Privacy Policy
"Kozloduy NPP – New Build" is a public limited company, EIK 202058513, with registered office and management address in the town of Kozloduy, postcode 3320, 1A „Panayot Hitov“ Street (hereinafter referred to in the present transparency notice as „Kozloduy NPP - NB or„The company“) processes personal data of natural persons („data subject categories“) as required in the course of the Company's activities.
To the extent that "Kozloduy NPP – NB" determines the purposes and means of processing personal data, the Company acts as a personal data administrator and, as such, complies with the rules and requirements of Bulgarian and European personal data protection legislation.
Regarding the current General Transparency Notice
1.1 The current General Transparency Notice on the processing of personal data of "Kozloduy NPP – New Build" EAD („Transparency Notice“ or „The notice“) aims to provide individuals („data subjects“) with clear and transparent information on how and why Kozloduy NPP – New Build processes their personal data, for what purposes their personal data is processed, and to whom their personal data is provided in cases provided for by law or in the legitimate interests of Kozloduy NPP – New Build.
1.2 The transparency notice supplements and does not replace the other internal acts and notices adopted by Kozloduy NPP – New Build regarding the processing and protection of personal data.
1.3 Kozloduy NPP – New Build aims to ensure the lawful, transparent, and secure processing of your personal data by complying with the requirements of the applicable Bulgarian and European data protection legislation, the technical and organisational data protection measures adopted and introduced by the Company, including, but not limited to, by providing transparent, complete, and easily accessible information regarding the personal data processed by Kozloduy NPP – NEW MONARCHY.
1.4 This Transparency Notice in no way restricts or adversely affects your rights relating to the processing of your personal information, ensuring the transparent and fair processing of your personal data.
1.5 This Notice is published and freely available in the dedicated special section of the Kozloduy NPP – New Build website: ………. The Notice may be amended and/or supplemented at any time by Kozloduy NPP – New Build if the need arises or if the circumstances indicated therein change. If you wish to receive further information and/or have questions regarding the processing of your personal data, you can contact the Company using the contact details provided below.
The Company will assist you and respond to your questions and requests without undue delay.
2.1 Kozloduy NPP – New Build processes the personal data provided by you as a personal data administrator. The company collects and processes personal data in compliance with the principles for personal data processing set out in the General Data Protection Regulation, in particular, Kozloduy NPP – New Build processes personal data in compliance with the principle of „data minimisation,“ i.e. the personal data which Kozloduy NPP – New Build collects and processes are adequate, relevant to and limited to what is necessary in relation to the purposes for which they are processed.
2.2 The categories of personal data processed by Kozloduy NPP – New Build are determined by the purposes for which personal data are processed. Depending on the categories of natural persons („data subjects“), personal data may differ, and in some legally established cases, the Company is obliged to process a specific category of personal data.
2.3 Depending on the purposes for processing personal data and the legal basis for their processing, as well as the categories of natural persons („data subjects“) whose personal data are processed, e.g. (i) counterparties (legal representatives, authorised persons, employees); (ii) current and former employees of the Company; (iii) job applicants for the Company; (iv) persons who have reported to the Company; (v) visitors to the Company's premises and other natural/legal persons, Kozloduy NPP – New Builds may process personal data relating to your physical, physiological, economic, social or other type of identity, such as:
- 2.3.1 Names, national identification number (EGN, LNC), date of birth;
- 2.3.2 Contact details – address (permanent/work), telephone number (personal/work), email address;
- 2.3.3 Identity document data (to the extent necessary to achieve the processing objectives);
- 2.3.4 Information on education, work experience and practice, professional qualifications and experience;
- 2.3.5 Details regarding position held and place of employment.
- 2.3.6 Further data provided by you with regard to your specific situation.
The purposes of personal data processing are related to the activity carried out by Kozloduy NPP – New Build management and administration of the Company's human resources; interaction of the Company with state bodies and institutions, other legal and natural persons.
Depending on the relationship that arises between you and Kozloduy NPP – New Build, the purposes for processing your personal data may be, for example:
- Management and administration of the Company's human resources, including job applicants.;
- Management and administration of relations between Kozloduy NPP – New Build and its contractors;
- Management of signals, complaints and enquiries from natural and legal persons addressed to Kozloduy NPP – New Build;
- Carrying out internal audits and inspections at companies within the Kozloduy NPP – New Build holding group;
- Financial and accounting objectives;
- Protection of the property and assets of Kozloduy NPP – New Build;
- Exercising your rights under data protection legislation.
Depending on the purposes for processing your personal data, the existence or non-existence of a statutory obligation to process your personal data, the existence of a legitimate interest of Kozloduy NPP – New Build for processing personal data, and/or other specific circumstances related to your specific situation with Kozloduy NPP – New Build, the Company may process your personal data on the basis of at least one of the following legal grounds provided for in the General Data Protection Regulation:
- For the fulfilment of legally established obligations of Kozloduy NPP – New Build, in connection with which your personal data needs to be processed;
- Upon your provision of consent for the processing of your personal data (when no other legal basis for the processing of your personal data by Kozloduy NPP is applicable);
- For taking actions necessary for the conclusion of a contract with you or for the performance of a concluded contract;
- For the pursuit of the legitimate interests of the Company or a third party, unless those interests are overridden by the interests or fundamental rights and freedoms of the individual („data subject“);
- For the protection of your vital interests;
- Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in Kozloduy Nuclear Power Plant - NPP (to the extent applicable and relevant to the Company's activity);
- Processing is necessary for the establishment, exercise or defence of legal claims, whether in court, administrative or other out-of-court proceedings.
5.1 Kozloduy NPP – New Build will store and process your personal data only for the period necessary to achieve the personal data processing purposes stated above or to fulfil a statutory obligation. Kozloduy NPP – New Build will process and store your personal data only for the period necessary to achieve the personal data processing purposes stated above („storage limitation principle“).
5.2 Your personal data will be stored for a limited period of time, which is determined by (i) the existence of a legal basis for such storage of your personal data; (ii) the existence of a legally established minimum storage period for a certain category of personal data; (iii) the achievement of the purposes for which your personal data is processed; (iv) the legitimate interests of the Company, provided that such storage of your personal data does not affect your rights and interests in the protection of your personal data.
5.3 Following the cessation of the grounds for processing your personal data, the expiry of the legally defined minimum retention period for personal data, the achievement of the purposes for processing your personal data, and/or the existence of any other circumstance that renders the storage of your personal data unnecessary, Kozloduy NPP – NPP will take the necessary actions and measures to delete or destroy your personal data (depending on the medium on which your personal data was stored – paper and/or electronic data medium).
6.1 In connection with the achievement of the above-mentioned goals, your personal data may be disclosed to a certain category of recipients, but with strict adherence to the requirements of personal data protection legislation and to the extent necessary to achieve these goals.
6.2 Kozloduy NPP – NB does not disclose or provide your personal data, which it processes, to other natural or legal persons („personal data recipients“) without legal grounds and necessity to do so.
6.3 Depending on the specific relationship that has arisen between you and Kozloduy NPP – NPP, in connection with and within the scope of which the processing of your personal data is necessary, your personal data may be disclosed to the following categories of recipients:
- Kozloduy NPP - NB employees - Your personal data is disclosed to Company employees in accordance with the „need-to-know“ principle and to the extent necessary for the performance of their duties and the Company's activities.
- State bodies, institutions, agencies and other administrative bodies, where provided by law or regulation or where approval, authorisation or another type of sanction from such body/ies is required, with regard to and within the scope of the activity carried out by Kozloduy NPP – New Build EAD;
- Service providers, professional consultants and other contractors of Kozloduy NPP EAD (if and to the extent applicable in the specific case, e.g. suppliers of IT hardware support, hosting or the Kozloduy NPP EAD website, provision of legal, financial or other types of consulting services);
- To other persons or bodies, when provided for by law or regulation or when necessary for the performance of Kozloduy NPP – New Build’s specific activity in the energy sector.
6.4 Kozloduy NPP - NB will provide (disclose) your personal data to the above-mentioned recipients of personal data only when it is necessary and to the extent required to achieve the purposes of personal data processing, in compliance with regulatory or internal acts of the Company, without affecting your rights and legitimate interests for the protection of your data.
6.5 Kozloduy NPP – NB does not provide (disclose) your personal data to persons established in third countries outside the European Union (EU) or the European Economic Area (EEA).
7.1 In view of the performance of the statutory obligations of Kozloduy NPP – New Build as a personal data administrator, it is important for the Company to process and maintain your personal data accurately and up-to-date; in case of need, you can request your personal data to be updated, corrected and/or supplemented, for which purpose you can send an application to this effect to the Company, in compliance with the terms and conditions provided for in the personal data protection legislation.
7.2 You have certain rights under the data protection legislation regarding the processing of your personal data by Kozloduy NPP – New Build, as follows:
- Right to information and access to your personal data, the right to request a copy of your personal data stored or otherwise processed by Kozloduy NPP – New Build, and
- The right to request correction of your personal data if it is inaccurate, out of date, or incomplete, and
- Should you have any doubts that your personal data is not being processed lawfully, you have the right to lodge a complaint with the competent data protection supervisory authority, as indicated below in this Notice, and
- Provided the conditions and prerequisites stipulated in the personal data protection legislation are met, you also have the right to request the erasure of your personal data or restriction of its processing, as well as to exercise your right to data portability (provided the stipulated prerequisites and conditions for this are met), and
- The right to object, as well as rights related to automated decision-making – in cases provided for by law, you have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data, including where your personal data is used for profiling.
Please be advised that Kozloduy NPP – New Builds does not process or use your personal data for profiling or automated decision-making.
It is important for you to know that the specific conditions and procedures for exercising your rights related to the protection of your personal data are governed in detail by the General Data Protection Regulation and the Bulgarian Personal Data Protection Act.Kozloduy NPP – New Build will provide the necessary assistance for the exercise of the rights granted to you by law.
7.3 If you wish to receive further information on how Kozloduy NPP – New Build processes your personal data, or if you have questions regarding the operation and application of this Transparency Notice for the Processing of Personal Data „Kozloduy NPP – New Build“ EAD, you may contact the Company at the following email address: ……… or to the management address of Kozloduy NPP – NM in the town of Kozloduy, postcode 3320, 1A Panayot Hitov Street.
Kozloduy NPP – NB strives to ensure the protection and security of your personal data by implementing appropriate technical and organisational measures for the protection of personal data.
The company has adopted and implemented personal data protection policies aimed at safeguarding your personal data from unauthorised access and misuse; securing information systems and protecting information, including encryption.
Should you have any questions regarding the lawfulness of the processing of your personal data, or require further information on how to exercise your rights related to the personal data processed by Kozloduy NPP – New Build, please contact the Company directly via the contact forms for Kozloduy NPP – New Build, located on the Company's website, at the Company's registered office address, or at the provided telephone numbers.
In the event that you believe that Kozloduy NPP – New Build is unlawfully processing your personal data, please contact us so that we can clarify the matter quickly and provide you with the necessary assistance to reach a satisfactory resolution for you.
You can also lodge a complaint with the Commission for Personal Data Protection:
Commission for Personal Data Protection (CPDP)Address: Professor Tsvetan Lazarov Blvd. 2, Sofia 1592 Telephone number: +3592/91-53-594
Email kzld@cpdp.bg Website www.cpdp.bg
