Privacy Policy

PRIVACY POLICY OF JSIC OZK-INSURANCE AD FOR THE PROTECTION OF PERSONAL DATA OF NATURAL PERSONS

This Policy (the Policy) sets out the terms and conditions under which individuals whose personal data is processed by JSIC OZK-Insurance AD (OZK) may exercise their rights under the Personal Data Protection Regulations.

I. GENERAL PRINCIPLES

1. Personal data shall be processed lawfully and in good faith.
2. Personal data shall be collected for specific, clearly defined and lawful purposes and shall not be further processed in a manner incompatible with those purposes.
3. Personal data collected and processed in the course of human resources management shall be relevant, related to and not excessive in relation to the purposes for which they are processed.
4. Personal data shall be accurate and, where necessary, kept up to date.
5. Personal data shall be erased or rectified when it is found to be inaccurate or disproportionate in relation to the purposes for which it is processed.
6. Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

1. Right of access;
2. Right to rectification;
3. Right to data portability;
4. Right to erasure (right to be forgotten);
5. Right to request restriction of processing;
6. Right to object to the processing of personal data;
7. Right of the data subject not to be subject to a decision based solely on automated processing, including profiling.

4. Upon request, OZK shall provide the data subject with the following information:

1. confirmation whether OZK processes the personal data of the person or not;
2. a copy of the personal data of the person processed by OZK and an explanation regarding the processed data.

1. the purposes of the processing;
2. the categories of personal data concerned;
3. 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 organizations;
4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
5. the existence of the right to request rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing;
6. the right to lodge a complaint with a supervisory authority;
7. where the personal data are not collected from the data subject, any available information as to their source;
8. the existence of automated decision-making, including profiling, and information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject;
9. where personal data are transferred to a third country or to an international organisation, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.

1. personal data of third parties, unless they have given their express consent to this;
2. data that constitutes a trade secret, intellectual property, or confidential information;
3. other information that is protected under applicable law.

Right to rectification

13. Data subjects may request that their personal data processed by OZK be corrected if it is inaccurate or incomplete.

Right to erasure (right to be forgotten)

15. Upon request, OZK is obliged to delete personal data if any of the following grounds exist:

1. the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
2. the data subject withdraws their consent on which the processing is based and there is no other legal ground for the processing;
3. the data subject objects to the processing and there are no overriding legitimate grounds for the processing;
4. the data subject objects to the processing of personal data for direct marketing purposes;
5. the personal data has been unlawfully processed;
6. the personal data must be erased in order to comply with a legal obligation of OZK;
7. the personal data has been collected in relation to the offering of information society services to children within the meaning of Article 8(1) of Regulation (EU) 2016/679.

1. for exercising the right to freedom of expression and the right to information;
2. for complying with a legal obligation of OZK;
3. for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3) of Regulation (EU) 2016/679;
4. for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) of Regulation (EU) 2016/679 in so far as the right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
5. for the establishment, exercise, or defense of legal claims

Right to restriction of processing

17. The data subject shall have the right to obtain restriction of processing where one of the following applies:

1. 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;
2. the processing is unlawful, but the data subject does not want the personal data to be erased and requests instead that its use be restricted;
3. the controller 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 defense of legal claims;
4. the data subject has objected to the processing on the basis of the legitimate interest of OZK and an assessment is ongoing as to whether the legitimate grounds of the controller override the interests of the data subject;

1. for data storage
2. with the consent of the data subject;
3. for the establishment, exercise, or defense of legal claims;
4. to protect the rights of another natural person;
5. or for important reasons of public interest.

19. When the data subject has requested restriction of processing and any of the grounds under Article 17 apply, OZK shall inform the data subject before lifting the restriction on processing.

Right to data portability

20. The data subject has the right to receive the personal data concerning him or her, which he or she has provided to OZK, in a structured, commonly used, and machine-readable format.

1. the processing is based on the consent of the data subject;
2. the processing is based on a contractual obligation;
3. the processing is carried out by automated means.

Right to object

24. The data subject has the right to object to the processing of his or her personal data by OZK if the data is processed on one of the following grounds:

1. the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
2. the processing is necessary for the purposes of the legitimate interests pursued by OZK or by a third party;
3. the processing involves profiling.

III. PROCEDURE FOR EXERCISING THE RIGHTS OF DATA SUBJECTS

30. Data subjects may exercise their rights under these Rules by submitting a request to exercise the relevant right.

1. By email to the following email address: headoffice@ozk.bg
2. In person at the OZK offices
3. By post to the address of the OZK Central Administration: 7, Sveta Sofia Street, 1000 Sofia City

32. The request to exercise personal data rights should contain the following information:

1. Identification of the person – name and personal identification number and, depending on the nature of the relationship, policy number/ client number/claim number.
2. Contact details for feedback – address, telephone number, email address
3. Request – description of the request

33. OZK shall provide information on the actions taken in connection with a request to exercise the rights of data subjects within one month of receiving the request.

IV. DEFINITIONS