Privacy Policy

Introduction

D.M. Security Group Ltd.respects the privacy of employees, providers and partners and any other personal data, which the organization processes from various sources and guarantees to a maximal degree the protection of their personal data.

D.M. Security Group Ltd. offers complex licensed services in the sphere of security.

The objective of this Privacy Policy of D.M. Security Group Ltd. is to protect “the rights and the freedoms” of the natural persons and to guarantee that the personal data are not processed without their knowledge, and, where possible, that they are processed with their consent.
This Policy is applied for all the employees / customers of D.M. Security Group Ltd. Each infringement of the General Regulation shall be deemed as infringement of the labor discipline, and in event that there is a presumption for a crime committed, the matter shall be presented to the relevant state authorities for consideration within the shortest possible term.
This Privacy Policy determines the rules which shall be observed by D.M. Security Group Ltd. at the processing of the personal data we collect from or about you, or which you provide us with. This Privacy Policy does not concern, limit and repeal your rights ensuing from the Personal Data Protection Act (PDPA) or other relevant legislation.

If you have any queries or comments pertaining to this Personal Data Protection Policy, please, contact us at address: contact@security-dm.com

Who processes and bears responsibility for your personal data

DM. Security Group Ltd. is data controller with regard to its employees and data processor pertaining to the principals under contracts, whose Party it is.
The management address of D.M. Security Group Ltd. is: city of Sofia – 1510,

Str. Vasil Kunchev 26, Business Centre “Stefan Karadzha”,ent. D, floor 3.

E-mail: contact@security-dm.com

Tel: +359 2 868 0306

Categories of personal data processed by D.M. Security Group Ltd.

DM. Security Group Ltd. may process the publicly accessible personal data and/or the personal data provided by you.

The main types of personal data processed shall be:

Information about personal identification ;
Information about the sphere of activity (inclusive of education, educational institution, place of work, position occupied and so on);
Contact data (inclusive of mail and electronic addresses, telephone and fax numbers and so on);
Financial information (bank account and so on);
Information about a representative (legal representative or proxy of our customer legal person;
Data from the communications between us and you;
The data received at the fulfillment of the obligations ensuing from the legislative acts (i. е., data ensuing from inquiries, regulations, investigating bodies, Notary Public, tax services, Court, an enforcement agent);
The data received at the fulfillment of the contractual obligations (inclusive of name, PIN, address, telephone and/or address of the electronic mail and so on).

D.M. Security Group Ltd. may process data developed and generated by the Company in the process of provision of the services:

Video recordings at the execution of the main subject of business activity under contracts for security services rendered by the Company related to video surveillance;
Personal data of the natural person (names, PIN, addresses and other data depending on the goal and the requirements of the Principal under a Security Contract) in connection with the realization of access control of sites of customers under Security Service Contracts.

Aimed at guaranteeing the good provision of the services and of the obligations ensuing from customer’s contracts, D.M. Security Group Ltd. shall be entitled to process any information which is available in public registers (inclusive of public database and data announced on Internet) as well as information received from third parties with regard to performance of legal provisions pertaining to customers.

D.M. Security Group Ltd. shall have the right and the obligation to verify the accuracy of the personal data entered into the database, for the purpose requesting you to verify the data and if needed, to rectify them or to confirm the correctness of your data.

Objective and legal grounds for personal data processing

Personal data processing which is needed for conclusion or execution of contracts with us by natural and legal persons or in connection with preparation for conclusion of contracts.

D.M. Security Group Ltd. processes your data for the following purposes:

Identification of a customer at the conclusion of a new or amendment of an existing contract with us, clarification for the services used, execution of a contract concluded.
Development of proposals for conclusion of contracts, sending pre-contractual information and a draft of a contract;
Data received from you at the fulfillment of obligations ensuing from contracts (Employment Contracts, contracts under the Obligations and Contracts Act, public procurements and so on);
Servicing and answers to customers’ complaints / inquiries / grievances;
Technical maintenance and elimination of damages and any technical problems – in situ;
Payment of liabilities, rescheduling of amounts due;
Data received from you at enrollment for trainings.

In fulfillment of its legal duties, D.M. Security Group Ltd. processes your data for the following purposes:

For exercise of control by the authorities of the Ministry of Interior through declaring data of employees and customers, in compliance with the requirements of the Law on Private Security Activities, the Ministry of Interior Act and the Ordinances on their implementation.
Issue of invoices;
For exercise of tax and social insurance control by the relevant competent bodies;
Obligations stipulated in the Accountancy Act, the Tax and Social Insurance Procedure Code and other related legislative acts, in connection with keeping proper and lawful accountancy by a hired accounting house.

D.M. Security Group Ltd. processes the relevant data on the grounds of:

Contracts signed;
Legal requirements;
Protection of its legitimate interests as a Party under Contracts;

Categories of third persons which are provided with access to and process your personal data

Transport / courier’s companies, postal operators with a view to the fulfillment of our contractual obligations, sending correspondences and communications in connection with contracts;
Providers of the service for collection of debts, a Notary Public, a lawyer, an enforcement agent or another third person, if an employee and/or a customer violated the obligations ensuing from a contract with us;
The banks servicing the payments made by and to employees and customers;
Persons whom D.M. Security Group Ltd. assigned the implementation of a part of the activities or the obligations related to a specific service we owe you to;
Persons rendering consultancy services in various spheres – lawyers, accountants and so on;
Authorities, institutions and persons, which we are obligated to present personal data to under the virtue of the effective legislation;
Principals, bodies of the executive power, processing the video recordings from sites, which D.M. Security Group Ltd.exercises monitoring control in;
Principals keeping registers in the process of provision of the access control in sites protected by the Company.

What term are your personal data stored for?

The duration of storage of your personal data depends on the purposes of the processing they were collected for.

The personal data processed aimed at conclusion / amendment and execution of contracts between D.M. Security Group Ltd. and you or a company represented by you – for the term of effect of the Contract and up to the final settlement of all the financial relationships between the Parties. D.M. Security Group Ltd. may store some of your personal data also for a longer term up to the expiration of the relevant limitation period aimed at defense in events of possible claims of employees and/or customers in connection with the execution / the termination of contracts with us, as well as for a longer term in event of an already arisen legal dispute up to its final settlement by an effective court decision / arbitration award;

The personal data processed aimed at issue of accounting / financial documents for the exercise of the tax and social insurance control, such as but not limited to – invoices, debit, credit notes, Delivery and Acceptance Protocols, contracts for provision of services / goods shall be stored for at least 11 years after the expiration of the limitation period for the redemption of the public receivable, unless the applicable legislation anticipates a longer term.

Photography and/or video data presented by you at participation in training programs and/or issue of a distinctive mark (a service card) and so on – up to the explicit withdrawal of the consent given or the receipt of an objection for processing personal data in connection with the conduct of training and/or in execution of an Employment Contract.

Data from video recordings from security cameras – up to 60 (sixty) calendar days from the creation of the recording.

Your rights in connection with the processing of your personal data

General rights

You have the following rights with respect to personal data processing, which you may exercise any time whilst we store or process your personal data, sending an application to the address of D.M. Security Group Ltd., indicated hereinabove or in an electronic manner to e-mail: contact@security-dm.com

You are entitled to request from D.M. Security Group Ltd.:

A copy of your personal data and access to them at any time;
To rectify without undue delay your inaccurate personal data as well as the data which are no longer current;
Your personal data in a kind convenient for transfer to another data controller (right to data portability);
Your personal data to be erased without undue delay with the availability of any of the legal grounds for the purpose;
To restrict your personal data processing and in this event your data shall only be stored but not processed. Our refusal for restriction shall be explicit solely in writing and we shall be obligated to motivate it with the legitimate reason;

You are also entitled:

To withdraw your consent for your personal data processing at any time by a separate request made to D.M. Security Group Ltd. at processing based on consent given;

To object to your personal data processing;
To object to automated processing, profiling included;

You are entitled to a complaint to the Supervisory Authority

You are entitled to submit a complaint directly to the Supervisory Authority.

Automated decision-making

The Controller shall not use your personal data for automatic decision-making. In event that we intend to use your personal data for automated decision-making, you are entitled to be notified about that as well as to receive information about the logic of each automated personal data processing referring to you.

Objection to use for direct marketing purposes

You are entitled to object to the processing of your personal data for direct marketing and advertising purposes in the future, as well as to their disclosure to third persons and their use on their behalf for direct marketing and advertising purposes withdrawing the consent given by you at any time. For the purpose you may send an electronic message with the relevant request for suspension of the use of your data for direct marketing purposes at address: contact@security-dm.com.

Can you refuse the presentation of personal data to D.M. Security Group Ltd. and what are the consequences from that?

To conclude a contract with you and/or to provide you with the services declared and/or to supply the goods ordered in conformity with our legal and consequently contractual obligations, D.M. Security Group Ltd. needs certain data which should identify the Party under the Contract, its Proxy, contact data, data about the payment of the liabilities.

The non-provision of such data shall obstruct our possibility to conclude a contract with you.

How do we protect your data?

D.M. Security Group Ltd. applies organizational, physical, information technological and other needed measures to guarantee the security and the protection of your personal data and the monitoring of the personal data processing.

Inter alia, such security measures shall include the following activities:

DM. Security Group Ltd. established the requirements for processing, registration and storage of personal data by internal procedures, the observation of which is constantly monitored;
The access of the employees of D.M. Security Group Ltd. to personal data and the permission for personal data processing in the database of D.M. Security Group Ltd. shall be limited depending on their obligations;
The access to the office equipment of D.M. Security Group Ltd. and the computes of each employee is limited;
We apply all the needed organizational and technical measures anticipated in the Personal Data Protection Act as well as the best practices from international standards;
Aimed at maximal security at processing, transfer and storage of your data, we may use additional mechanisms for protection as encryption, pseudonymization and so on.

The security measures we apply are subject to permanent improvement and adaptation to the most state-of-the-art technologies.

Personal data about children

We consciously do not collect personal information from children under the age of 16, except at presentation of sick leaves by our employees for their children and/or at the exercise of access control as an obligation imputed by our customers (principals) under security contracts;

Amendments of the Privacy Policy

We may periodically update our Personal Data Protection Policy. An announcement shall be published on our web site at amendment in this Policy.

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