Privacy policy
1. WHO ARE WE
"Industrial Capital-Holding" AD is a public joint-stock company within the meaning of the Law on Public Offering of Securities, registered in the Commercial Register at the Registration Agency under EIK 121619055, with headquarters and management address: Sofia, district "Oborishte", 8 Bacho Kiro Str.
The protection of your personal data when using the company's services is extremely important to us and we want to let you know what personal data we use about you, the reasons why we use and share such data, how long we store it and how you can use your rights.
"Industrial Capital-Holding" JSC observes the principle of banning the processing of high-quality data (revealing racial or ethnic origin, political views, religious or philosophical views or membership in trade unions, as well as the processing of genetic, biometric data for the sole purpose of identifying the natural person, data on the state of health or on the sex life or sexual orientation of the natural person), with exceptions allowed only in the cases provided for by law.
"Industrial Capital-Holding" JSC does not process personal data for the purposes of direct marketing and does not provide personal data for such a purpose.
When visiting our site www.hika-bg.com, personal data, such as IP address, can also be collected through the use of cookies.
2. PERSONAL DATA PROCESSED
We collect and process your personal data to the extent necessary for our activities. We may collect various types of personal data about you, including:
- identifying information (e.g. name, ID and passport number, nationality, place and data of birth, gender, photo, IP address);
- identification data of proxies;
- contact information (e.g. postal address and e-mail address, telephone number)
- tax status (eg tax identification number, tax status);
- bank details (e.g. bank account details);
- number of shares, value of dividend, etc.
The data we process about you may be provided directly by you or obtained from other sources to verify our databases for the purpose of performing our contractual and legal obligations, for example:
- publications/databases to which access is granted by official authorities (e.g. State Gazette, registers maintained by the Registration Agency; Central Depository, etc.)
- our corporate customers or service providers;
As a public joint-stock company "Industrial Capital-Holding" AD does not have a book of shareholders. According to the law, the book of shareholders of public companies is generated, stored and changed by a Central Depository. In fulfillment of the legal requirements, we receive from the Central Depository a list of the shareholders of "Industrial Capital-Holding" AD for the purpose of holding a general meeting of shareholders and for the payment of dividends.
"Industrial Capital-Holding" JSC does not collect the personal data of the shareholders for their entry in the share register and has no right to make changes in it.
Changes in shareholder data are made only by the Central Depository through a licensed investment intermediary that has the rights of the registration agent.
3. DATA SECURITY AND PROTECTION
"Industrial Capital-Holding" AD implements the necessary technical and organizational measures to protect your data from any illegal actions, incl. loss and unauthorized access. These include limiting access to personal data, strict adherence to the adopted Rules for the measures and means of personal data protection, appropriate training of the persons responsible for the processing of personal data and compliance with good practices, guidelines and instructions for the protection of personal data from the competent supervisory authorities.
All measures are subject to regular review and are periodically updated. In the event of a breach of the security of your personal data, we will notify you without undue delay within a reasonable time after becoming aware if the breach of the security of personal data is likely to result in a high risk to your rights and freedoms.
4. GROUNDS FOR PROCESSING PERSONAL DATA
Your personal data is collected and processed for the following purpose:
- fulfillment of regulatory requirements of the current legislation for public companies, including the protection of the rights of shareholders and their proxies, such as holding general meetings, paying dividends, inheriting shares, etc.;
- certain legal and regulatory obligations – for example to the National Revenue Agency, the Central Depository, the Financial Supervision Commission, the Bulgarian Stock Exchange. We may provide information upon official request by a duly authorized public or judicial authority.
- requirements of labor legislation;
- accounting records;
- activities related to the existence, amendment and termination of contractual relationships and for the preparation of any documents in this connection (contracts, additional agreements, protocols, reports, certificates, etc.);
- establishing contact with the person when it concerns his rights as a shareholder by sending correspondence or a telephone communication.
Your personal data will be processed by "Industrial Capital-Holding" AD only in accordance with the applicable data protection regulations.
5. SOURCES OF PERSONAL DATA
Your personal data may be collected by us through:
- Central depository in the form of a book of shareholders. The list is received by us via an encrypted channel in electronic format;
- information provided by you;
- submission of documents when applying for a job in the company or intermediary recruitment agency;
- completed by you declarations , official notes and criminal record certificates, if they are required by law;
- on the basis of the contracts concluded by us with counterparties and related documents.
When you correspond with us by e-mail or fill out an application for the payment of a dividend in your capacity as shareholders, you declare that you voluntarily provide your personal data contained in the application and consent to their processing for the purposes of paying my dividend due from the company.
6. TERM OF KEEPING. DESTRUCTION
We process and store your personal data for a certain period of time, which is determined by:
- the periods required to comply with Bulgarian and European legislation;
- another period in relation to our operational requirements, with a view to protecting our legal rights and interests.
Each dividend payment list shall be kept until the expiry of the general limitation period by which the cash claim is extinguished, which is 5 years from the starting date of the dividend payment.
Your data as a counterparty (in the case of contractual relationships) is stored in accordance with the requirements of the law for a period of 10 years after the year of termination of the legal relationship, taking into account the storage periods of accounting information.
We take all necessary technical and organizational measures to destroy data that is no longer needed, except in cases where there is a legal basis to process it for a longer period of time.
7. OUR PARTNERS
In certain cases, "Industrial Capital Holding" AD processes the data with the support of professional partners such as: banks, auditors, lawyers, accounting firms, notaries, couriers, etc.
Our partners are carefully selected and ensure that they have taken appropriate legal, technical and organizational measures to ensure that your data is processed in accordance with applicable data protection legislation.
8. DISCLOSURE OF DATA TO THIRD PARTIES
We do not disclose your personal data unless the provision of certain information is required by law. In exceptional circumstances, we may provide your personal data to competent public authorities and/or supervisory authorities in proceedings before them, or to another person when we are required by law. In certain cases, we may be required to disclose information: in compliance with a judicial, regulatory or other official act or decision; based on an agreement between us and another administrator/s or processor/s of personal data, in accordance with the requirements of the current legislation; upon instructions given by you or instructions of a person authorized by you. We require all third parties to whom we disclose personal data or who may receive it on our behalf to ensure its confidentiality and manage it in accordance with legal requirements.
9. YOUR RIGHTS
You have the following rights under data protection legislation:
- Right to information
- Right of access
- Right to corrections
- Right of erasure
- Right to restriction of processing
- Right to data portability
- Right of objection
- Right to submitting a complaint
In addition to the information set out above, you should note that you are not subject to automated decision-making. In accordance with the applicable legislation in the field of personal data, you have the rights described below, and we undertake to respond to each of your requests within one month of receipt of the request and without charge. In the presence of factual or technical difficulties for the timely implementation of such requests, the deadline for implementation can be extended by another 2 months, for which the data subject should be notified within 1 month of receiving the request.
You can receive information related to the processing of your personal data and a copy of this personal data.
If we process incomplete or incorrect personal data from you, you can request their correction or completion at any time. Please note that we cannot make changes to the shareholder register.
You may request the deletion of your personal data, to the extent permitted by law, unless the company proves that there are legitimate grounds for the processing that override the interests of the data subjects, or for the establishment, exercise and protection of legal rights and interests of the company.
You may request the restriction of the processing of your personal data to the extent permitted by law.
Where legally applicable, you have the right to have your personal data that you have provided us returned to you or, where technically possible, to have it provided to a third party.
You have the right, at any time and on grounds related to a specific situation, to object to the processing of your personal data, which is based on a legitimate interest or is necessary for the performance of a task in the public interest or the exercise of official powers, in the event that that these have been provided to "Industrial Capital-Holding" AD,including profiling.
If you believe that we have violated applicable data protection legislation when processing your data and as a result affected your rights, please contact us. Of course, you also have the right to lodge a complaint with the Commission for Personal Data Protection.
Please note that in some cases your rights are limited and where there is a legal basis for processing, some of them may not be applicable, e.g. we will only be able to change, restrict or delete your personal data to the extent, order and manner in which we are required to retain it due to regulatory or legal requirements, such as statutory retention obligations, pending proceedings, establishment, exercise or defense of legal claims etc.
All requests, as well as additional explanations and information related to the exercise of your rights, can be submitted directly to "Industrial Capital-Holding" AD by contacting us.
10. CONTACT US
You can send questions and requests according with the processing of your personal data to the address:1000 Sofia, 8 Bacho Kiro str.
tel. +(359)2 980 26 48 e-mail:office@hika-bg.com