Privacy policy

With regard to the entry into force of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and taking into account the aspiration of Besha-B Ltd. to strictly comply with all its obligations arising from the applicable national and European regulations in the field of processing and protection of personal data, we would like to inform you of the following:

Besha-B Ltd. is a company registered in accordance with the requirements of the Commercial Act and entered in the Commercial Register and the register of non-profit organizations at the Registry Agency with UIC 200702411, with registered office and address of management: Sofia district, Stolichna municipality, Sofia 1000, 36 Solunska Street, Office "Center". You can contact us as follows:

  1. address for correspondence: Sofia district, Stolichna municipality, Sofia 1000, 36 Solunska Str., Office "Center";

  2. Contact person: Ashod Shakaryan

  3. phone: + 359 899 876 369

  4. e-mail: info@besha.bg

When carrying out its activities Besha-B Ltd. collects and processes personal data of the following data subjects:

  1. Employees (current and former);

  2. Job applicants;

  3. Customers, contractors and suppliers - individuals and / or employees and representatives of legal entities;

  4. Visitors to the commercial sites located (retail outlets) in the city of Sofia (also called "Visitors");

  5. Persons who have used the contact form available on the website of Besha-B Ltd.

With this Privacy Policy we would like to inform you about the personal data processed by us, for what purposes we process it and of the nature of your rights.

1.1. Privacy Policy for Employees

Besha-B Ltd. processes the personal data of its employees (current and former) in the capacity of an employer and in accordance with this Policy.

The personal data of employees that we process are three names, PIN / date of birth / other identification number, address, passport data (if necessary), place of birth (if necessary), gender and age, physiological identity data and those that relate to health, education, employment, professional and other qualifications, marital status and family relations, contact details (telephone and / or email), bank account, photos, content of an inquiry made through the contact form available on the Besha-B Ltd. website. Within the process of video surveillance conducted on the territory of the retail outlets of Besha-B Ltd., located in Sofia, it is possible to process data of employees regarding their social and cultural identity, as well as such, revealing racial and ethnic origin. These categories of data are not collected purposefully by Besha-B Ltd., but only if the individuals fall within the scope of the cameras used on the territory of retail outlets, whose purpose is to ensure security and protection of property and information of the Controller.

Personal data on health status are sensitive data that we process only in cases provided by the law, when the processing is necessary to protect the vital interests of the data subject or another individual, when the subject has given his explicit consent, as well as when the processing is necessary for the purposes of fulfillment of obligations and / or exercise of rights of Besha-B Ltd. under the labor and/or insurance law and for the purposes of preventive and/or labor medicine.

In case you do not provide us with the required information, including the necessary personal data, an labor agreement cannot be concluded between you and Besha-B Ltd, respectively Besha-B Ltd. will be unable to fulfill its legal and contractual obligations arising from its capacity as an employer.

As an employee of Besha-B Ltd. we may process your personal data to fulfill any of the following purposes:

  1. For concluding and/or fulfilling a concluded labor agreement;

  2. To fulfill and /or to comply with our legal obligations;

  3. For the purposes of the legitimate interests of Besha-B Ltd.;

  4. When you have given your explicit consent.

Besha-B Ltd. will not store your data for longer than necessary to achieve the purposes for which it processes them. When storing your personal data, we are guided by the statutory storage periods, as well as their quantity, nature and sensitivity, the purposes for which we process them, and whether we can achieve these purposes by other means.

After fulfilling the purpose for which your personal data is processed, or after the termination of the legal obligation and/or our legitimate interest, we will delete or destroy your personal data in a secure manner.

Besha-B Ltd. has the right to disclose your personal data to:

  1. its employees, the performance of whose job functions requires the processing of this data on its behalf;

  2. to public authorities in the performance of its legal duties or protection of legitimate interests;

  3. to an industrial medicine authority, to providers of legal, accounting, IT and other services for the performance of contractual or legal obligations, as well as for the protection of its legitimate interests.

We inform you that we will not provide your personal data to other external organizations, structures, individuals and/or legal entities other than those mentioned above, as an exception to the above is permissible only if there is a legal obligation to do so or your express consent has been given.

Besha-B Ltd. applies all appropriate technical and organizational measures to ensure the security of personal data and will update these measures periodically.

In the event that your data is disclosed to third parties, we require them to implemented the necessary technical and organizational security measures to protect your personal data in accordance with applicable law.

We inform you that you have the right to request from Besha-B Ltd. access to, correction or deletion of personal data, restriction of the processing of personal data, you have the right to object to the processing, the right to data portability, as well as the right not be subject to a solution based solely on automated processing. These rights can be exercised by sending an explicit application in this sense to the following email address: info@besha.bg  or electronically under the terms of the Electronic Document and Electronic Certification Services Act, the Act on electronic management and the Electronic Identification Act, or in writing at the address: Sofia District, Stolichna Municipality, Sofia 1000, 36 Solunska Street, Office "Center".

In cases where the processing of your personal data is carried out on the basis of your consent, you have the right to withdraw the same at any time. You can make the withdrawal in one of the following ways: by sending an explicit application in this sense to the following e-mail address: info@besha.bg or in writing to the address: Sofia district, Stolichna municipality, Sofia 1000, Solunska Str. № 36, Office "Center". We would like to draw your attention to the fact that the subsequent withdrawal of the given consent does not affect the legality of the personal data processing performed so far by Besha-B Ltd.

In cases where you believe that with its actions Besha-B Ltd. violates your legal rights regarding the collection, processing and storage of personal data provided by you, you can contact the Personal Data Protection Commission or the competent courts, having the right to file a complaint in which to set out your complaints.

1.2 Privacy Policy for Job Applicants

Besha-B Ltd. processes personal data of job applicants when conducting recruitment procedures and in accordance with this Policy.

The personal data of job applicants that we process are two / three names, date of birth, gender, address, education, employment, professional and other qualifications, contact details (telephone, email address), photo, content of the inquiry sent through the contact form available on the website of Besha-B Ltd. Within the process of video surveillance conducted on the territory of the retail outlets of Besha-B Ltd., located in Sofia, it is possible to process data of job applicants revealing racial and ethnic origin. These categories of data are not collected purposefully by Besha-B Ltd. but only if the individuals fall within the scope of the cameras used on the territory of retail outlets, whose purpose is to ensure security and protection of property and information of the Controller.

In case you do not provide us with the required information, including the necessary personal data, Besha-B Ltd. will not be able to include you in the recruitment procedure for which you have stated your desire to participate, respectively, this will affect your chances of being approved for the position you are applying for.

We may process your personal data to fulfill any of the following purposes:

  1. To carry out the recruitment procedure for the job position for which you are applying;

  2. To fulfill and/or comply with our legal obligations;

  3. For the purposes of the legitimate interests of Besha-B Ltd. or a third party;

  4. When you have given your explicit consent.

Besha-B Ltd. will store the personal data of unapproved job applicants for a period not exceeding 6 (six) months from the date of final completion of the procedure for which the person has applied, except in cases where you have given consent for longer storage. We will not store your data for longer than necessary to achieve the purposes for which we process it. When storing your personal data, we are guided by the statutory storage periods, as well as their quantity, nature and sensitivity, the purposes for which we process them, and whether we can achieve these purposes by other means.

After fulfilling the purpose for which your personal data is processed, or after the termination of the legal obligation and/or our legitimate interest, we will delete or destroy your personal data in a secure manner.

Besha-B Ltd. has the right to disclose your personal data to:

  1. its employees, the performance of whose job functions requires the processing of this data on its behalf;

  2. to public authorities in the performance of its legal duties or protection of legitimate interests;

  3. of IT or other services providers for fulfillment of contractual or legal obligations, as well as for protection of its legitimate interests.

We inform you that we will not disclose your personal data to other external organizations, structures, individuals and/or legal entities other than those mentioned above. An exception of the above is permissible only if there is a legal obligation to do so or your express consent has been given.

Besha-B Ltd. applies all appropriate technical and organizational measures to ensure the security of personal data and will update these measures periodically.

In the event that your data is disclosed to third parties, we require them to implemented the necessary technical and organizational security measures to protect your personal data in accordance with applicable law.

We inform you that you have the right to request from Besha-B Ltd. access to, correction or deletion of personal data, restriction of the processing of personal data, you have the right to object to the processing, the right to data portability, as well as the right not be subject to a solution based solely on automated processing. These rights can be exercised by sending an explicit application in this sense to the following email address: info@besha.bg  or electronically under the terms of the Electronic Document and Electronic Certification Services Act, the Act on electronic management and the Electronic Identification Act, or in writing at the address: Sofia District, Stolichna Municipality, Sofia 1000, 36 Solunska Street, Office "Center".

In cases where the processing of your personal data is carried out on the basis of your consent, you have the right to withdraw the same at any time. You can make the withdrawal in one of the following ways: by sending an explicit application in this sense to the following e-mail address: info@besha.bg  or in writing to the address: Sofia district, Stolichna municipality, Sofia 1000, Solunska Str. № 36, Office "Center". We would like to draw your attention to the fact that the subsequent withdrawal of the given consent does not affect the legality of the personal data processing performed so far by Besha-B Ltd.

In cases where you believe that with its actions Besha-B Ltd. violates your legal rights regarding the collection, processing and storage of personal data provided by you, you can contact the  Personal Data Protection Commission or the competent courts, having the right to file a complaint in which to set out your complaints.

1.3. Privacy Policy for Customers, contractors and suppliers

Besha-B Ltd. processes personal data of customers, contractors and suppliers in the performance of its contractual relations with them and in accordance with this Policy.

The personal data of Clients, contractors and suppliers - individuals and/or employees and representatives of legal entities, which we process are: two / three names, PIN / date of birth or other identification number (if necessary), address, passport data (if necessary), position held, contact details (telephone, e - mail address, fax), content of an inquiry sent through the contact form available on the website of Besha-B Ltd., bank account. Within the process of video surveillance conducted on the territory of the retail outlets of Besha-B Ltd., located in Sofia, it is possible to process data of customers, contractors and suppliers - individuals and/or employees and representatives to legal entities regarding their social and cultural identity, as well as those revealing racial and ethnic origin. These categories of data are not collected purposefully by Besha-B Ltd., but only if the individuals fall within the scope of the cameras used on the territory of retail outlets, whose purpose is to ensure security and protection of property and information of the Controller.

The provision of this data by you is voluntary and at the same time absolutely necessary in order for a contract to be concluded between you and Besha-B Ltd. In this regard, we would like to inform you that the performance of the contract on our part is possible only if we have the personal data provided by you. In case you do not want to provide your personal data, we inform you that Besha-B Ltd. will not be able to conclude a contract with you.

We may process your personal data to fulfill any of the following purposes:

  1. for concluding and/or executing a concluded contract;

  2. to fulfill and/or comply with our legal obligations;

  3. for the purposes of the legitimate interests of Besha-B Ltd.or a third party;

  4. when you have given your explicit consent.

The personal data provided by you will be stored by Besha-B Ltd. within the validity of the contract concluded with you. After its termination and expiration of the storage terms provided in the organization of Besha-B Ltd., your personal data will be deleted or destroyed in a secure manner, except in cases where there is a legitimate interest and/or regulatory basis, which oblige Besha-B Ltd. to continue their storage and/or processing.

Besha-B Ltd. has the right to disclose your personal data to:

  1. its employees, the performance of whose job functions requires the processing of this data on its behalf;

  2. to public authorities in the performance of its legal duties or protection of legitimate interests;

  3. of IT, legal, accounting, transport, etc. services providers for fulfillment of contractual or legal obligations, as well as for protection of its legitimate interests.

We inform you that we will not provide your personal data to other external organizations, structures, individuals and / or legal entities other than those mentioned above. An exception to the above is permissible only if there is a legal obligation to do so or your express consent has been given.

Besha-B Ltd. applies all appropriate technical and organizational measures to ensure the security of personal data and will update these measures periodically.

In the event that your data is disclosed to third parties, we require them to have implemented the necessary technical and organizational security measures to protect your personal data in accordance with applicable law.

We inform you that you have the right to request from Besha-B Ltd. access to, correction or deletion of personal data, restriction of the processing of personal data, you have the right to object to the processing, the right to data portability, as well as the right not be subject to a solution based solely on automated processing. These rights can be exercised by sending an explicit application in this sense to the following email address: info@besha.bg or electronically under the terms of the Electronic Document and Electronic Certification Services Act, the Act on electronic management and the Electronic Identification Act, or in writing at the address: Sofia District, Stolichna Municipality, Sofia 1000, 36 Solunska Street, Office "Center".

In cases where the processing of your personal data is carried out on the basis of your consent, you have the right to withdraw the same at any time. You can make the withdrawal in one of the following ways: by sending an explicit application in this sense to the following e-mail address: info@besha.bg or in writing to the address: Sofia district, Stolichna municipality, Sofia 1000, Solunska Str. № 36, Office "Center". We would like to draw your attention to the fact that the subsequent withdrawal of the given consent does not affect the legality of the personal data processing performed so far by Besha-B Ltd.

In cases where you believe that with its actions Besha-B Ltd. violates your legal rights regarding the collection, processing and storage of personal data provided by you, you can contact the Personal Data Protection Commission or the competent courts, having the right to file a complaint in which to set out your complaints.

1.4. Visitor Privacy Policy

Besha-B Ltd. processes personal data of visitors to retail outlets located in Sofia, which do not fall into any of the other categories of data subjects, in order to ensure security and control of property and information of Besha-B Ltd.- in compliance with its legal obligations and in accordance with the provisions of this Policy.

Within the process of video surveillance conducted on the territory of the retail outlets of Besha-B Ltd., located in Sofia, it is possible to process the following data of visitors - gender, data revealing racial and ethnic origin. These categories of data are not collected purposefully by Besha-B Ltd., but only if the individuals fall within the scope of the cameras used on the territory of retail outlets, whose purpose is to ensure security and protection of property and information of the Controller.

The provision of this data by you is voluntary and at the same time absolutely necessary in order to be able to provide you with access to the retails outlets of Besha-B Ltd., located in Sofia. In case you do not want to provide your personal data, we inform you that Besha-B Ltd. will not be able to provide you with access to retail outlets located in Sofia.

We may process your personal data to fulfill any of the following purposes:

  1. to fulfill and/or comply with our legal obligations;

  2. for the purposes of the legitimate interests of Besha-B Ltd.or a third party;

  3. when you have given your explicit consent (when processing for purposes other than those originally set);

  4. for the purposes of ensuring security and protection of the property and information of Besha-B Ltd.

The personal data provided by you will be stored by Besha-B Ltd. for a period not exceeding 2 weeks from the day following the day within which the personal data is collected. We will not store your data for longer than necessary to achieve the purposes for which we process it. When storing your personal data, we are guided by the statutory storage periods, as well as their quantity, nature and sensitivity, the purposes for which we process them, and whether we can achieve these purposes by other means.

Besha-B Ltd. has the right to disclose your personal data to:

  1. its employees, the performance of whose job functions requires the processing of this data on its behalf;

  2. to public authorities in the performance of its legal duties or protection of legitimate interests;

  3. to companies providing legal, etc. services for fulfillment of contractual or legal obligations, as well as for protection of its legitimate interests.

We inform you that we will not disclose your personal data to other external organizations, structures, individuals and / or legal entities other than those mentioned above, as an exception to the above is permissible only if there is a legal obligation to do so or your express consent has been given.

Besha-B Ltd. applies all appropriate technical and organizational measures to ensure the security of personal data and will update these measures periodically.

In the event that your data is disclosed to third parties, we require them to have implemented the necessary technical and organizational security measures to protect your personal data in accordance with the applicable law.

We inform you that you have the right to request from Besha-B Ltd. access to, correction or deletion of personal data, restriction of the processing of personal data, you have the right to object to the processing, the right to data portability, as well as the right not be subject to a solution based solely on automated processing. These rights can be exercised by sending an explicit application in this sense to the following email address: info@besha.bg or electronically under the terms of the Electronic Document and Electronic Certification Services Act, the Act on electronic management and the Electronic Identification Act, or in writing at the address: Sofia District, Stolichna Municipality, Sofia 1000, 36 Solunska Street, Office "Center".

In cases where the processing of your personal data is carried out on the basis of your consent, you have the right to withdraw the same at any time. You can make the withdrawal in one of the following ways: by sending an explicit application in this sense to the following e-mail address: info@besha.bg or in writing to the address: Sofia district, Stolichna municipality, Sofia 1000, Solunska Str. № 36, Office "Center". We would like to draw your attention to the fact that the subsequent withdrawal of the given consent does not affect the legality of the personal data processing performed so far by Besha-B Ltd.

In cases where you believe that with its actions Besha-B Ltd. violates your legal rights regarding the collection, processing and storage of personal data provided by you, you can contact the Personal Data Protection Commission or the competent courts, having the right to file a complaint in which to set out your complaints.

1.5. Privacy Policy for individuals who have used the contact form available on the Besha-B Ltd.website

Besha-B Ltd. processes personal data of Persons who have used the contact form available on the website of Besha-B Ltd., upon receipt of an inquiry, message or other statement submitted through the contact form, in compliance with their legal obligations and in accordance with this Policy.

The personal data of Persons who have used the contact form available on the Besha-B Ltd. website that we process are: names, contact details (email address), content of the inquiry.

The provision of this data by you is voluntary and at the same time absolutely necessary in order to be able to use the functionalities of the contact form. In this regard, we inform you that you could use the functionalities of the contact form, and Besha-B Ltd. - to prepare a response to the inquiry, message or other statement, only if we have the personal data provided by you. In case you do not want to provide your personal data, we inform you that you will not be able to use the functionalities of the contact form.

We may process your personal data to fulfill any of the following purposes:

  1. to process your inquiry, message or other statement and respond to it;

  2. to take steps to conclude a contract (provided that your inquiry, communication or other statement is of such a nature);

  3. to fulfill and/or comply with our legal obligations;

  4. for the purposes of the legitimate interests of Besha-B Ltd. or a third party;

  5. when you have given your explicit consent;

The personal data provided by you will be stored by Besha-B Ltd. for a period not exceeding 1 (one) year from the year following the calendar year in which the data are collected unless there is reason to subsequent processing of the provided data, requiring their storage for a longer period. After the expiration of this term, your personal data will be deleted or destroyed in a secure manner, except in cases where there is a legitimate interest and/or regulatory basis, which obliges Besha-B Ltd. to continue their storage and/or processing.

 Besha-B Ltd. has the right to disclose your personal data to:

  1. its employees, the performance of whose job functions requires the processing of this data on its behalf;

  2. to public authorities in the performance of its legal duties or protection of legitimate interests;

  3. of IT, etc. services providers for fulfillment of contractual or legal obligations, as well as for protection of its legitimate interests.

We inform you that we will not disclose your personal data to other external organizations, structures, individuals and / or legal entities other than those mentioned above, as an exception to the above is permissible only if there is a legal obligation to do so or your express consent has been given.

Besha-B Ltd. applies all appropriate technical and organizational measures to ensure the security of personal data and will update these measures periodically.

In the event that your data is disclosed to third parties, we require them to have implemented the necessary technical and organizational security measures to protect your personal data in accordance with the applicable law.

We inform you that you have the right to request from Besha-B Ltd. access to, correction or deletion of personal data, restriction of the processing of personal data, you have the right to object to the processing, the right to data portability, as well as the right not be subject to a solution based solely on automated processing. These rights can be exercised by sending an explicit application in this sense to the following email address: info@besha.bg or electronically under the terms of the Electronic Document and Electronic Certification Services Act, the Act on electronic management and the Electronic Identification Act, or in writing at the address: Sofia District, Stolichna Municipality, Sofia 1000, 36 Solunska Street, Office "Center".

In cases where the processing of your personal data is carried out on the basis of your consent, you have the right to withdraw the same at any time. You can make the withdrawal in one of the following ways: by sending an explicit application in this sense to the following e-mail address: info@besha.bg or in writing to the address: Sofia district, Stolichna municipality, Sofia 1000, Solunska Str. № 36, Office "Center". We would like to draw your attention to the fact that the subsequent withdrawal of the given consent does not affect the legality of the personal data processing performed so far by Besha-B Ltd.

In cases where you believe that with its  actions Besha-B Ltd. violates your legal rights regarding the collection, processing and storage of personal data provided by you, you can contact the Personal Data Protection Commission or the competent courts, having the right to file a complaint in which to set out your complaints.

2. Changes to the Privacy Policy

This Privacy Policy of Besha-B Ltd., entering into force as from 17.11.2020 may be amended periodically, which will be notified by email or other appropriate means.

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