Privacy Policy for business partner

Кликнете тук за версия на български език

Thank you for visiting our website.

We from Schwarz Global Services Bulgaria EOOD take the protection of your personal data very seriously and strive to provide you with comprehensive information about the processing of your personal data. The following privacy policy applies to you if you contact us, if you enter into contract negotiations with us and/or if there is a contract in place between us and the data of natural persons is processed in that context. The specific legal bases are the EU General Data Protection Regulation (GDPR) and national Bulgarian legislation. Which data is processed in the individual case depends primarily on the agreed services. As a result, not all of this information will be relevant to you.

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 pro