PRIVACY POLICY

In ZLATNA PANEGA CEMENT AD

WE TAKE CARE OF YOUR PERSONAL DATA

Who are we?

Identification of the personal data controller and personal data officer in ZLATNA PANEGA CEMENT AD.

ZLATNA PANEGA CEMENT AD is a commercial company, registered in the Commercial Register at the Registry Agency with UIC 820162213, having its seat and registered addressat:Zlatna Panega village 5760, Lovech Region, Yablanitsa Municipality, 1 Shipka Street, tel. 02 8820100; email:site_admin@titan.bg,and is personal data controller within the meaning of the Personal Data Protection Act.

How to contact us?

Address: Zlatna Panega village 5760, Lovech Region, Yablanitsa Municipality, 1 Shipka Street, tel. 02 8820101; email:zlatnapanega@titan.bg

ZLATNA PANEGA CEMENT AD respects the privacy of your personal data

The protection of your personal data throughout the entire process of personal data processing, as well as the security of all business data, is important for us. We process the personal data collected at your visitofour website, in privacy and in accordance with the national and European laws.

The protection of data and security of information are part of our corporate policy.

Privacy Policy and Confidentiality Statement

This Privacy Policy aims to provide you with exhaustive information in clear and plain language about what actions are performed with the personal data you provide to ZLATNA PANEGA CEMENT AD, including:

- What personal data do we collect for you?

- What is the purpose of their collecting?

- What term do we keep the provided personal data for?

- With whom we share your personal data?

- How do we inform you about changes to our Privacy Policy?

- What types of “cookies” do we use to make your stay at our website better?

- What are your rights regarding the provided data?

With this Privacy Policy, ZLATNA PANEGA CEMENT AD declares that the company applies all technical and organizational measures forprotectionof the personal data of the natural persons, as established by law or other national or European legislative act.

What is personal data?

All information and data that might identify an individual directly or indirectly.

For instance, indirect identifying is the number of your mobile phone. Direct identification is achieved, when you provide a unique number, such as your PIN, personal number of a foreigner, client’s code, etc.

-What personal dataZLATNA PANEGA CEMENT AD collects for you?

In order to provide effective access to our products/services, ZLATNA PANEGA CEMENT AD collects the following information for you:

- Name, family name, phone number, e-mail, organization, city/country, address, etc., upon filling-in of the various forms at our website, including creating of initial registration, subscription for our bulletin, filling-in of form for opinions and/or comments;

- Technical data automatically sent to us, when you use our website - IP address, information for the device from which you visit the website;

- Cookies - for identifying the browser or your device.

On what groundZLATNA PANEGA CEMENT ADprocesses your personal data?

The processing of personal data includes collection, keeping, transfer, correcting, updating, deletion, destruction and all other actions performed with your personal data.

ZLATNA PANEGA CEMENT AD collects your personal data in order to fulfill its contractual obligations under contracts concluded with you for the provision of services – oncontractualground.

ZLATNA PANEGA CEMENT AD collects personal data upon receipt of explicit, clear, free and unambiguous consent from you for the purposes of processing. For instance for marketing purposes or receipt of advertisement bulletins.

Consent for processing of your personal data may be given at a visit onplacein our office or at the registration on our website.

The consent you provide may be withdrawn at any time if you visit one of our offices or through your profile on our website.

ZLATNA PANEGA CEMENT AD processes personal data also in fulfilment of its legal obligations, if this is necessary in order to protect the vital interests of the data subject or of another natural person for whom the personal data refers.

ZLATNA PANEGA CEMENT AD process personal data also in event it has legal (legitimate) interests, unless where such interests are overridden by the interests of the data subject which require protection of personal data.

What purposes do we collect your personal data for?

The personal data obtained from you shall be used to enable usfulfill your requirements towards you, as well as to support thefulfilmentof your rights, including, but not limited, to:

- Provide you the services/products we offer;

- Ensure you access to our webpage, where for the purpose we display content, which is relevant, personalized and limited to the criteria posed by you;

- Respond to your queries, opinionsandrecommendations;

- Send you information related to special campaigns or new products or services of ours.

In addition to the above, we have legal interest to collect your personal data, because without it we may not provide you with the service(s) or products(s) you are interested about.

How we process your personal data?

To provide you with products and services ZLATNA PANEGA CEMENT AD processes (collects) the data you provide regarding physical, economic, social and family identity in the following ways:

- Through filling-in by you of applications, forms and statements, provided to you by officers of ZLATNA PANEGA CEMENT AD. Such forms are filled-in in our offices or in external workplaces, ineventyou file a request for rendering of services;

-Through visit of the web-portal for use of electronic services;

- Upon updating of data at your request and filing of form for update on paper or electronically;

- Through processing of information for your visits in the web-portals of ZLATNA PANEGA CEMENT AD, including in the sections for queries and contacts;

- Through processing of information of IP addresses, “cookies”, operational system and browser type.

How long we keep and process your personal data before we destroy them?

Depending on the ground we process your personal data, the term of their keeping differs.

Your personal data are kept with us for a term of 6 years upon dropping of the contractual ground if we process forfulfillmentof contractual obligations towards you. Upon expiry of this term and if no other legal ground for extending the keeping of your personal data exists, the information shall be destroyed. From our system permanently shall be deleted the records for you, as well as destroyed all paper files, containing your personal data.

To whom we may transfer the personal data provided by you?

ZLATNA PANEGA CEMENT AD obliges not to provide your personal data to third parties without your explicit consent, unless when necessary for the fulfillment of undertaken contractual relations towards you.

For the fulfillment of undertaken contractual relations or pre-contractual relations towards you, ZLATNA PANEGA CEMENT AD might disclose your personal data to the following persons:

- Companies rendering courier services;

- The company rendering hosting services related to this website;

ZLATNA PANEGA CEMENT ADhas right to disclose and transfer your personal data to companies part of the TITAN Cement Group, situated on the territory of Greece to the extent there is a legitimate interest, connected with the processing of your personal data for internal administrative purposes. Such transfer, as well as any other transfer, shall be made in strict observance of confidentiality and security of your personal data.

Are there any other events in which we may share your personal data?

Your personal data may be provided to third parties in the following events:

- Upon request of the natural person who has given the data, subject of the personal data protection;

- Upon request of competent authorities according to the applicable legislation of Bulgaria or the European Union.

In all above-pointed events, the persons to whom we provide your personal data shall have declared that they ensure an adequate level of protection of your personal data, including the foreign companies, situated in the EU or EEA. As regards companies, situated outside EU and EEA, for each specific case, the respective company shall guarantee that renders the adequate level of protection of the personal data, observing the requirements of the European legislation.

Use of “Cookies”

General Terms

The “Cookies” are small text files, which are recorded on your computer when you visit our website. Ineventyou have access to the said website inother moment, your browser sends back the content of the “cookies” to the respective inquirer and in this way allows repeated identifying of the terminal device. The reading of “cookies” allows us to design our webpage optimally for you and facilitates you in its use.

Deactivation and Deletion of “Cookies”

Your browser allows you to delete all “cookies” at any time. To do this, please refer to the “help” functions of your browser. This might render some functions on our website not be accessible for you.

Generaloverview of the Cookies we use

In this section, you will findgeneraloverview of the “Cookies” we use.

Absolutely necessary cookies

Some “cookies” are necessary, in order to be able to provide securely our services through the website. This category includes for instance:

– “Cookies” that identify orattestour users;

– “Cookies” temporary storing certain user data (such ascontentof online application form);

– “Cookies” storing certain user preferences (for instance search adjustments or language adjustments);

– “Cookies” storing data forensuingof unimpeded displaying of audio or video content.

Analytical “Cookies”

We use analytical “Cookies”, in order to register thebehaviourof the users (for instance clicking over advertisement banners, inserted search requests) and to evaluate statistically these actions.

Advertisement “Cookies”

We use “cookies” also for advertisement purposes. The users’ behaviour profiles created with the help of such “cookies” (for instance clicking on advertisement banners, visited sub-pages, inserted search request) are used by us to show you advertisements or offers, which are considered with your interests (“advertisement based on individual interest”).

Advertisement “Cookies” of third parties

We let also other companies evaluate data of our users through advertisement “Cookies”. This allows us and third parties to display to the users of our website advertisement, based on interests, which in their turn are based on the analyses of your behaviour (for instance clicking on advertisement banners, visited sub-pages, inserted search request), where this is not limited only to our online offers.

“Cookies” at Redirecting

Our partners for tracking of redirections pose “cookies” on your computer (“Cookie at Redirecting”) ineventyou have reached our website through advertisement of the respective partner. These cookies usually expire validity within 30 days. Ineventyou visit certain pages, which we host, and the “cookie has not expired, we and the respective partner for tracking may see that a specific user has clicked on the advertisement and is redirected to our website. The information collected through the “cookies” for redirecting is used for creating of statistical data for the redirection and determining the total number of users, who have clicked on the respective advertisement and are redirected to a page, havingmarkerfor tracing the redirections.

Web Analyses

We need statistical information for the use of our website, in order to make it more accessible, to perform measurements of the scope and to make marketresearches.

For this purposes, we use the instruments for web analyses, described in this section.

The users’ profiles, created with these instruments, with the help of analytical “cookies” or through evaluation of log files, do not contain personal data. The instruments either do not use the IP addresses of the users at all, or they shorten them immediately after collecting.

The suppliers of instruments process the data only as processors of personal data in accordance with our instructions, and not for own purposes.

Below you will find information about each supplier of instrument and how you may object to the collecting and processing of personal data through the instrument.

You should have in mind that in the instruments that use “cookies” for rejecting, the function for rejecting is connected with the device or the browser and is therefore valid for the user in the moment end device or browser. If you are using several end devices or browsers, you should choose the function for rejecting of each end device and each used browser.

Besides, in general, you may prevent the creation of user profiles by the deactivating the use of “cookies”.

Google Analytics

Google Analytics is offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). We use Google Analytics with the offered by Google additional function for anonymizing of the IP addresses. Google shortens the IP address already in the frames of EU and only in exceptional cases in USA, where in both cases records only the shorten IP addresses.

You may object to the collection and processing of your data, by downloading and installing appliance forbrowserat the following link:http://tools.google.com/dlpage/gaoptout?hl=en

What are your rights regarding the provided data?

In observance of the Bulgarian and European legislation, including Regulation (EU) 2016/679 of EU and EEA (General Data Projection Regulation – GDPR) regarding the protection of personal data, you may exercise the following rights:

- Right of access to personal data, which ZLATNA PANEGA CEMENT AD processes for you and to receive a copy of it;

- Right to request from ZLATNA PANEGA CEMENT AD correcting in event you establish irregularities or necessity of updating of your personal data, by sendinge-mailatsite_admin@titan.bg;

- Right to request blocking of your personal data or limiting the processing of personal data, in the occasions, determined in the law and the Regulation;

- Right to request deletion of your personal data by ZLATNA PANEGA CEMENT AD,in event there are conditions for this;

- Right to object to the processing of your personal data for the purposes of direct marketing by using the link “unsubscribe”, which we have placed in each e-mail sent to you and containing advertisement information for our products;

- Right to object to the provision of your personal data to third persons, by entering into personal profile on our webpage and removing the tick concerning the provision of personal data to third persons;

- Right, whenever you wish, to withdraw the consent given by you your personal data to be processed for the purposes for which the consent was given, for instance for marketing purposes, by sending an e-mail at site_admin@titan.bg;

- Right to make a request for portability of your personal data in structured, machine-readable manner, which is commonly used;

- Right to file complaint or application for protection of your rights before the Commission for Personal Data Protection in event there are pre-requisites for this.

You may exercise all rights at any time during the processing of your personal data.

What each of the above rights means?

Right of access to personal data

This right provides you with possibility to obtain information regarding the data that identify the controller and its representative, the purposes of personal data processing, the recipients or categories recipients, to whom the data may be disclosed, data about the obligatory or voluntary nature of providing the data and the consequences of the refusal for their provision, as well as information for the right of access and the right of correction of the collected data.

The data shall not be provided when the natural person they refer to already disposes with it or there is a legal ban for their provision.

Right of erasure, access, rectification, restriction of processing

Right to demand from the controller at any time to erase, correct or restrict, personal data, the processing of which does not respond to the requirements of the Personal Data Protection Act, as well as right to demand from the controller to inform the third parties, to whom personal data was disclosed for each erasure, rectification or restriction that has been performed, excluding the events when this is impossible or is connected with excessive efforts.

Right to object

Right to object to the controller against the processing of personal data of the individual in the existence of legal ground for this, as well as against the processing and disclosing to third persons of your personal data for the purposes of direct marketing. You have the right to be informed before your personal data is disclosed for the first time to third persons or used on their name for direct marketing purposes, as you have right to object against such disclosure or usage.

Right to data portability

When the processing of personal data is made by automated means, you have right to receive the personal data referring to you, which you have provided to the controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.

This right should apply when the subject has provided personal data on the grounds of own consent or the processing is needed because of contractual obligation. The right should not apply when the processing is based on the legal ground different from consent or contract. Because of its own nature, this right should not be applied as regards controllers who process personal data in fulfillment of their public obligations. That’s’ why this right should not apply when the processing of personal data is necessary for observance of legal obligation, to which the controller is subjected or for the fulfilment of task carried out in the public interest or in the exercise of official authority vested in the controller. The right of the data subject to transmit or receive pertaining to him/her personal data does not create obligation or the data controllers to perceive or maintain technically compatible systems for processing. When in certain package of personal data more than one data subject is affected, the right personal data to be received should not affect the rights and freedoms of other data subjects in accordance with the applicable law.

Right to file complaint or application before the Personal Data Protection Commission

In event your rights are violated you have right to approach the Personal Data Protection Commission within a term of one year upon becoming aware of the violation, but not longer than five years after committing. When your rights are violated you have right to appeal actions and acts of the controller before courts, including before the Supreme Administrative Court. The court may not be approached, if there is pending procedure before the Personal Data Protection Commission or decision of the Commission for the same violation is appealed and there is no entered into force decision of the court.

Changes to the Privacy Policy

For all amendments made to this Privacy Policy, we shall inform you with letter sent by electronic means (e-mail) to the e-mail address provided by you.

In this way you will be provided with possibility to discontinue the use of some or all services and/or make use of your rights, part of them being explicitly pointed above. In addition we shall take all possible measures for informing you in event of changes concerning the personal data protection by placing notices in the offices and the web-portals of ZLATNA PANEGA CEMENT AD.

This Privacy Policy is approved by ZLATNA PANEGA CEMENT AD and is in force from 25th May 2018.

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