Thank you for visiting our website.
1. General information
As a rule, the personal data of yours that we collect is obtained directly from you.
However, it may also be necessary to process personal data that we obtain from other companies, authorities or other third parties, such as credit agencies, tax offices and the like. This may include personal data that we obtain through our whistleblower channels about potential compliance violations or in the context of compliance investigations.
Relevant personal data may include: personal details (e.g. first name, last name, address and other contact details, date and place of birth and nationality), identification and authentication data (e.g., commercial register excerpts, I.D. data, specimen signature), data within the scope of our business relationship (e.g., payment data, data on orders), creditworthiness data, data on corporate and ownership structure, photos and videos (e.g., with deliveries of goods) and other data comparable to the aforementioned categories.
You may elect to communicate with us by e-mail or mail. For technical reasons, e-mail communications may be unencrypted.
2. "Controller" within the meaning of Article 4(7) GDPR
The controller responsible for data processing within the meaning of Article 4(7) GDPR is the company named in the e-mail signature or the company with which you are initiating or entertaining a business relationship.
3. Purposes and legal bases of processing
a) Visiting this website
When you visit this website, log files are generated containing the following information:
- the website from which you visit our site;
- the IP address;
- the date and time of access;
- the client request;
- the http response code;
- the data volume transmitted;
- information about the type of browser and operating system you are using.
Recipients/categories of recipient
Each time that a user accesses this website and each time a file is accessed, Schwarz IT KG, Stiftsbergstraße 1, 74172 Neckarsulm save log files documenting this process; this serves exclusively to protect our systems and to prevent improper and/or fraudulent behavior.
Storage time/criteria for determining storage time:
Storage time is 7 days.
b) For the performance of contractual obligations (Article 6(1)(b) GDPR)
The purposes of processing follow from the need to take steps prior to entering into a contract, in advance of a contractual business relationship and to perform obligations under an existing contract.
c) For compliance with a legal obligation (Article 6(1)(c) GDPR)
The purposes of processing follow from statutory requirements in the individual case. Such legal obligations include, e.g., complying with retention and identification obligations, e.g., in the context of anti-money laundering requirements, tax monitoring and reporting requirements and data processing in the context of requests from authorities.
For example, pursuant to Bulgarian legislation implementing the EU Whistleblowing Directive Schwarz Global Services Bulgaria EOOD is obliged to create a channel for receiving signals for violations of legislation in various areas. In case such signal is filed by employee or third party Schwarz Global Services Bulgaria EOOD is obliged to investigate the signal. For these purposes the following categories of data might be processed: the signal sender's three names, address and telephone number, as well as an email address, if any; the names of the person against whom the report is filed and their workplace, if the report is filed against specific persons and they are known; specific details of an actual or potential breach, the place and time of the breach, if already committed, a description of the act or the situation and other circumstances, as far as these are known to the whistleblower; date of submission of the report; signature, electronic signature or other identification of the sender and other circumstances around the signal, as well as any other data voluntarily shared by the signal sender. The personal data shall be stored for a period of one year after the case is solved or closed without solving.
d) For the purposes of legitimate interests (Article 6(1)(f) GDPR)
It may be necessary to process the personal data you provide for purposes beyond the actual performance of the contract. Legitimate interests in this case include, in particular, selecting suitable business partners, asserting legal claims, defending against liability claims, protecting our IT infrastructure, managing system access authorizations, physical and data access controls, entering your contact details in our global Schwarz Group user directory, clarifying potential compliance violations, preventing crimes and settling claims arising out of the business relationship.
At the time of contracting, we occasionally obtain data on your credit history from credit agencies to serve the aforementioned legitimate interests. We use the credit history information from the credit agencies to assess your creditworthiness. Credit agencies store data that they receive from banks or companies, for example. Such data includes in particular last name, first name, date of birth, address and information on payment history. Information on the data stored about you can be obtained directly from the credit agencies.
If you accept our offer of contract by means of digital signature (e.g., Adobe Sign), we process your data, such as in particular e-mail address, IP address as well as the time and date of any modifications you make to the respective contract document, for instance when you approved, displayed or digitally signed it. We have a legitimate interest in ensuring that the process for signing contracts digitally is fast and efficient and that the signing process can be logged for verification purposes. Certain contracts may also be signed using a so-called qualified electronic signature. In this case we also process the certificate data associate with your signature in addition to the aforementioned data. We have a legitimate interest in being able to verify whether you are able to provide a valid qualified electronic signature serving to replace any written form prescribed by statute. To use a qualified electronic signature, you must independently register with a trust service provider (e.g., B-TRUST). When you register, the respective provider will process your data under its own responsibility and not on our behalf, however.
4. Who receives the personal data you provide to us?
Within our company, access to the data provided by you will be granted to those departments that require such data for the purposes of performing contractual obligations, complying with legal obligations or serving legitimate interests. In the context of the contractual relationships, we also engage processors or service providers who may be given access to your personal data. Their compliance with data protection requirements is ensured by contractual agreement.
In addition, the data may be transferred to Schwarz Group companies for purposes of performing contractual obligations.
In the case of contracts executed by digital signature, your data is also accessible to all persons involved in the approval and signing of the contract, as they receive a log after the contract has been signed indicating all processing steps, including e-mail address, IP address, date and time. Your data may also be accessible to the respective service providers that we use for the relevant digital signature procedure. In the case of Adobe Sign, this would be Adobe Systems Software Ireland Limited, 4-6 Riverwalk, City West, Business Campus, Saggart D24, Dublin, Ireland. If a qualified electronic signature is used to execute digital contracts, your data may also be accessible to B-Trust in Bulgaria (or another similar type of supplier), which is the provider responsible for checking the validity of the signature.
5. For how long will the data be stored?
The personal data will be stored for as long as necessary for fulfilling the above-mentioned purposes. Some of the particularly relevant periods are for example for tax purposes – 10 years starting as of 1st of January of the year following the year in which the tax obligation has arisen, for legal claims – 5 years after the termination of the contracts and after the performance of all rights and obligations therein or for as long as necessary in case of commenced court proceedings/ lawsuits and/or other claims, etc.
6. Are you obligated to provide the data?
Within the scope of our business relationship, you must provide us with the personal data needed to commence, execute and terminate a business relationship and to perform the obligations associated therewith, which we are legally obligated to collect and/or are entitled to collect on the basis of legitimate interests. Without such data, we would generally not be able to enter into a business relationship with you.
7. Is data transferred to third countries?
If we transfer personal data to recipients outside the European Economic Area (EEA), the transfer will only take place if an adequate level of data protection has been confirmed for that third country by the European Commission, if an adequate level of data protection has been agreed with the data recipient (e.g., by means of EU standard contractual clauses) or if we have received your consent.
8. Your rights as data subject
Under Article 15(1) GDPR, you have the right to obtain information, free of charge, on the personal data stored about you.
If the statutory requirements are met, you also have a right to rectification (Article 16 GDPR), erasure (Article 17 GDPR) and restriction of processing (Article 18 GDPR) of your personal data.
If the basis of processing is Article 6(1)(e) or (f) GDPR, you have a right to object under Article 21 GDPR. If you object to processing, your data will no longer be processed thereafter, unless the controller demonstrates compelling legitimate grounds for the processing which override the interests of the data subject in the objection.
If you have provided the processed data yourself, you have a right to data portability under Article 20 GDPR.
If the data processing is carried out on the basis of consent granted under Article 6(1)(a) or Article 9(2)(a) GDPR, you may revoke that consent at any time with effect for the future without this affecting the lawfulness of the previous processing.
In the above-mentioned cases, or if you have questions or complaints, please write to or e-mail the data protection officer (see no. 9).
You also have a right to lodge a complaint with a data protection supervisory authority. The data protection supervisory authority located in the state in which you live or where the controller is domiciled has jurisdiction.
9. Data protection officer/coordinator
For further questions concerning the processing of your data or the exercise of your rights, please contact the competent data protection officer/coordinator of the controller at:
Schwarz Global Services Bulgaria EOOD
Sofia, Business Park Mladost, building 15, fl. 2