For the processing of your personal data, the controller is Aurubis Bulgaria AD, a joint stock company, registered in the Company Register with the Registry Agency under uniform ID code 832046871, having its registered seat and management address in:
Aurubis Bulgaria is represented by Tim Kurth – Executive Director.
Contact details of the Data Protection Officer
Data Protection Officer, Security and Risk Management Department, Aurubis Bulgaria AD, Industrial Zone, 2070 Pirdop
Phone: +359 7286 2280
Fax: +359 7286 2646
Collection and processing of personal data of shareholders in Aurubis Bulgaria AD
When issuing an access card, as part of the security and safety measures, review and transfer of the personal data from the identity document is performed, via reader, into the access control system, or the personal data is entered manually into the system. We collect and process the following data:
Video Surveillance – on the territory of the company are located cameras for 24-hour video surveillance designed for security and operational purposes; on the entrances of the company are located cameras for 24-hour body temperature measurement that aim is to prevent epidemic/ pandemic disease spreading.
Other personal data:
· Information for current bank account.
The processing of personal data in p. III (1-3) is necessary for the following purposes:
· Operational management – including but not limited to convening a Shareholders Meeting, payment of dividends, checking the powers of attorneys of the representatives, reporting, establishing, implementing and managing the business activities of the company. The processing of personal data for these purposes is based on the legitimate interests of the company to manage its material and financial resources;
· Compliance with regulatory requirements and settling of legal disputes - including, but not limited to, the processing of personal data in accordance with regulatory requirements (e.g tax, trade and other applicable legislation). The processing of personal data for these purposes is done on the basis of compliance by the company with applicable legal obligations.
Personal data entered into the KIOSK system for initial Health & Safety instruction, for visitors (e.g. Names, ID date of expiry, photo, № and date of instruction) – is stored for up to 5 years according to Art. 9, para. (2) of Ordinance No. RD-07-2 of December 16, 2009 on the conditions for conducting periodic briefing of employees and the rules for ensuring healthy and safe working conditions.
Personal data entered into the access control system is processed and kept for up to 3 years.
Video records are processed and stored for up to 2 months of creation in compliance with the Private Security Services Legislation. The video records of sites under the Waste Management Act are processed for up to 1 year.
All other personal data will be stored for a period of 10 years after payment of dividends.
Video records and indicators of body temperature measurements are processed for up to 2 weeks.
Shareholders provide their personal data to the Company on a voluntary basis. If they do not provide their personal data, the company will not be able to fulfill its legitimate purposes and/ or legal obligations.
The grounds for processing the personal data under p. III are based on Regulation (EU) 2016/679 as follows: Article 6 (1) (b) of Regulation (EU) 2016/67 and Article 6 (1) (c) of Regulation (EU) 2016/679 and/ or Article 6 (1) (f) of Regulation (EU) 2016/679 and Article 6 (1) (d) of Regulation (EU) 2016/679, in relation with Article 9 (2) (i) of Regulation (EU) 2016/679.
Provision of personal data to third parties
Aurubis Bulgaria AD uses service providers, who process and store personal data ("Personal Data Processors" pursuant to Article 28 of Regulation (EC) 2016/679). In particular, this is applicable to the security company, legal advisers and other services. These processors work only on contractual basis with Aurubis Bulgaria AD and store and process personal data according to the company's instructions.
If you contact Aurubis Bulgaria regarding issues that concern a company affiliated with Aurubis Bulgaria, in individual cases we will provide this affiliated company with your personal data.
If you have entered the premises of the company and subsequently informed us that you have been infected in order to prevent the spread of a pandemic/ epidemic disease, this information shall be disclosed to employees of Aurubis Bulgaria AD and employees of contractors who have been in contact with you and respectively may have been infected.
Out of these three circumstances, data will only be provided in individual cases and in a volume that is in accordance with a specific legal obligation of Aurubis Bulgaria AD, as well as in cases where You submitted consent to provide your data.
Shareholders rights as Data Subject
· Right to withdraw consent at any time (Article 7 (3) of Regulation (EC) 2016/679). As a consequence, the company will not be able to continue processing this data if it was based on consent.
· Right to request confirmation whether the company processes personal data, and if so, information on the storage and processing (Article 15 of Regulation (EC) 2016/679). In particular, information may be requested about the purposes of processing; categories of personal data; the categories of recipients to whom personal data will be or have been provided; storage period; the right to request correction, erasure and / or limitation of processing, to object to such processing and to lodge a complaint with a supervisory authority; information about the source from which the company have received personal data when it was not collected by the subject; information on the availability of automated decision making (including profiling) and, if applicable, relevant detailed information.
· Right to request immediate rectification of the personal data (Art. 16 of Regulation (EU) 2016/ 679).
· Right to request erasure of the personal data, unless its processing is necessary:
1) For exercising the right of freedom of expression and information;
2) For compliance with a legal obligation;
3) For reasons of public interest;
4) For the establishment, exercise or defense of legal claims (Art. 17 of Regulation (EU) 2016/ 679).
· Right to request restriction of the processing of the personal data if: contest their accuracy; the processing is unlawful; the company does not need the personal data any more, but the data subject require them for establishment, exercise or defense of а legal claim; if the data subject has objected to processing pursuant to Article 21 (1) of Regulation (EU) 2016/ 679 (Art. 18 of Regulation (EU) 2016/ 679).
· Right to receive the personal data in a structured, widely used and machine readable format or request the transfer of this data to another Administrator (Article 20 of Regulation (EC) 2016/679).
When exercising the right to receive personal data or to transfer it to another Controller, more than once within 24 months, Aurubis Bulgaria AD reserves the right, according to Ch. III, Art. 12 par. 5 (a) of Regulation (EU) 2016/679, to require payment of administrative costs of BGN 20 per set of paper copy and BGN 20 per electronic carrier.
In order to exercise his rights under the above points, the shareholder/ data subject must contact the Data Protection Officer designated by Aurubis Bulgaria AD:
Address: 2070. Pirdop, Industrial zone,
Tel : + 359 886 131 999
The shareholder/ data subject has the right, under Article 77 of Regulation (EC) 2016/679, to lodge a complaint to the Commission for Personal Data Protection (CPDP) by the ways described in the Commission's website. The contact details of CPDP are:
Address: 1592 Sofia, Prof. Tsvetan Lazarov Blvd. 2
Fax: 02 9153525
Aurubis Bulgaria AD will cooperate to CPDP in the handling of such complaints and will comply with all recommendations and/ or instructions issued by the supervisory authority.
The shareholder/ data subject has the right to lodge a complaint at Aurubis Group Headquarters by sending an email to dataprotection(at)aurubis.com .
Right to object
If the personal data is processed on the basis of a legitimate interest of the company pursuant to Article 6 (1) (f) of Regulation (EC) 2016/67, the shareholder/ data subject has the right to object the processing of these data under Article 21 (1) of Regulation (EC) 2016/679. In this case, the company will not continue the processing of the personal data, unless there are convincing legal grounds for the processing that take precedence over the interests of the data subject, his rights and freedoms or are necessary for the establishment and/ or the defense of legal claims.
If the shareholder/ data subject wants to use the right to object, it is enough to send an email to d.temelkova(at)aurubis.com