1. Details of the personal data controller
United Milk Company EAD, registered with the Commercial Registry at the Subscription Agency, UIC 121673766, having its registered seat and address of management at 3 Dunav Blvd., North District, Plovdiv 4003, is a 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 natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter the “Regulation”) and the Bulgarian Personal Data Protection Act (hereinafter the “PDPA”).
The website http://www.vereya.bg is owned and managed by United Milk Company EAD in full compliance with the Regulation and the PDPA.
Contact details of data controller
The present Policy aims to provide information about the principles and the way in which United Milk Company EAD, acting in the capacity of data controller, processes personal data of users of the website of the company as well as of the national consumers telephone line, the type of processed personal data, as well as the rights of the personal data subjects. The present Policy, inter alia, is adopted and published in fulfillment of the obligations of United Milk Company EAD under Art.13 and Art.14 of the Regulation.
Should you have any questions or you need additional information in relation to your personal data, rights, and privacy, please contact United Milk Company EAD using the contact details, indicated in item 1 above.
3. Principles of processing. Legal grounds
Personal data protection is a priority of United Milk Company EAD. United Milk Company EAD does not sell personal data collected by it, to any third parties, neither processes nor discloses such personal data to third parties without legal basis within the meaning of the Regulation and PDPA. United Milk Company EAD processes and discloses personal data to third parties only upon proper legal basis, including explicit and voluntary provided consent by virtue of the Regulation and/or on other legal basis for processing, provided in the Regulation and the PDPA. It is possible that under a law or in case of a court/arbitral/enforcement/security proceedings and/or upon request of a competent authority United Milk Company EAD discloses personal data, as well as in case that such disclosure is needed for the purposes of national security, law enforcement or other cases provided for in the law.
United Milk Company EAD may also disclose personal data when such disclosure is reasonably necessary for protecting United Milk Company EAD’s legitimate interests. It is possible as well, in case of transformation or sale of the whole or part of the company, United Milk Company EAD to transfer collected personal data to the respective newly established/transformed company or company – legal successor.
United Milk Company EAD processes personal data in strict compliance with the principle of minimization of the data processed whereby data is processed only for specific, reasonable and legitimate purposes (need-to-know principle).
4. Personal data
Personal data means any information relating to an identified natural person or natural person that is identifiable on the basis of such information.
5. Data processing purposes
United Milk Company EAD collects and processes personal data, which are necessary for carrying out of its activity. United Milk Company EAD processes personal data of users of the website and of the national consumer’s telephone line of the company, when an inquiry, claim, complaint, appeal or other signal has been submitted by user through the website contact form, by email or by telephone. The purpose of processing of personal data is:
- United Milk Company EAD to respond as well as to undertake actions with regard to the submitted inquiry, claim, complaint, appeal or other signal;
- United Milk Company EAD to maintain records with regard to the submitted inquiries, claims, complaints, appeals or other signals by users, including for the purposes of control and supervision by public authorities and the respective administrative procedures.
In case of submission of inquiries, claims, complaints, appeals or other signals by users through the national consumer’s telephone line, United Milk Company EAD may record the conversation for the purposes, indicated herein above, as well as for improvement of the quality of service. United Milk Company EAD informs the users for the recording of the conversation through and automatic message prior to connecting the user with an operator.
Upon user’s consent, or in cases when it is permitted by law, United Milk Company EAD may use the personal data of users, namely email address and names, for marketing purposes, which include contacting the user for provision of information, news and offers. Such consent may be revoked at any time by the users, through the functionality (link) provided for in each marketing email.
6. Categories of processed personal data
United Milk Company EAD processes the following categories of personal data from the following data subjects – users of the website as well of the national consumer’s telephone line of the company:
- For natural persons, who have submitted an inquiry, claim, complaint, appeal or other signal, United Milk Company EAD processes the personal data, which have been voluntary submitted by the data subject through the contact form, the telephone conversation, the email or other type of correspondence with the company (thus having granted consent for their processing). The company requires from the user names, phone and contact address as a minimum for carrying out of checkup and preparation of response to the user.
When users send inquiry, claim, complaint, appeal or other signal to United Milk Company EAD through the contact form at the website or through e-mail, or through the national consumer’s telephone line, then it is presumed that the users have given their free, explicit and informed consent for processing of the personal data which is voluntarily included by them in the respective inquiry, claim, complaint, appeal or other signal.
Cookies are small files with information sent from the web server and stored in the user's Internet browser (for example, information on the selected language, connection time, visited websites) or on the hard drive, and then returned from the Internet browser to the server whenever access to this server is obtained by visiting the relevant website.
United Milk Company EAD 's website may use both First Party Cookies of United Milk Company EAD and Third-Party Cookies, these latter being used for the purposes of advertising. United Milk Company EAD 's website may use from time to time some or all of the following types of First Party Cookies:
- Strictly Necessary Cookies
A Cookie falls into this category if it is essential to the operation of United Milk Company EAD 's website, supporting functions such as logging in and/or requests submitting.
- Analytics and Targeting Cookies
It is important for United Milk Company EAD to understand how users use the website, for example, how efficiently users are able to navigate around it, and what features they use. These Cookies enable United Milk Company EAD to gather this information, helping to improve the website and the users’ experience of it.
- Functionality Cookies
Functionality Cookies enable United Milk Company EAD to provide additional functions on the website, such as personalization and remembering saved preferences.
Any of the above types of cookies may be a persistent cookie. Persistent cookies are those which remain on the computer or device for a predetermined period and are activated each time the user visits the website. Any of the above types of cookies may be a session cookie. Session cookies are temporary and only remain on the computer or device until the browser is closed. Session cookies are deleted when the browser is closed. Cookies on United Milk Company EAD 's website are not permanent and will expire after expiration of 1 (one) month, except for the following Cookies:
- Cookies from the cookie address bar, which could be stored for a period of up to 3 years; and
- Cookies for the purposes of Google Analytics, which could be stored for a period of up to 2 years according to the functionalities, rules and policies of Google Analytics.
Every user may disable in his/her Internet browser the storing of cookies, as well as may delete the already stored cookies at any moment. Every user who wishes to proceed that way shall make the necessary changes in the settings of his/her browser and/or shall contact the browser’s provider for assistance.
United Milk Company EAD shall not be liable and shall be held harmless in case that the Internet browser used by the user does not allow to control the enabling/disabling of cookies, their blocking or the deletion of already stored cookies. If the user disables the cookies or deletes the already stored ones, then it is possible that the normal functioning of the website is technically disrupted for that user.
8. Security measures
United Milk Company EAD takes sufficient technical and organizational measures to protect the personal data it processes from theft, misuse, unauthorized access, unauthorized disclosure, unauthorized deletion and any other unauthorized processing or disposal with such data.
All representatives and employees of United Milk Company EAD, as well as all counterparties of the company, are obliged to keep confidentiality as well as to apply strictly the applicable laws in the field of personal data protection.
When users submit an inquiry, claim, complaint, appeal or other signal to United Milk Company EAD through the contact form at the website or through e-mail, or through the national consumer’s telephone line, United Milk Company EAD may provide the personal data of such users to: 1) employees from the Quality Assurance Department and the Marketing Department of the company; 2) company’s employees on management positions, namely Production Department director, Commercial Department director, Logistic Department director, regional commercial managers, as the case may be; 3) external consultants of the company with regard to protection of its legitimate interests; 4) public authorities in case of exercising of their functions as well as for the purposes of the respective procedures before such authorities.
In the cases where United Milk Company EAD provides personal data to third parties, United Milk Company EAD applies mechanisms, including inter alia contractual ones, which guarantee that such data is processed and protected in compliance with the applicable laws.
9. Time limits for storing of data
United Milk Company EAD complies with the principle of storing data only for the time necessary for completing the purpose for which such data has been collected, unless the applicable laws require a longer storage period for such data.
United Milk Company EAD deletes and erases personal data related to submitted inquiries, claims, complaints, appeals or other signals with regard to company’s products immediately after expiry of the statutory time limits for investigations by administrative authorities, for imposition of legal sanctions for infringements of the law, including consumers protection and competition protection laws, as well as for submission of legal (court or out of court) consumers’ claims against the company.
United Milk Company EAD deletes and erases personal data related to submitted inquiries with regard to company’s products not later than upon expiration of 6 months after completion of the correspondence with the user under the respective inquiry.
10. Personal data rights
Pursuant to the Regulation and the PDPA data subjects have the following rights at all times: (1) right of access to their personal data processed by United Milk Company EAD; (2) right of rectification of incorrect personal data, right of erasure (in case there is proper legal basis for that), right to restriction and blocking of processing of personal data processed by United Milk Company EAD (in case there is proper legal basis for that); (3) right to data portability under the conditions provided for in the Regulation; (4) right to object at any time to the processing of their personal data, as well as right to withdraw their consent for processing of personal data, without prejudice to legitimacy of the processing prior to such withdrawal, when there is proper legal basis for that; (5) right to file a complaint with the Bulgarian Personal Data Protection Commission in case where the data subject considers that his/her rights related to data protection have been breached.
United Milk Company EAD may refuse to grant requests for exercising of rights on a grounds provided for in the Regulation and/or the PDPA, including in case of unreasonably repeating requests, requests that require unproportionate efforts and/or costs for the controller, as well as when the respective request is manifestly unfounded or when such request puts in danger or breaches the confidentiality and rights of other data subjects.
11. Entry into force and updates
This Policy enters into force on 25/05/2018. United Milk Company EAD may amend and update the present Policy, provided that each amendment/update should be published on the website of the company, whereas United Milk Company EAD may undertake upon its discretion other actions for notifying the users of such amendments/updates in the Policy.