Privacy Policy

Transparancy Policy for the Processing of Personal Data

of Prime Holding Jsc., UIC 203531218,
with address: Bulgaria, Plovdiv 4000, Central District, 22, Opalchenska Street

Prime Holding Jsc., as data controller under the provisions of Art. 4 (7) OF REGULATION (EC) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95 / 46 / EC (General Data Protection Regulation, GDPR).

Prime Holding Jsc. , as part of the holding structure of Prime Holding Jsc., consisting of: APT Systems EOOD, with UIC 160069500; SBND EAD, UIC 200479428; SBND Web Technologies Ltd., UIC 130508728; Programista EAD, UIC 203944811, Brigade Prime AD, with UIC 204223974, which are joint controllers, pursuant to Art. 26 of the General Regulation on the protection of personal data Regulation (EU) 2016/679 and an agreement between them.

The General Data Protection Regulation (GDPR) defines personal data as: "any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual".


We hereby, would like to inform you about the ways in which Prime Holding Jsc. (the Company) processes your personal data and the opportunities provided to you for defending your legal rights in case of a violation and illegal use of your personal data.

The purposes for which your personal data is collected and processed are as follows:

  • - For accounting and tax purposes, on the grounds of the Accountancy Act of Republic of Bulgaria, the Tax and Social Insurance Procedural Code, etc.;

  • - Human resources management, based on the Labor Code and CVs submitted by job applicants, etc.;

  • - To implement contracts concluded by our Company with clients, business partners and suppliers;

  • - For purposes of video surveillance for security purposes, based on the legitimate interests of the administrator;

Consent for processing of personal data is required only if there is no other basis for data processing, such as contract, a special provision of law, legitimate interest of the controller, etc.

The categories of personal data that the Company processes are as follows:

  • - For accounting and tax purposes - three names, PIN, address;

  • - For human resources management and CVs submitted by job applicants - three names, PIN, address, telephone number, e-mail, photos (if present), identity card details;

  • - For execution of contracts concluded with the Company with clients, business partners and suppliers - three names, position / position, date of birth, identity card, citizenship, address, telephone number, e-mail address, bank account;

  • - For security video surveillance purposes - recordings.

The deadlines for storing this personal data are the following:

  • - For accounting and tax purposes - according to the applicable and effective legislation in the Republic of Bulgaria;

  • - Human resources management and CVs submitted by job applicants - according to the applicable and effective legislation in the Republic of Bulgaria;

  • - For execution of contracts signed by the Company with clients, business partners and suppliers - 5 years from the termination of the contract / dropping the grounds for their processing;

  • - For video surveillance purposes - 60 days.

At your request, Prime Holding Jsc., shall inform you about what information it stores about you and how it is processed. If the Company stores your personal data, you may request the following information:

  • - the identity and the contract details of the controller;

  • - purpose and legal basis for the processing;

  • - whether processing is based on legitimate reasons, information about these reasons;

  • - categories of personal data collected, stored and processed;

  • - how long your personal data will be stored;

  • - recipients or categories of recipients (if any) to whom the data is or will be disclosed;

  • - if we intend to transfer your personal data to a third country or international organization - information on how we ensure that this is done in a secure manner;

  • - the ways to exercise your rights of correction, deletion, limitation, or objection to such processing;

  • - how to exercise your right to withdraw your consent at any time;

  • - how to lodge a complaint with the national supervisory authority;

  • - whether the provision of personal data is a statutory or contractual requirement, including if it is necessary to enter into a contract, what would be the possible consequences if such data were not provided;

  • - source of personal data, if it is not collected directly from you;

  • - any details and information about automated decision making, such as profiling.

The Company does not provide data about its clients to third parties unless required by law. The Company does not provide data about its clients in a third country or international organization.

Usage of cookies:

Our website uses Google Analytics, which is type of “cookies”. Cookies are text files and are used in this specific case to improve the performance of the site. Some cookies remain stored on your device until you delete them. Through them, we can analyze the internet traffic, while in the meantime Google’s data collected by us does not use profiling and features that make it possible to recognize the identity of a user that visits the site again. The data we use for this purpose is anonymized by Google. Please note, that Google, as a personal data controller, has fully complied with the provisions of the General Data Protection Regulation.

Note that our website does not use other cookies or software of the same or similar type in collecting and processing your personal information. If there is a change in this respect, we will duly inform you with a statement on the site.

Changes in the transparency policy:

We reserve the right to change our privacy policy.

If you have any questions regarding the processing of your personal data, please contact us [email protected]

The privacy and security of your personal data is of utmost importance to us. In this respect, we want to inform you that as of 25.05.2018, new European requirements for the protection of personal data come into force.

You may exercise your rights as a data subject* pursuant to the General Regulation on the protection of personal data by contacting the e-mail, mentioned above.

* This data will only be used to handle your request for the exercise of your rights as a personal data subject.

As data subject you have the right to lodge a complaint with the supervisory authority:

Commission for Personal Data Protection

Sofia 1592, 2, "Prof. Tsvetan Lazarov" Blvd.

E-mail: [email protected]


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