Privacy Policy

Data protection is of particular priority. The use of the website dzhurov.com is possible without providing personal data, however, if you still wish to use certain of our services via our website, the processing of personal data may become necessary. If the processing of personal data is necessary and there is no legal or contractual basis for this, we always ask for your prior consent.

The processing of personal data, such as name, surname, country, city, address, telephone, email, etc. will always be in accordance with the General Data Protection Regulation (GDPR) and the specific provisions of the Personal Data Protection Act. With this privacy policy we inform you about the nature, scope and purpose for which we collect, use and process personal data. Furthermore, through this data protection policy, personal data subjects are informed about their rights.

The data controller has taken a number of technical and organizational measures to ensure complete protection of personal data processed through our website. However, when transmitting data over the Internet, security breaches may occur and therefore complete protection cannot be guaranteed.

1. Definitions

The data protection policy is based on the terms used by the European legislator when implementing the General Data Protection Regulation (GDPR). The aim of our data protection policy is to be clear and understandable for the general public as well as for our customers and business partners. To ensure this, we would first like to clarify the terminology used.

In this data protection policy, we use, among others, the following terms:

a) “Personal data”

Personal data means any information relating to an identified or identifiable natural person ('data subject'). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

b) “Data Subject”

A data subject is any identified or identifiable natural person whose data are processed by the controller responsible for the processing.

c) “Processing”

Processing means any operation or set of operations which is performed upon personal data or upon sets of personal data, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

d) “Restriction of processing”

Restriction of processing means marking stored personal data with the aim of restricting their processing in the future.

e) “Profiling”

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning the performance of that natural person's professional duties, his or her economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) “Pseudonymization"

Pseudonymisation means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that it is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;

g) “Personal data administrator”

Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its determination may be laid down in Union or Member State law;

h) “Personal data processor”"

Processor of personal data means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;

i) “Recipient”

Recipient means a natural or legal person, public authority, agency or other body to which the personal data are disclosed, whether or not it is a third party. However, public authorities which may receive personal data in the framework of a specific investigation in accordance with Union or Member State law shall not be considered as ‘recipients’; the processing of such data by those public authorities shall comply with the applicable data protection rules in accordance with the purposes of the processing;

j) "Third party"

Third party means a natural or legal person, public authority, agency or other body other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorised to process the personal data;

k) “Consent of the data subject”

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes, by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the administrator

The controller for the purposes of the GDPR on data protection, other data protection laws applicable in Member States of the European Union and other provisions relating to data protection is:

• Aleksandar Krasenov Dzhurov, Attorney
• Sofia, 13 "Georg Washington" Str., 2nd floor, office 2.4.
• BULSTAT UIC: 180774546
• Email: office@dzhurov.com
• Phone numer: +359 442 19 19
• Web site: dzhurov.com/en/

3. Cookies

The website uses cookies (or “cookies”). Cookies are text files that are stored on the computer system via an internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. This is a unique cookie ID. It consists of a string of characters by which websites and servers can be assigned to the specific internet browser in which the cookie is stored. This allows visited websites and servers to distinguish the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified using the unique cookie ID.

By using cookies, we can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of cookies, the information and offers on our website can be optimized for the respective user. Cookies allow us, as mentioned above, to recognize users of our website. The purpose of this recognition is to make it easier for users to use our website. The user of a website that uses cookies does not have to enter access data every time they log in, as this is done by the website and the cookie is thus stored on the user's computer system.

The data subject may at any time remove the cookie setting via our website by means of a corresponding setting of the Internet browser used and can thus permanently deactivate the cookie setting. In addition, cookies that have already been set can be deleted at any time via the Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the cookie setting in the Internet browser used, not all functions of our website can be fully used. 

4. Collection of general data and information

Our website collects a set of general data and information when a data subject or automated system connects to the website. This general data and information is stored in server log files. Information may be collected regarding (1) the type of internet browser and its version, (2) the operating system through which the user accesses the website, (3) the website from which the user is directed to visit our website (also called a referring website or link), (4) websites with a local navigation menu, (5) date and time of access to the website, (6) Internet Protocol address (IP address), (7) the user's internet service provider and (8) any other similar data and information that may be used in the event of attacks against our information technology systems.

When using this data and information, no conclusions are drawn about the data subject. Rather, this information is needed to: (1) provide the content of our website correctly; (2) optimize the content of our website as well as its advertising; (3) ensure the long-term functionality of our information technology systems and website technology; and (4) provide law enforcement authorities with information necessary for criminal prosecution in the event of a cyberattack. For this reason, we analyze anonymously collected data and information statistically in order to increase the level of data protection and security of our enterprise and to ensure an optimal level of protection for the personal data we process. The anonymous data in the files containing server logs is stored separately from all personal data provided by a data subject.

5. Possibility to contact us via our website

The website contains information that you provide or update by filling out the website's contact form (name, surname, email address and phone number, etc.).

If a data subject contacts the data controller by e-mail or fills in the contact form on the website, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted voluntarily by a data subject to the controller are stored for the purpose of processing or contacting the data subject. We may disclose your personal data to third parties, namely: accounting firms and courier service providers.

6. Ongoing deletion and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to fulfil the purpose of the storage or as long as this is permitted by the European legislator or other legislators in accordance with laws and regulations applicable to the data subject or the data controller.

If the purpose of the storage is not applicable, or if the storage period provided for by the European legislator or another competent legislator expires, the personal data shall be blocked or erased in accordance with the legal requirements.

7. Data subject rights

a) Right to confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may, at any time, contact any employee of the controller.

b) Right of access

Each data subject has the right granted by the European legislator to obtain from the controller free information concerning personal data stored concerning him or her at any time and a copy of that information. In addition, European directives and regulations grant the data subject access to the following information:

• • The purpose of the processing;
  • The categories of personal data concerned;
  • The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • If possible, the intended period for which the personal data will be kept or, if not possible, the criteria used to determine that period;
  • The existence of the right to require the controller to rectify or erase personal data or to restrict the processing of personal data of the data subject or the right to object to such processing;
  • The existence of the right to lodge a complaint with a supervisory authority;
  • Any available information about the source of the personal data where it is not collected from the data subject;
  • The existence of automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the General Data Protection Regulation and, at least in those cases, substantial information on the logic used and the significance and intended consequences of that processing for the data subject.

In addition, the data subject has the right to be informed as to whether personal data are transferred to a third country or an international organisation. If this is the case, the data subject has the right to be informed of the appropriate safeguards in relation to the transfer.

If a data subject wishes to exercise the right of access, he or she may, at any time, contact any employee of the controller.

(c) Right of rectification

Each data subject shall have the right granted by the European legislator to have inaccurate personal data concerning him or her rectified by the controller without undue delay. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by adding a policy.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.

d) Right to erasure (right to be forgotten)

Each data subject shall have the right granted by the European legislator to request the controller to erase personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies if the processing is no longer necessary under the legislation:

• • The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
  • The data subject withdraws his or her consent on which the processing is based pursuant to Article 6(1)(a) or Article 9(2)(a) and there is no other legal basis for the processing;
  • The data subject objects to the processing pursuant to Article 21(1) of the General Data Protection Regulation and there are no legitimate grounds for the processing which override, or the data subject objects to the processing pursuant to Article 21(2) of that Regulation;
  • Personal data have been unlawfully processed
  • The personal data must be erased in order to comply with a legal obligation under Union or Member State law to which the controller is subject;
  • The personal data were collected in connection with the provision of information society services under Article 8(1) of the General Data Protection Regulation.

If one of the aforementioned grounds applies, and a data subject wishes to request the erasure of personal data stored by the controller, he or she may, at any time, contact any employee of the controller. The controller shall promptly ensure that the erasure request is complied with immediately.

If a controller has made personal data publicly available and is required under Article 17(1) of the General Data Protection Regulation to erase the personal data, the controller should - subject to available technology and the costs of implementation - take appropriate steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested those controllers to erase any links to, or copies or replicas of, those personal data if processing is not necessary. The controller will take the measures necessary in this case.

e) Right to restriction of processing

Each data subject shall have the right granted by the European legislator to require the controller to restrict processing where one of the following applies:

• • The accuracy of the personal data shall be contested by the data subject for a period which allows the controller to verify the accuracy of the personal data;
  • The processing is unlawful, but the data subject does not wish the personal data to be erased but requests instead that their use be restricted;
  • The controller no longer needs the personal data for processing purposes, but the data subject requires them for the establishment, exercise or defence of legal claims;
  • The data subject has objected to processing pursuant to Article 21(1) of the General Data Protection Regulation, pending verification whether the legitimate grounds of the controller override the interests of the data subject.

If one of the following conditions is met and a data subject wishes to request the restriction of the processing of personal data stored by the controller, he or she may at any time contact any employee of the controller. The controller will carry out the restriction of the processing without delay.

(f) Right to data portability

Each data subject shall have the right granted by the European legislator to obtain personal data concerning him or her which he or she has provided to a controller in a structured, commonly used and machine-readable format. He has the right to transfer those data to another controller without hindrance from the controller to whom the personal data have been provided, where the processing is based on consent in accordance with Article 6(1)(a) or Article 9(2)(a) of the General Data Protection Regulation or on a contractual obligation pursuant to Article 6(1)(b) of the General Data Protection Regulation and the processing is carried out by automated means, in so far as the processing is not necessary for the performance of a task carried out in the public interest, or

Furthermore, when exercising his or her right to data portability under Article 20(1) of the General Data Protection Regulation, the data subject shall have the right to obtain a direct transfer of personal data from one controller to another, where this is technically feasible and does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may contact the controller.

g) Right to object

Each data subject shall have the right granted by the European legislator to object, at any time and on grounds relating to his or her particular situation, to processing of personal data concerning him or her which is based on Article 6(1)(e) or (f) of the General Data Protection Regulation, including profiling based on those provisions.

The controller shall terminate the processing of personal data in the event of an objection, unless it demonstrates that there are legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims, and unless there is a contractual ground for the processing of the personal data.

Where the controller processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for this type of marketing. This includes profiling insofar as it relates to direct marketing. Where the data subject objects to the controller to processing for direct marketing purposes, the processing of personal data for those purposes shall cease.

In addition, the data subject shall have the right, on grounds relating to his or her particular situation, to object to processing by the controller of personal data concerning him or her for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the General Data Protection Regulation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact the controller. In addition, the data subject shall be free, in the context of the use of information society services and notwithstanding Directive 2002/58/EC, to exercise the right to object by automated means using technical specifications.

(h) Automated individual decision-making, including profiling

Each data subject has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects him or her, unless the decision: (1) is necessary for entering into, or the performance of, a contract between the data subject and a controller; or (2) is permitted by Union or Member State law applicable to the controller and which also provides for appropriate measures

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a controller, or (2) it is based on the data subject's explicit consent, the controller will take appropriate measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, the right to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact the controller.

(i) Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the controller.

8. Рdata protection provisions for the implementation and use of Google Analytics (with anonymisation function)

The administrator has integrated a Google Analytics component (with an anonymization function) on this website. Google Analytics is a web analytics service. Web analytics is the collection, aggregation and analysis of data relating to the behaviour of website users. The web analytics service collects, inter alia, data about the website from which the person came (also referred to as the reference site), which subpages were visited or how often and for how long a subpage was viewed. Web analytics is primarily used to optimise a website and perform cost-optimal analysis of Internet advertising.

Google Analytics is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

For web analysis via Google Analytics, the administrator uses the available Google Analytics application. Through this application, the IP address of the Internet connection of the data subject is shortened by Google and anonymised when accessing our websites from an EU Member State or another contracting state to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the data and information collected, inter alia, to evaluate the use of our website and to provide online reports that show the activities on our websites and to provide other services to us concerning the use of our website.

Google Analytics places a cookie on the IT system of the data subject. The definition of cookies is given above. By setting cookies, Google is able to analyse the use of our website. When connecting to one of the pages of this website, which is maintained by the controller and in which the Google Analytics component is integrated, the Internet browser of the data subject will automatically submit data via the Google Analytics component for the purpose of online advertising and payment of commissions to Google. During this technical procedure, the Google enterprise becomes aware of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of the visitors and their actions and, consequently, to be paid a commission.

The cookie is used to store personal information, such as time of access, location from which access was made and frequency of visits to our website by the data subject. With each visit to our website, this personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may transfer this personal data collected through the technical procedure to third parties.

The data subject may, as stated above, remove the cookie setting via our website at any time by changing the web browser they are using accordingly and thereby permanently opt-out of the cookie setting. Such a change of the Internet browser used will also prevent the setting of cookies by Google Analytics in the information technology system of the data subject. In addition, cookies that are already used by Google Analytics can be deleted at any time via a web browser or other software programs.

In addition, the data subject has the possibility to object to data collection, which is generated by Google Analytics and is related to the use of this website, as well as to the processing of this data by Google and to exclude the same. For this purpose, the data subject should download a browser add-on from the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on informs Google Analytics via JavaScript that no data and information concerning visits to the websites can be transmitted to Google Analytics. The installation of browser add-ons is considered by Google as an objection. If the data subject's IT system is later deleted, formatted, or reinstalled, then the data subject must reinstall the browser add-on to block Google Analytics. If the browser add-on is uninstalled by the data subject or any other person with the relevant competence or is blocked, then it is possible to perform a reinstallation or activation of the browser add-ons.

Further information and applicable Google data protection regulations can be found at https://policies.google.com/privacy and on https://marketingplatform.google.com/about/analytics/terms/us/Google Analytics is further explained at the following link https://marketingplatform.google.com/about/analytics/.

9. Data protection provisions for the application and use of Google Ads

Google Ads is an internet advertising service that allows an advertiser to place ads in Google search results and the Google ad network. Google Ads allows an advertiser to pre-define specific keywords, using which an ad in Google search results appears only when the user uses the search service to find a search result relevant to the keyword. In Google's advertising network (Google Network), advertisements are distributed to relevant websites using an automatic algorithm that takes into account the predefined keywords.

Google Ads is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

The purpose of Google Ads is to advertise on our website by including relevant advertising on third party sites and in search results on Google search services and to include third party advertising on our website.

If a user accesses our website via a banner ad from Google's system, their behaviour is tracked and recorded via a so-called tracking cookie. A definition and explanation of what cookies are can be found above. "The tracking cookie is valid for 30 days and is not used to identify the user. If the cookie has not expired, it is used to track the user's behavior as to whether and which subpages of our site are visited, such as the shopping cart page. Through the behaviour tracking cookie, Googleand the owner of this website can find out whether a user who visited the website via Google Ads generated a sale.  

The data and information collected through the use of tracking cookies is used by Google to create statistics on visits to our website. These visit statistics are used to determine the total number of users who have been served Ads to determine the success or failure of an Ads banner ad and optimize our Ads ads for the future. Neither our company nor other advertisers on Google Ads receive information from Google that could identify the data subject.

The tracking cookie stores personal information, e.g. websites visited by the data subject. Whenever you visit our websites, personal data, including the IP address of the Internet access used by the data subject, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may transmit this personal data collected through the technical procedure to third parties.

The data subject may, at any time, revoke the setting of cookies via our website as indicated above by adjusting the Internet browser used accordingly and thereby permanently refuse the setting of cookies. Such setting of the Internet browser used will prevent the placement of a tracking cookie by Google on the IT system of the data subject. In addition, a cookie set by Google Ads can be deleted at any time via the Internet browser or other software programs.

The data subject has the possibility to object to interest-based advertising by Google. For this reason, the data subject should access the www.google.de/settings/ads link from any browser and make the desired settings.

Further information and applicable Google data protection regulations can be found at https://policies.google.com/privacy.

10. Data protection provisions on the application and use of Facebook

The administrator has integrated enterprise Facebook (Facebook) components on this website. Facebook is a social network.

A social network is a social meeting space on the Internet, an online community that typically allows users to communicate with each other and interact in a virtual space. A social network can serve as a platform for exchanging opinions and experiences or enable the Internet community to provide personal or company information. Facebook enables social network users to include the creation of private profiles, upload photos, and build relationships through friend requests.

Facebook's service company is Meta Platforms Inc., 1 Meta Way, Menlo Park, CA 94025, United States. If a person lives outside the United States or Canada, the administrator is Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

Whenever you connect to one of the pages of this website, which is maintained by the controller and which has an integrated Facebook component (Facebook plug-ins), the data subject's web browser is automatically activated, downloads and displays information from the corresponding Facebook component of the Facebook plug-in via the same additional Facebook component. An overview of all Facebook extension modules can be found at https://developers.facebook.com/docs/plugins/. During this technical procedure, Facebook receives information that our website has been visited by the data subject.

If the data subject has registered at the same time on Facebook, each time the data subject connects to our website, Facebook identifies that the data subject has visited our page - for the entire duration of their presence on our website. This information is collected via the Facebook component and linked to the data subject's corresponding Facebook profile. If the data subject clicks on one of the Facebook icons integrated on our website, e.g. "Like", or if the data subject submits a comment, then Facebook links this information to the data subject's personal Facebook profile and stores the personal data.

Facebook always receives, via the Facebook component, information about a data subject's visit to our website when the data subject is simultaneously on Facebook at the time of connecting to our website. This takes place regardless of whether the data subject clicks on the Facebook component or not. If such a data transmission to Facebook is not desirable for the data subject, then the data subject may prevent the same by logging out of his or her Facebook account before connecting to our website.

The Data Protection Directive published by Facebook, which is available at https://facebook.com/about/privacy/, provides information about Facebook's collection, processing and use of personal data. In addition, it explains what settings options Facebook offers to protect data subject privacy. In addition, various configuration options are available to allow the elimination of data transmission to Facebook. These applications can be used by the data subject to eliminate data transmission to Facebook.

11. Provisions for data protection in the application and use of LinkedIn

The administrator has integrated components of LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and make new business contacts. LinkedIn is currently the largest business networking platform and one of the most visited websites in the world.

LinkedIn's service company is LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, California, 94085, United States. For privacy matters outside the United States of America, LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland is responsible.

Whenever you connect to one of the individual pages of this website, which is operated by the controller and which has integrated a LinkedIn component (LinkedIn extension module), the internet browser of the data subject is automatically activated to download and display a message from the corresponding LinkedIn component. Further information on the LinkedIn Extension Module can be found at https://developer.linkedin.com/product-catalog/plugins. During this technical procedure, LinkedIn acquires information that the data subject has visited our website.

If the data subject has registered at the same time on LinkedIn, each time the data subject connects to our website, LinkedIn identifies that the data subject has visited our page - for the entire duration of their presence on our website. This information is collected via the LinkedIn component and linked to the data subject's corresponding LinkedIn profile. If the data subject clicks on one of the LinkedIn icons integrated on our website, LinkedIn links this information to the personal LinkedIn profile of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject has registered on LinkedIn at the time of connecting to our website. This occurs regardless of whether the person clicks on the LinkedIn icon or not. If such a transfer of information to LinkedIn is not desired by the data subject, then the data subject can avoid this by logging out of his or her LinkedIn profile before connecting to our website.

At https://www.linkedin.com/psettings/guest-controls LinkedIn provides the ability to unsubscribe from email, SMS messages and targeted ads, as well as the ability to manage ad settings. Setting the cookies that LinkedIn uses can be done at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out?trk=microsites-frontend_legal_cookie-policy. The applicable LinkedIn privacy policy is available at https://www.linkedin.com/legal/privacy-policy. LinkedIn's cookie policy is available at https://www.linkedin.com/legal/cookie-policy.

12. Legal basis for processing

Article 6(1)(a) of the General Data Protection Regulation is the legal basis for processing operations for which we obtain consent for the purposes of specific processing. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, such as where the processing operations are necessary for the supply of goods or the provision of another service, the processing is based on Article 6(1)(b) of the GDPR. The same applies to such processing operations which are necessary for pre-contractual measures, e.g. in the case of enquiries concerning our products or services. If our company has a legal obligation under which the processing of personal data is necessary, such as for compliance with tax obligations, the processing is based on Article 6(1)(c) of the General Data Protection Regulation. In rare cases, processing may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor is injured in our company and their name, age, health insurance/insurance or other important information is passed on to a doctor, hospital or other third party. The processing would then be based on Article 6(1)(d) of the GDPR. This legal basis applies to processing operations that do not fall within the legal bases mentioned above if the processing is necessary for the legitimate interests of our company or of a third party, except if those interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data. These processing operations are in particular permissible as they are specifically mentioned by the European legislator. It has taken into account that a legitimate interest could exist if the data subject is a customer of the controller (Recital 47 sentence 2 of the General Data Protection Regulation).

13. Зthe legitimate interests of the controller or a third party

If the processing of personal data is based on Article 6(1)(f) of the General Data Protection Regulation, our legitimate interest is to carry out our activities for the benefit of our employees and shareholders.

14. Сthe year for which the personal data are stored

The criteria used to determine the retention period of personal data is the relevant statutory period. If there is none, the personal data collected shall be kept for a period of 3 years. After this period, the relevant data is deleted on an ongoing basis if it is no longer necessary for the performance or activation of a contract.

15. Provision of personal data as a legal or contractual obligation; Requirement necessary for the conclusion of a contract; Obligation of the data subject to provide personal data; Possible consequences of not providing such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. information about the contractual partner). Sometimes it may be necessary to enter into a contract for the data subject to provide us with personal data that must subsequently be processed by us. For example, the data subject is obliged to provide us with personal data when signing a contract with us. Failure to provide the personal data would result in the data subject being unable to enter into a contract. Before the data subject provides personal data he should contact an employee. The officer shall explain to the data subject whether the provision of the personal data is required by law or by contract, whether there is an obligation to provide the personal data and the consequences of not providing the personal data.

Last update: 15.09.2025