SUBJECT
Art. 1. This PRIVACY POLICY (hereinafter referred to as the “Policy”) is adopted by DISCORDIA AD, UIC 117015342 (hereinafter referred to as “DISCORDIA”), acting in its capacity as a personal data controller, in accordance with the requirements of Regulation (EU) 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 (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”), as well as the Bulgarian Personal Data Protection Act (PDPA).
Art. 2.
(1) The right to privacy of personal data is a fundamental priority for DISCORDIA. DISCORDIA strictly complies with all applicable national and European legislation regarding the protection and secure storage of personal data of employees, contractors, partners, and individuals who have provided their personal data through the communication forms on the website https://discordia.eu/ (hereinafter referred to as the “WEBSITE”).
(2) DISCORDIA observes the fundamental principles applicable to the processing of personal data, namely: lawfulness, fairness and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality; and accountability.
(3) This Privacy Policy does not cover DISCORDIA’s entire activity but aims to inform data subjects about the processing of personal data when using the WEBSITE.
DEFINITIONS
Art. 3. The terms used in this Policy shall have the meaning assigned to them in the GDPR.
WHO PROCESSES YOUR PERSONAL DATA
Art. 4. The personal data controller is DISCORDIA AD, UIC 117015342, with registered office and management address at: Sofia 1528, Iskar District, 7 Iskarsko Shose Street, Europa Trade Centre, Building 1, Floor 3.
CONTACT DETAILS OF THE CONTROLLER
Art. 5. The Controller’s contact details are as follows:
- Address: Sofia 1528, Iskar District, 7 Iskarsko Shose Street, Europa Trade Centre, Building 1, Floor 3
- Email: office@discordia.bg
- Phone: +359 2 447 58 11
WHEN DO WE PROCESS PERSONAL DATA
Art. 6. DISCORDIA does not collect personal data unnecessarily or without limitation. Only personal data required for the lawful performance of the company’s activities is collected. The activities related to the use of the WEBSITE that involve personal data processing are linked to the communication forms available on the WEBSITE.
CATEGORIES OF DATA SUBJECTS
Art. 7. Through the WEBSITE, DISCORDIA processes personal data of the following categories of individuals:
- Registered users of the WEBSITE;
- Individuals who have provided personal data through the transport and logistics service request form;
- Job applicants who have provided personal data via the job application forms;
- Individuals who have provided personal data via the general contact inquiry form on the WEBSITE.
CATEGORIES OF PERSONAL DATA PROCESSED
Art. 8.
(1) DISCORDIA processes personal data provided directly by data subjects. Data subjects determine the scope of personal data they provide depending on the purpose. DISCORDIA stores only data necessary for the processing purposes, such as:
- Names, email address, and phone number provided during registration or via communication forms;
- Personal data included in CVs submitted through job application forms, such as education, marital status, residence, employment history, and insurance history.
PURPOSES OF PROCESSING
Art. 9. DISCORDIA processes personal data solely for specific and legitimate purposes and does not process them in a manner incompatible with those purposes, including:
- Recruitment and selection of employees;
- Providing information about DISCORDIA’s services upon inquiry;
- Contacting individuals who have expressed interest in DISCORDIA’s services;
- Managing inquiries and communication through the WEBSITE, including consent for receiving messages.
LEGAL GROUNDS FOR PROCESSING
Art. 10. DISCORDIA processes personal data on the basis of Article 6(1)(b) and Article 6(1)(f) of the GDPR, namely:
- (b) processing is necessary for the performance of a contract or to take steps prior to entering into a contract;
- (f) processing is necessary for the purposes of legitimate interests pursued by the controller, except where overridden by the interests or fundamental rights and freedoms of the data subject.
DATA DISCLOSURE
Art. 11.
(1) DISCORDIA may disclose personal data only to competent public authorities legally entitled to request such data (courts, investigative authorities, police, prosecution, national security agencies, supervisory authorities).
(2) DISCORDIA does not transfer personal data to third countries outside the EU.
DATA RETENTION PERIOD
Art. 12. Personal data retention depends on the processing purpose and shall not exceed statutory limits. Specifically:
- Job application data: up to 6 months unless extended with explicit consent;
- Service request data: until communication ends or contractual steps commence;
- General inquiry data: until the purpose is fulfilled or legal grounds cease;
- Registered user data: until account termination.
DATA SECURITY
Art. 13. DISCORDIA applies appropriate technical and organizational measures to ensure personal data security, including data minimization, confidentiality obligations, recovery procedures, and SSL SwissSign certificates for encrypted data transmission and website authenticity protection.
RIGHTS OF DATA SUBJECTS
Art. 14. Data subjects have the right to:
- Access and obtain copies of their personal data;
- Rectification of inaccurate or incomplete data;
- Erasure of unlawfully processed data;
- Restriction of processing;
- Objection to processing;
- Data portability where applicable;
- Not to be subject to automated decision-making, including profiling.
Requests may be submitted electronically. DISCORDIA responds within 30 days.
PROTECTION OF DATA SUBJECTS’ RIGHTS
Art. 15. Any individual who believes their personal data rights have been violated may lodge a complaint with the Bulgarian Commission for Personal Data Protection at:
Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., website: www.cpdp.bg.