Browsing our website is done without processing your personal data. However, in some special cases (such as participating in a survey, quiz or even contest), users will have their personal data collected and processed.
In the case that personal data is necessary and there is no statutory principle available for this process, we are obliged to request consent from the aforementioned person.
Processing personal data of certain individuals – such as name, surname, address, email, phone number – shall be executed according to the Legal Regulations no. 679/27.04.2016 regarding personal protection of processing personal data and free circulation of data and revocation of 95/46/CE Directive (“Regulation”) and in accordance with the local GDPR of the operating company CTE Trailers Bulgaria Ltd.
Through this Policy, our company informs the general public about the nature, adequacy and purpose for which we collect and process personal data. Additionally, concerned individuals referred here by “data subjects” are also informed about their own rights according to the Directive. As an operator, CTE Trailers Bulgaria Ltd has implemented various technical and organizational measures in order to ensure full protection of personal data.
The present Policy is based on the present Regulations, as well as on all the applicable laws regarding private data protection. The Policy has to be accessible to the general public and also, our business partners. In order to ensure this, we shall further explain the terms used. In this Policy, we shall use, inter alia, the following terms:
Personal Data refers to any information that makes possible the pinpointing of a physical person (the person in question).
The Person in question – they represent the identifiable or non-identifiable physical person. An identifiable physical person is a person that can be identified directly or indirectly, especially through a serial number or any other factors pertaining to their physical, physiological, mental, economic, cultural or social identity.
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated 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.
Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.
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 that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information 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.
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 processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. 2However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
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 controller CTE Trailers Bulgaria Ltd
3. The Controller’s email
Any person in question is able to contact us directly at anytime with questions or suggestions regarding personal data processing at the following email address: – email@example.com
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
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Your consent applies to the following domains: ctetrailers.bg
5. The data subject’s rights
The access right of the data subject. As far as access rights are concerned, the data subject may contact CTE Trailers Bulgaria Ltd at any given time with requests for generating a personal data report.
Right of rectification. The data subject shall have the right to obtain from the controller without any delay, the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure. Every data subject has the right to request erasing personal data as follows:
i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
ii) the data subject withdraws consent on which the processing is based;
iii) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
iv) the personal data have been unlawfully processed or have been erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
Right to restriction of processing. Every data subject has the right to processing restriction as follows:
i) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
ii) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
iii) CTE Trailers Bulgaria Ltd no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
Right to data portability. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided.
Right to object. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. CTE Trailers Bulgaria Ltd shall no longer process the personal data unless the controller demonstrates compelling 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. Where personal data are processed 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 such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Automated individual decision-making, including profiling. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. CTE Trailers Bulgaria Ltd shall implement suitable 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 CTE Trailers Bulgaria Ltd, to express his or her point of view and to contest the decision.
Right to withdraw consent. Every data subject has the right to withdraw consent when it comes to consent for personal data processing at any given time.
Right to file a complaint to authorities – in the extreme case that the data subject feels that their legitimate rights of personal data processing have been breached, they can file a complaint to Information Commissioner’s Office with headquarters on 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Е-mail: firstname.lastname@example.org, website https://www.cpdp.bg/.
If you would like to exercise your rights or send in a notification/request, please contact us at the address supplied in the present Policy. CTE Trailers Bulgaria Ltd will get back to you shortly but no later than 30 days. For any potential delays, we will let you know and provide you with justifiable reasons.
6. Signing up for our Newsletters
On the https://ctetrailers.bg website, users are given the chance to sign up for the company’s newsletter. CTE Trailers Bulgaria Ltd keeps their clients and business partners regularly informed through a newsletter describing the company’s offers. The newsletter may be received only if the data subject:
- has a valid email address and
- if the data subject registers for the newsletter reception.
A confirmation email will be sent to the email address registered by the data subject for the first time for legal reasons through the double opt-in process. This confirmation email is used to prove if the email address possessor is authorised to receive the newsletter.
Throughout the process of signing up for the newsletter, we store the internet and data subject IP used at the moment of registration as well as the date and time. Collecting this data is necessary for the purpose of understanding the possible unruly uses of a data subject at a later time which is why legal protection is ensured.
The newsletter collection data will be used only to send in the newsletter. Additionally, each and every user registered for the newsletter will be informed by email as long as this option is necessary for the newsletter service or in the event of any changes to the newsletter structure or even technical aspects.
There will be no transfer of personal data collected by the newsletter service by a third party. Our newsletter subscriptions can be cancelled at any given time. Consent to store personal data given by the data subject for receiving the newsletter can be withdrawn at any moment. In every newsletter, there is a link for cancelling the subscription. Upon unsubscribing, all data shall be erased from CTE Trailers Bulgaria Ltd’s database.
As follow-up of newsletter subscription, the data subject is informed about being able to freely exercise the right to information, access, restriction, rectification, erasure, data portability (if such is the case), opposition, refusal of an individual for a pre-set decisional process, the right to file a legal complaint to court or to ANSPDCP either physical or by email at: email@example.com Withdrawing consent at any given time will not affect the legal aspect of data processing before withdrawal.
7. Possibility of contract through website
The https://ctetrailers.bg website contains info that allow a brief electronic contract with our company as well as direct communication with us by including a general email address.
If a data subject contacts us through email or the contact application, the provided personal data will be customarily stored. Such personal data, sent by a data subject voluntarily are stored for the purpose of processing and contacting the person in question.
Data shall be kept by the controller for a maximum duration of 3 years starting from the moment email contact is initiated. By the end of the restriction period, data shall be erased from the controller’s database and of the individuals with power of attorney (if such is the case).
As a result of registration for follow-up, the data subject agrees to freely express their right to information, access, restriction, rectification, erasure, the right to data portability (if such is the case), opposition, refusal of an individual for a pre-set decisional process, the right to file a legal complaint to court or to ANSPDCP either physical or by email at: firstname.lastname@example.org. Withdrawing consent at any given time will not affect the legal aspect of data processing before withdrawal.
8. Regular erasure and blocking of personal data
CTE Trailers Bulgaria Ltd will process and store the data subject’s personal info only during the necessary period of time in order to fulfill storage purpose or during the period of time established by European laws or other applicable laws. If storage purpose is not applicable or if the legal storage period expires, personal data is erased in accordance with the specific legal requests.
9. Legal processing requirements
Art. 6 I lit. a GDPR serves as legal basis for our company for processing transactions during which we obtain consent for a certain processing purpose.
Art. 6 I lit. a GDPR serves as legal basis for our company for processing transactions during which we obtain consent for a certain processing purpose. Where processing personal data is used to fulfill contractual duties with the contractual party being the data subject, as is the case during processing transactions, for example, which are required for the delivery of goods or the provision of any other service or return service, such processing is based on Art. 6 I lit. b GDPR. This shall also apply for processing transactions required for the performance of pre-contractual measures, for example in the context of inquiries about our products or services. Where our company is subject to a legal obligation which requires processing of personal data, such as for the performance of tax obligations, such processing is based on Art. 6 I lit. c GDPR. In rare cases, the processing of personal data may be required in order to protect the vital interests of the data subjects or any other natural persons. This would be the case, for example, if a visitor were to be injured on the premises of our company and would have to pass on the name, age, health insurance data or other vital information to a doctor, hospital or any other third party. In such a case, the process would be based on Art. 6 I lit. d GDPR. Finally, processing transactions may be based on Art. 6 I lit. f GDPR. Processing transactions based on this legal foundation are those not included in any other previously mentioned legal bases or if the processing is required to maintain a legitimate interest of our company or of a third party as long as the interests, basic rights and freedoms of the data subject do not outweigh such interests. We are particularly entitled to such processing transactions as they were particularly mentioned by the European legislature which is of the opinion that interests can be considered as legitimate if the data subject is a customer of the controller (Recital 47 Clause 2 GDPR).
10. Legitimate interests of the controller or third party
In the event that processing personal data is based on Art. 6 I lit. – f, our legitimate interest is to unfold our business in favor of our employees and business partners.
11. Duration of Data Strategy
We store your personal data according to respective legal retention periods. We routinely delete the corresponding data after these periods expire, provided that it is no longer necessary for the performance or initiation of a contract.
If the storage purpose ceases to apply, or if a compulsory storage period by European Union or national law expires, the personal data is routinely blocked or deleted in compliance with statutory provisions.
12. Contractual necessity as a lawful basis for processing
The second legal ground for lawful processing as mentioned in GDPR Article 6 is the necessity of personal data processing for a contract.
A natural person or data subject is a party in a contract or has to take steps in order to enter a contract, at his or her request, and in order to enter a contract or perform a contract, it is needed and agreed that personal data processing happens within this contractual scope. This isn’t really new in comparison with the Directive that is replaced by the GDPR.
CTE Trailers Bulgaria Ltd applies an internal framework of minimal policies and standards with regards to GDPR. These policies and standards are periodically analysed in order to comply with regulations and market evolution. In accordance with legal dispositions, we take appropriate technical and structural measures (policies, procedures, security etc.) especially to ensure confidentiality and data integrity as well as providing the necessary framework for processing said data.