ECOPACK BULGARIA AD (hereinafter referred to as Ecopack, the Organization or the Controller) is an organization engaged in repurposing packaging waste as well as preserving the environment and its resources. Ecopack aims to raise social awareness and inspire positive action in the sphere of recycling and environmental protection. We appreciate your interest in our mission, campaigns and initiatives. Thank you for visiting our Website. This Policy is intended to inform you of the way we process your personal data.
Personal data protection
In order to be as useful as possible through its Website, in certain cases Ecopack shall process personal data of users of the Website and as such it is a Controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter referred to as General Data Protection Regulation, GDPR or the Regulation).
The security of your information is an important part of Ecopack's by-laws. As a Controller, Ecopack shall handle with priority the issues relating to the protection of your personal data collected when you visit our online platforms and during the processing and storage procedures in compliance with legal requirements.
Contacting the Controller
ECOPACK BULGARIA AD is a company that is registered with the Bulgarian Commercial Register under UIC 131210347, having its seat and registered office at: Sofia 1750, Mladost, 60 ‘Tsarigradsko shose’ Blvd., floor 1. You can contact the Controller in one of the following ways:
- in writing to this address: Sofia 1750, Mladost, 60 ‘Tsarigradsko shose’ Blvd., floor 1;
- on this phone number: 02/40 19 100;
- at this е-mail address: firstname.lastname@example.org;
- through this Website: http://www.ecopack.bg/;
- Point of contact: Mariana Petkova
Collection, processing and use of personal data
Accessing the information on Ecopack’s website does not require the provision of personal data on your part. Nevertheless, the website contains the following functionality which allows you to:
- Subscribe to Ecopack’s newsletter to receive new content notifications to the email address you provided us with;
- Use the free ‘Green Telephone Line’ for submitting an inquiry;
- Submit an inquiry through the provided contact form regarding any of our activities that may be of interest to you;
- Use the ‘Ecopack Online’ platform, available to certain registered users - clients and partners;
- Participate in one of Ecopack’s campaigns;
- Use Ecopack’s blog to comment on any topics that may be of interest to you.
Data processing categories and reason for processing
Ecopack collects and processes the following personal data:
- Data collected through the newsletter subscription form
If you want to subscribe to Ecopack’s newsletter and receive new content notifications, you can use the provided form found on our website. By filling it in, you voluntarily provide us with your personal data - email address. It is then processed on the basis of your explicit consent, given when filling the form in.
- Data collected through the ‘Green Telephone Line’ service
Ecopack strongly believes that its activities should be clear and transparent and thus provides a free opportunity for citizens to use the free ‘Green Telephone Line’ for submitting inquiries regarding separate waste collection. The personal data provided in such cases comprises name, telephone number and any other data you choose to provide during the phone call. The basis for processing your personal data in this case is your explicit consent, given at the start of the conversation.
- Data collected through the contact form
If you want to submit an inquiry to Ecopack, you can do so through the provided contact form. We will do our utmost to respond to all inquiries regarding any of our activities that may be of interest to you. By submitting your enquiry, you provide us with your email address as well as any other personal data you deem necessary. The basis for processing your personal data in this case is your explicit consent, given when filling the form in.
- Data collected through the ‘Ecopack Online’ platform
Ecopack has developed the ‘Ecopack Online’ platform for reporting and administration purposes and has thus made the software available to its clients and some of its partners. Access to the service is gained through registration which requires an email address and a password. The basis for processing your personal data is the contractual relationship with the company which specifically covers matters of personal data processing through the platform.
- Data collected through Ecopack’s blog
Ecopack encourages users to openly share their opinions and exercise their civic duties in all matters related to recycling and preserving the environment. Thus, we offer our users the opportunity to comment on various topics on Ecopack’s website by providing a name, email address and any other data they deem necessary. The email address you provide is not visible to the rest of the blog users and is processed solely by Ecopack. The name and any other personal data you choose to provide in your comment will be part of the blog’s public content and as such will be available to the other users. By posting your comment you make your name and other data included in the comment publicly available.
- Data collected through campaign participation
Ecopack run various yearly campaigns. The personal data processed for the purposes of said campaigns can vary and is listed in the terms and conditions of each specific campaign.
- Other data
Besides the above listed personal data collected by Ecopack, in case of use of certain functions of the Website, the following data may be additionally processed:
- Log files related to security, technical maintenance, development etc.
Log files are files that record events that occur in and between operating systems or other software and/or between users and a given operating system or software. On our website we use log files for the following purposes:
We do not store log files with user data. The server to which each website user connects stores access and error log files which can be useful for identifying threats such as hacker attacks and others.
Cookies are small text files that may be saved on your computer or mobile device when you visit a website. A cookie will help the Website or other websites to recognise your device the next time you visit it. Web beacons or other similar files can do the same. In this Policy, we use the term cookies to refer to all the files collecting information in this manner.
Purposes and legal bases for processing
Ecopack processes your personal data for the following purposes:
- To inform you of recent developments related to Ecopack’s activities by sending you new content notifications to the email you have provided us with.
- To respond to an inquiry you submitted and to inform you of actions undertaken by Ecopack for the prevention or cessation of violations.
- To respond to your inquiries - we use the personal data you provided us with through the contact form on our website in order to communicate back and respond to your inquiries.
- To improve the quality of our work and to provide you with faster, easier and more effective ways of performing your duties as clients of Ecopack, including the duty of accountability.
- To raise awareness and bring attention to matters related to recycling and preserving the environment as well as to inform society of the progression of various initiatives and campaigns organized by Ecopack.
- To encourage the exercise of civic duties on various matters related to Ecopack’s activities and to encourage and initiate debates on various matters related to environmental protection.
- To carry out the games and campaigns we have organized in line with the predetermined conditions.
- To protect Ecopack’s legal interests in promoting its activities and performing tasks in the public’s interest as well as those arising from contractual relationships with clients.
If you object to the processing of your personal data for the fulfillment of some of the above listed duties, please contact us.
Children’s personal data
Some of Ecopack’s campaigns are aimed at encouraging children’s interest in the field of recycling and environmental protection. The participation and processing of personal data of children under the age of 14 is only possible with the explicit consent of their legal guardians - parent/guardian, and for children of the age of 14 but under the age of 18 - with the consent of the child and a parent/guardian.
Disclosing data to third parties
Ecopack may disclose your personal data to the following categories of recipients:
- Government bodies, institutions and individuals to whom we are legally obliged to provide personal data;
- Individuals tasked with tech maintenance, software and hardware, used for the processing of personal data;
- Partners who are contractually tasked by Ecopack to work and help us provide you with our services and with whom we have signed confidentiality and personal data protection agreements.
We use service providers to process personal data for some purposes such as sharing user content, logging in with a social media profile and others. These companies are (the list is non-exhaustive):
- Google (with Google Analytics, Google Tag Manager, DoubleClick for Publishers, AdX, AdSense, AdWords, Google Plus): https://privacy.google.com
Transferring data to recipients outside of the EEA
Ecopack Bulgaria will not transfer your personal data to other countries from or outside of the European Union/ European Economic Area
Personal data retention period
Ecopack Bulgaria oversees the lawful processing and storage of your personal data. The retention period is the minimum required for the purpose for which the data is being processed and is dependent on the type of service:
- Data collected in relation to Ecopack Bulgaria’s newsletter is stored until you withdraw your consent to have it sent to you.
- Data collected through inquiries received through the ‘Green Telephone Line’ is stored for a period of up to 2 months after the last piece of correspondence sent regarding the submitted inquiry, thus after all the actions taken in response to the inquiry have been finalized.
- Data from the ‘Ecopack Online’ platform is stored in compliance with what is stipulated in the contract made with the respective client/ partner.
- Data related to the participation in one of Ecopack Bulgaria’s campaigns is stored in compliance with the terms and conditions of the respective campaign.
- Data provided through Ecopack Bulgaria’s blog is stored until consent is withdrawn.
Games and campaigns
If you take part in one of Ecopack Bulgaria’s games and campaigns, your data is used for the purpose of your participation in the respective game or campaign as well as to promote Ecopack’s activities insofar as it is lawful and in line with your given consent. For more information about the processing of your personal data in the course of the games and campaigns please consult the respective terms and conditions.
Rights regarding the processing of personal data
In connection with the processing of your personal data by Ecopack, you have various rights protecting your interests. All rights listed below can be exercised upon submission of a request to Ecopack using the contact details provided in the Contact the Controller section. Ecopack shall make provision to respond to your request without undue delay.
- Right of access:
You have the fundamental right to receive confirmation from Ecopack at any time as to whether your personal data are being processed and for what purposes they are being processed, the categories of personal data being processed, the recipients of your personal data, the processing time, any automatic decision-making in effect, and your rights concerning processing. You thus exercise your right to access any personal data processed by us.
- Right to rectification:
If you consider that your personal data being processed are inaccurate, you have the right to request that Ecopack rectify them, as well as to request that your incomplete data be completed. You can also do so by submitting a declaration to that end to Ecopack.
- Right to erasure:
As an individual whose personal data are processed by Ecopack, you have the right to request that the Controller erase them in the following cases:
a) the personal data are no longer necessary in relation to the purposes for which they have been collected or otherwise processed; b) you withdraw the consent on which the processing of your personal data is based; c) your personal data have been unlawfully processed; d) you have objected to the processing of your personal data and there are no overriding legitimate grounds for processing; e) personal data must be erased in order to comply with the law of the European Union or the Republic of Bulgaria.
- Right to restriction of processing:
Another right of yours related to Ecopack processing your personal data is to request, insofar as the legal requirements have been met, that Ecopack restrict the processing of your personal data in the following cases: a) you dispute the accuracy of the personal data – for a period enabling Ecopack to verify the accuracy of your personal data; b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; c) Ecopack no longer needs your personal data for the purposes of processing, but you require the restriction of their processing for the purposes of establishing, exercising or defending legal claims.
- Right to object to processing:
Insofar as your personal data is subject to processing by Ecopack, you have the right to object at any time to such processing. In this case, Ecopack shall suspend the processing of your personal data unless there is any other legal basis for further processing such as compliance with legal requirements or other legitimate interests that require further processing, which fall outside your rights and interests or for the purposes of establishing, exercising or defending legal claims.
- Right to withdraw your consent:
The processing of your personal data by Ecopack,where based on your explicit consent, may be terminated by withdrawal of your consent. This right of yours has immediate effect without prejudice to the lawfulness of any processing based on consent before its withdrawal.
- Right to data portability:
You have the right to receive a copy of the personal data you have provided to Ecopack, including, where possible, in electronic form. You may do so by requesting Ecopack to give you your personal data in a structured, commonly used and machine-readable format. In this regard, you may also request Ecopack to transmit these data directly to another controller at your direction.
- Right to lodge a complaint with a supervisory authority:
If you consider that your personal data are processed unlawfully or your rights in relation to them have been infringed, you have the right to lodge a complaint with the competent Bulgarian supervisory authority – the Commission for Personal Data Protection (CPDP). You can contact CPDP using the following contact details:
Address: Sofia 1592, 2 Professor Tsvetan Lazarov Boulevard Telephone: 02/91-53-518 E-mail: email@example.com
If you have any additional inquiries regarding the collection, processing and use of your personal data, you can contact Ecopack through any of the means listed in the Contacting the Controller section. Ecopack will do its utmost to respond to all of your inquiries in a timely fashion.