Privacy Policy
“AMBULATORY GROUP PRACTICE FOR PRIMARY DENTAL CARE MEDICARE” Ltd.
(Notice regarding the processing of personal data)
Personal Data Administrator:
Name: “AMBULATORY GROUP PRACTICE FOR PRIMARY DENTAL CARE MEDICARE” Ltd.
UIC: 205311968
Registered office and management address: Varna, Odessa district, 64 Macedonia St., 1st floor
Phone: 0887 191 113
Email address: medicare.varna@gmail.com
Website: www.medicare-varna.com
“AMBULATORY GROUP PRACTICE FOR PRIMARY DENTAL CARE MEDICARE” Ltd. (“The Company” or “The Administrator”) operates in compliance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data (“General Data Protection Regulation” or “The Regulation”). This “Privacy Policy” (“Privacy Policy” or “The Policy”) aims to inform each Client (as defined below) of the Company about the processing of data that identifies or can identify the specific Client.
For the purposes of the Policy, a “Client” is any natural person who is a party to a contract with the Company for the sale of goods or services, as well as a natural person expressing their intention to enter into pre-contractual relations with the Administrator and/or a user of the website, accessible at the electronic address: www.medicare-varna.com, as well as a director, manager, representative, proxy, employee, partner, shareholder, beneficial owner of a legal entity or other legal formation using the website.
What personal data do we process?
The Company processes the following categories of personal data of Clients as the data administrator:
• Physical identity – names, personal identification number (EGN), address, phone, email address;
• Cookie data;
• Security camera footage.
Personal data is collected by the Administrator from the persons to whom it pertains.
How do we collect personal data?
We collect personal data:
• when using the website;
• when engaging in correspondence with the Client, which may include written, including electronic, and oral communication;
• through cookies when using or browsing our website;
• when visiting the Company’s facilities through the installed security cameras.
In some cases, we may collect information from third parties or public sources.
Our website collects data in log files. This information includes data about your IP address, internet service provider, the browser you use, your operating system, when you visited our website, and the pages visited.
Our website uses cookies. Cookies are small files of information that the website sends to the visitor’s browser. The browser stores this information in a text file on the user’s device. They help us make our website work better for you. More information about the use of cookies can be found in our Cookie Policy published on our website: www.medicare-varna.com.
Do we process special categories of personal data?
The Company does not process special categories of personal data of Clients.
For what purposes do we process personal data?
The Company processes personal data of Clients for the following purposes:
• providing information and assistance that you have requested from us;
• identifying and contacting Clients and beneficial owners;
• for all activities related to the existence, amendment, and termination of the relationship between the Company and the Client;
• offering and promoting additional services;
• compliance with regulatory requirements;
• providing protection in case of a dispute and cooperation with regulatory authorities to the extent required by law;
• performing security video surveillance at the Company’s facilities.
If we do not process this personal data, we may not be able to provide you with our services or the requested assistance.
What legal grounds do we process personal data on?
Personal data of Clients is collected, processed, and used based on several grounds for processing:
• To fulfill a contract or to enter into pre-contractual relations;
• To comply with a legal obligation applicable to the Company;
• For the legitimate interests of the Company or a third party, when the rights and interests of the data subjects do not outweigh theirs – for resolving disputes; preventing, detecting, investigating fraud, violations, or other unlawful behavior; for the establishment, exercise, or defense of legal claims;
• The territory of the Company’s facilities is under video surveillance by security cameras to ensure the safety of employees, Customers and equipment.
• Based on voluntarily given consent, when required by applicable legislation.
How long do we store personal data?
The Company retains personal data for the duration of the contractual relationship and until the obligation under the contract is fulfilled, and during a transitional period (e.g., for compliance with obligations related to archiving and storing accounting data). If legal action or other actions are initiated, personal data may be retained until the end of such action, including any possible periods for appeal, after which they will be deleted or archived as permitted by applicable law. Specifically, various accounting and tax information, containing personal data, is stored for a period of 10 years starting from January 1 of the reporting period following the reporting period to which they pertain.
In cases where your personal data is obtained and processed based on your consent, we will process your personal data only as long as we have your consent to do so.
With whom do we share personal data? Do we provide it to third countries?
The Company may, at its discretion, transfer part or all of the personal data to data processors for the purpose of processing, in compliance with the requirements of the Regulation.
The Company shares personal data with:
• third parties – service providers engaged by us to perform functions or activities on our behalf;
• third parties: regulatory authorities, tax, financial authorities, judicial, administrative, and law enforcement bodies, all in accordance with applicable law.
This list is not exhaustive and there may be other lawful purposes for storing, disclosing, or otherwise processing your personal data.
The Company notifies the data subject in the event of intent to transfer part or all of their personal data to third countries or international organizations.
Are personal data protected?
The Company ensures and maintains appropriate technical and organizational measures to protect personal data against unauthorized access or unlawful use of personal data and/or against accidental loss, alteration, disclosure, access, and/or damage or copying. These measures aim to provide continuous protection and integrity of personal data. The Company regularly re-assesses the measures to achieve continuous security of personal data.
Do we engage in automated decision-making?
The Company does not engage in automated decision-making using personal data.
What rights do Clients have regarding the protection of personal data?
Each Client can exercise the rights listed below by sending a written notice to the Company.
• Withdrawal of consent to process personal data
When the processing of personal data of a Client is based on their given consent, the Client has the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Right of access
Each Client has the right to receive confirmation from the Company as to whether their personal data is being processed. This includes the right of access to personal data, the right to receive a free copy of the data (except in cases of excessive and repetitive requests), unless otherwise provided in the applicable data protection rules, as well as the Client’s right to be provided with a description of the key information related to the processing of their personal data.
The Company provides the Client with a free copy of their personal data being processed, but reserves the right to impose an administrative fee in case of repeated or excessive requests.
• Right of rectification
Each Client has the right to rectify or request the Company to rectify, without undue delay, inaccurate, incomplete, or outdated personal data concerning them.
• Right to erasure (right to be forgotten)
Each Client has the right to request the Company to erase personal data relating to them without undue delay when one of the following grounds applies:
(i) The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
(ii) The Client withdraws their consent on which the processing of their data is based and there is no other legal ground for processing;
(iii) The Client objects to the processing, as specified below;
(iv) The personal data of the Client has been processed unlawfully; or
(v) The personal data of the Client must be erased to comply with a legal obligation under EU law, Member State law, or the law of another country;
(vi) The personal data were collected in connection with the provision of information society services.
The Company may refuse to erase the personal data of the Client to the extent that processing is necessary:
(i) for the exercise of the right to freedom of expression and the right to information;
(ii) for compliance with a legal obligation requiring processing under EU law or the law of the Member State applicable to the Administrator or for the performance of a task carried out in the public interest or in the exercise of official authority vested in it;
(iii) for reasons of public interest in the area of public health;
(iv) for archiving purposes in the public interest, scientific or historical research, or statistical purposes;
(v) for the establishment, exercise, or defense of legal claims.
• Right to restrict processing
Each Client has the right to request the Company to restrict the processing of their personal data in the following cases:
(i) When they contest the accuracy of the personal data provided by the Client and processed by the Company (the restriction is for a specific period, allowing the Company to verify the accuracy of the personal data);
(ii) When the processing is unlawful, but the Client does not want the personal data to be erased, but instead requests a restriction on its use;
(iii) When the Company no longer needs the personal data for processing purposes, but the Client requires it for the establishment, exercise, or defense of legal claims;
(iv) When the Client has objected to the processing and expects the Company to verify whether the legitimate grounds for processing the personal data outweigh the interests of the Client.
• Right to object
Each Client has the right, at any time, to object on grounds relating to their particular situation, to the processing of personal data concerning them.
The Client may exercise the right only in relation to the processing of their personal data carried out by the Company for the purposes of the legitimate interests of the Company.
If the objection is justified, the Company will cease processing the personal data regarding the Client who objected, unless the Company demonstrates that there are compelling legal grounds for processing that override the interests of the Client.
• Right to data portability
This right includes the following possibilities:
(i) to obtain the personal data in a structured, commonly used, and machine-readable format, to transfer it to another administrator, or
(ii) to obtain direct transfer of personal data to another administrator, if technically feasible.
• Right to complain
Each Client has the right to lodge a complaint regarding the processing of their personal data by the Company to the Personal Data Protection Commission, which is the competent supervisory authority.
Personal Data Protection Commission
Address: Sofia, P.O. Box 1592, Prof. Tsvetan Lazarov St. No. 2
Phone: (02) 91 53 519, Fax: (02) 91 53 525
Email: kzld@cpdp.bg
Website: www.cpdp.bg
What happens in case of changes?
In the event of a significant change in the way the Company processes the personal data of Clients and/or in the types of personal data it processes and/or in any other aspect of this notice, the Company will notify the Clients of the relevant change immediately by issuing and providing Clients with an updated version of the notice.