following comprehensively listed categories of persons:
a). natural persons to whom the data relate;
(b) persons for whom the right of access is provided for in a regulatory act or
(c) persons for whom the right arises under a contract;
14.2.In order to provide services, the controller shall provide information (necessary personal data) for the performance of a contractual obligation to the data subject. The controller shall provide personal data to third parties providing services on its behalf on the basis of an explicit written instruction/written contract. Those third parties shall not be entitled to use or disclose data outside the objectives for which they have been provided, except where it is necessary to perform services on behalf of the Administrator or to comply with legal requirements. The purposes of processing the personal data provided are explicitly defined in the written instruction/written contract on the basis of which the data are provided to the third party. Third persons (personal data processors) are obliged to provide the necessary technical and organisational measures for the protection of personal data provided by the Administrator or larger;
14.3. The administrator shall share the personal data received with its affiliates, franchise recipients, dealers and joint partners on the basis of explicit written instructions or written contract. Such persons may use the information for the purposes described in this Personal Data Protection Policy. In the event of explicit consent by the personal data subject, the latter may be shared with third parties on the basis of a written contract for their own purposes, such as offering products and services which may be of interest to the data subject;
14.4.The controller shall share personal data with competent authorities/persons in order to organise the protection of its legal rights and interests in initiating order, arbitration, security, claim and other proceedings;
14.5.The controller shall disclose personal data to entities whose personal data is processed when required by law, regulation, international contract or act of European Union law, or in connection with a judicial procedure, in response to a request from public authorities (e.g. law enforcement or investigative bodies), or in the event of a serious and unlawful violation of the legal rights and interests of the entities of law.
V. Training
15. Purpose
Having regard to the arrangements for the protection of personal data of natural persons and to the enhanced measures for the protection of personal data introduced by the TIPP/ZLD, „АНДРОМЕДА ООД“take into account the need to conduct initial and follow-up training of its personnel in the duties of which the processing of personal data of natural persons on behalf of the Administrator is included. Initial and subsequent trainings shall aim to inform the servants of the established rules and procedures for compliance with this Privacy Policy and applicable regulations, as well as other issues related to the protection of personal data and privacy.
The training of employees aims to achieve their awareness of the requirements already available or emerging regarding the protection of personal data and the measures taken by the Administrator in accordance with them.
16. Obligations and roles
16.1. The Data Protection Officer shall ensure the proper distribution of employee responsibilities in relation to data protection in accordance with the rules and procedures of the Data Processing Administrator.
16.2. The Data Protection Officer should ensure that all employees who have ongoing personal data obligations and processing operations as well as those with permanent/regular access to personal data show compliance with the data protection requirements.
16.3. Employees must be able to demonstrate competence in their understanding of compliance requirements and how they are applied in the organization of the Administrator.
16.4. The Data Protection Officer shall be responsible for updating their knowledge and information on all personal data issues under the scope of their professional obligations by organising ongoing trainings in the framework of the personal data protection legislation or in the event of a change in the subject of the controller's activities, as well as in introducing new procedures/ measures for the protection of personal data by the Administrator.
16.5. The administrator shall encourage training and awareness-raising measures by providing the necessary resources and material basis for this.
16.6. The Data Protection Officer shall identify and inform employees of the importance of data protection in the performance of their direct duties and in accordance with their role in the organisation.
16.7.The Data Protection Officer shall be responsible for making sure that employees understand how and why the rules and procedures in the Personal Data Processing Administration are applied, for which the relevant reports/records are drawn up.
16.8. The Data Protection Officer shall develop training and information programmes for both the entire staff and any particular role in the organisation that relates to the processing of personal data.
16.9. The Data Protection Officer shall establish a system for periodic verification of awareness as well as for updating employee knowledge of changes in data protection requirements.
16.10. Employees shall receive specific training for the processing of personal data relating to their permanent roles and responsibilities and in accordance with the rules and procedures adopted by the Administrator.
16.11. Employees shall receive specific training on all requirements and procedures for the protection of information applicable to data protection and data processing within their daily roles and responsibilities, including reporting of personal data breaches.
16.12. Staff members shall receive training on requests and complaints from data subjects relating to the protection of personal data and the processing of personal data under the rules and procedures of the Administrator.
16.13. The Data Protection Officer organizes trainings for all responsible persons and employees.
16.14.The Data Protection Officer shall document any training carried out and shall draw up a list/protocol with those attending the relevant trainings carried out at the appropriate time according to the activity of the Administrator.
16.15. Initial training of employees shall be carried out in the course of the implementation of this policy as well as in the course of new employees whose employment obligations include processing of personal data.
16.16. Follow-up trainings shall be carried out periodically (not less than once every 6 months) or in the event of a change in the regulations of protection of the data available/change in the subject of the controller's activities regarding the processing of personal data or the introduction of new measures/protection procedures.
VII. Transitional and final provisions:
1. This Policy was adopted by Decision No 1 of 01.05.2018 of the Governor of the „АНДРОМЕДА ООД“and shall enter into force from 25.05.2018;
2.Personal data subjects may be acquainted with the current policy in the office of the Administrator located in Pleven, 5 Bukston Str. and on the website of the Administrator http://www.andromeda.bg/;
3. Personal Data Protection Officer „АНДРОМЕДА ООД“is:
name: Angel Ivanov
telephone: 0888 09 99 31
address: Pleven, 5, Buckston Str., of.6
e-mail address: vanov@andromeda.bg
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