Privacy Notices
of SHEMHA HEALTH LTD
In relation to the new Regulation (EU) 206/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural person with regard to the processing of personal data and on the free movement of such data and considering SHEMHA HEALTH LTD’s aim to follow strictly its legal obligations especially considering the personal data protection rules, we would like to inform you about the following:
SHEMHA HEALTH LTD is a company registered under the Bulgarian legislation in the Commercial Register and the Register of the Legal Entities with Non-commercial Purpose at the Registry Agency of Republic of Bulgaria with UIC 206570393, having its registered address located in the City of Varna, postal code 9000, Odessos region, 26 Ivan Drasov. You could contact us through:
- correspondence address: Varna, 9000, Odessos region, 26 Ivan Drasov Str;
- telephone: +359 52604738;
- e-mail: [email protected]
- DPO: [email protected]
SHEMHA HEALTH’s day-to-day business activity requires processing of personal data of the following subjects:
- Employees;
- Job applicants;
- Clients and contracting parties – individuals and/or employees and company representatives;
- Visitors to the web-based Platforms and/or web pages owned by SHEMHA HEALTH, who have provided their own personal data in order to use it, and who are not part of any other category mentioned above;
With these Privacy Notices we would like to inform you about the personal data that we process, the purposes for which we process such data and about your rights in this respect.
We would like to inform you that SHEMHA HEALTH LTD’s web-based Platforms and/or web pages uses ‘cookies’ by which it collects information about the behavior of its visitors, including personal data. More information about the ‘cookies’, including what type of ‘cookies’ we use, etc. could be found in our Cookies Policy (click here).
1.1. Privacy Notices for Employees
SHEMHA HEALTH LTD processes its employees’ (current and former) personal data in its capacity of employer and as described herein below.
Employees’ personal data which we process include: names, EGN (unique personal identifier), address, ID document data, gender, physical identity data, health status data, remuneration, education, professional activity, professional qualifications, marital status, family relations, contact data (telephone, e-mail, bank account).
Your health status data are sensitive data which we process only when it’s legally required, in order to protect the vital interests of the data subject or of another natural person or when the data subject has given his/ her consent, also in the event that the processing is required for the purposes of fulfilling of obligations and/or for the execution of rights of SHEMHA HEALTH LTD under the labor legislation and/or social security legislation and for the purposes of the preventive or occupational medicine.
In the event that you do not provide us with the required information, including with the necessary personal data, no labor contract could be concluded between SHEMHA HEALTH LTD and you, and SHEMHA HEALTH LTD would not be able to fulfill its legal and contractual obligations resulting from its capacity of an employer.
In your capacity of SHEMHA HEALTH LTD’s employee we shall process your data for one or more of the following purposes:
- For the conclusion and/or execution of labor contract;
- To fulfill our legal obligations;
- For the purposes of the legitimate interests of SHEMHA HEALTH LTD;
- When the data subject has given his/ her consent.
SHEMHA HEALTH LTD shall not store your data for a period longer than the required for the processing purpose. We store your data following the legally defined periods as well as considering the volume, specifics and sensitivity of the data, the processing purposes and whether we could complete them with different means.
Once the purpose for which your data have been processed are met, or once there is no legal obligation and/or legitimate interest, we shall erase or delete your data in a secure way.
SHEMHA HEALTH LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Occupational medicine authorities, companies providing internal audition services, suppliers of human resource management services, suppliers of accounting, legal, IT, banking, insurance, social security, social services and/or other services providers for the performance of contractual or legal obligations, as well as for the protection of the legitimate interest;
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
SHEMHA HEALTH LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
1.2. Privacy Notices for Job Applicants
SHEMHA HEALTH LTD processes job applicants’ personal data within recruitment procedures and as described herein below.
The personal data of the job applicants that we process include: name, surname and family name, address, nationality, education, professional activity and professional qualification (including knowledge and practical skills), photo, contact information (telephone, e-mail, in particular cases – social media information), other data provided by the applicant.
In the event that you do not provide us with the information requested, including your personal data which is limited to that required for these purposes it will be an obstacle for you to be included in the recruitment procedure and it will negatively affect your chances of being selected for the applied position.
We shall process your data for one or more of the following purposes:
- For completion of the recruitment procedure under which you are applying;
- To fulfill or meet our legal obligations;
- For the purposes of the legitimate interest of SHEMHA HEALTH LTD or of a third party;
- When the data subject has given his/ her consent.
SHEMHA HEALTH LTD stores personal data of unsuccessful applicants for no longer than 6 (six) months after the recruitment process has been completed. We shall not store your data for a period longer than the required for the processing purpose. We store your data following the legally defined periods as well as considering the volume, specifics and sensitivity of the data, the processing purposes and whether we could complete them with different means.
Once we have met the purposes for which we process your data, or when there is no legal obligation and/ or legitimate interest, we shall erase or delete your data in a secure way.
SHEMHA HEALTH LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Companies providing internal audition services, suppliers of human resource management services, suppliers of accounting, legal, IT, banking, insurance, social security, social services and/or other services providers for the performance of contractual or legal obligations, as well as for the protection of the legitimate interest.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
SHEMHA HEALTH LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
1.3. Privacy Notices for Clients and Contracting Parties
SHEMHA HEALTH LTD processes its clients and contracting parties’ personal data in order to perform its contractual obligations and as described herein below.
The personal data of clients and contracting parties – individuals and/or employees and legal entities representatives, which we process are: names, EGN (unique personal identifier)/ date of birth or other ID number, address, professional qualification (including knowledge and practical skills), contact data (telephone, e-mail, bank account).
The provision of these data by you is voluntary and in the same time essential in order a contract between you and SHEMHA HEALTH LTD to be concluded. In this respect, we inform you that we could fulfill our contractual obligation only if we are provided with the respective information. In the event that you are not willing to provide your personal data, we inform you that no contract could be concluded between SHEMHA HEALTH LTD and you.
We shall process your data for one or more of the following purposes:
- For the conclusion or execution of a contract;
- To fulfill or meet our legal obligations;
- For the purposes of the legitimate interest of SHEMHA HEALTH LTD or of a third party;
- When the data subject has given his/ her consent.
The personal data that you have provided will be stored by SHEMHA HEALTH LTD in the period of the concluded contract. After its termination your personal data will be erased or deleted in a secure way except for the cases that there is a legitimate interest and/or a legal ground that obliges SHEMHA HEALTH LTD to maintain its storage and/or processing and/or the subject has given his/her consent for the additional storage.
SHEMHA HEALTH LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Companies providing internal audition services, suppliers of marketing and advertisement services, suppliers of accounting, legal, IT, banking and/or other services providers for the performance of contractual or legal obligations, as well as for the protection of the legitimate interest.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
SHEMHA HEALTH LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
1.4. Privacy Notices applicable to data processing in an online environment
The herein provided rules apply in special events of data processing in an online environment. Such events are these where contact forms, provided on the website of SHEMHA HEALTH LTD, are used by its visitors (including such that are not specified in any of the categories in item 1.1-1.3 above), as well as the cases of online registration for participation in events organized by SHEMHA HEALTH LTD (conference, training, seminar, etc.).
1.4.1 SHEMHA HEALTH LTD processes the following personal data of the visitors of its web based Platforms and/or web pages that have used one of the contact forms: names, e-mail, telephone number, content of the request/the message or any other statement.
We would like to inform you that SHEMHA HEALTH LTD’s web-based Platforms and/or web pages use ‘cookies’ by which it collects information about the behavior of its visitors, including personal data. More information about the ‘cookies’, including what type of ‘cookies’ we use, etc. could be found in our Cookies Policy (click here).
In addition, it should be noted that there are buttons on the website of SHEMHA HEALTH LTD providing links to other sites, social networks, etc. that lead to profiles of SHEMHA HEALTH LTD in the respective social networks. In the event that you are willing to use one or more of them, you shall consider the fact that by this action we will be provided with information about your participation in the respective social media.
The mentioned personal data are voluntarily provided by you and in the event that you are not willing to provide us with them, you shall be informed that you would not be able to use the functionality of the contact forms on our website, as well as some of the functionalities of our website.
SHEMHA HEALTH LTD processes the provided personal data for the following purposes:
- To process your request/ message or any other statement as well as to reply to it;
- For the conclusion of a contract (provided that your request/ message or any other statement falls under the respective conditions);
- For the purposes of the legitimate interest of SHEMHA HEALTH LTD or of a third party;
- When the data subject has given his/ her consent.
SHEMHA HEALTH LTD shall not store your data for a period longer than the required for the processing purpose. We store your data following the legally defined periods as well as considering the volume, specifics and sensitivity of the data, the processing purposes and whether we could complete them with different means.
Once the purpose for which your data have been processed are met, or once there is no legal obligation and/or legitimate interest, we shall erase or delete your data in a secure way.
SHEMHA HEALTH LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Suppliers of marketing and advertisement services; suppliers of legal services and to other services suppliers for the fulfillment of contractual or legal obligations, as well as for the safeguard of its legitimate interest.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
SHEMHA HEALTH LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
1.4.2 SHEMHA HEALTH LTD processes the following personal data of persons that have expressed their intention to participate in trainings, seminars, conferences and other events organized by SHEMHA HEALTH LTD by an online registration: name and family name, e-mail, telephone number, organization and position in the respective organization.
The provision of these data by you is voluntary and in the same time essential in order for you to take part in the organized training, seminar, conference or other event. In connection with that we inform you that SHEMHA HEALTH LTD could only fulfill its obligations if you have provided us with the respective personal data. In the event that you are not willing to provide us with these data, we inform you that SHEMHA HEALTH LTD could not be able to list you as a participant of the organized event (training, seminar, conference or other).
In addition, you should bear in mind that depending on the specific case the online registration could be performed through the opportunities provided by the social networks, etc. If you are willing to use them, you shall be informed that this will provide us with information about the social networks you take part in.
We shall process your data for one or more of the following purposes:
- For the conclusion or execution of a contract (for your participation in the respective event – conference, seminar, training, etc.);
- To fulfill or meet our legal obligations;
- For the purposes of the legitimate interest of SHEMHA HEALTH LTD or of a third party;
- When the data subject has given his/ her consent.
The provided personal data will be stored by SHEMHA HEALTH LTD until it is needed for the fulfillment of the purposes for which they are collected. After that your personal data will be deleted or erased in a secured way, except for the cases when there is a legitimate interest and or legal ground that obliges SHEMHA HEALTH LTD to maintain their storage and/or processing and/or a consent for additional storage for fulfillment of additional purposes has been given by the subject.
Once the purpose for which your data have been processed are met, or once there is no legal obligation and/or legitimate interest, we shall erase or delete your data in a secure way.
SHEMHA HEALTH LTD has the right to disclose your personal data only to:
- Its employees, whose professional obligations require processing of personal data on our behalf;
- Public bodies when it’s legally required or for the purposes of our legitimate interests;
- Companies providing internal audition services, suppliers of marketing and advertisement services; suppliers of accounting, IT, legal, banking and/or other services suppliers for the fulfillment of contractual or legal obligations, as well as for the safeguard of its legitimate interest.
You shall be informed that we shall not disclose your data to other external organizations, companies and/ or individuals except for the ones described herein above or only when it is legally required or you have given your consent in advance.
SHEMHA HEALTH LTD has implemented all appropriate technical and organizational measures with the objective of protecting your privacy and will update these measures as appropriate.
In case your data have been disclosed to third parties, we require that the adequate levels of protection have been implemented by them as well in order to safeguard the personal data as prescribed by the applicable legislation.
2. Rights of the Data Subjects
We would like to inform you that you have the right to require from SHEMHA HEALTH LTD access to personal data, right to rectification or erasure of personal data, restriction of the processing of the provided data, the right to object to the processing, the right of personal data portability, as well as the right not to be a subject to a decision based solely on automated processing These rights could be exercised by sending an explicit request in this respect to the following e-mail: [email protected] or in writing to the following address: Varna, 9000, Odessos region, 26 Ivan Drasov Str;
In those cases when processing is based on a consent, you have the right to withdraw your consent at any time. The withdraw can be done by explicit notification sent to the following e-mail: [email protected] or in writing to the following address: Varna, postal code 9000, Odessos region, 26 Ivan Drasov Str, It shall be noted that this will not affect the validity of the processing prior to the withdrawal of consent.
In the event that you assume that SHEMHA HEALTH LTD violates your legal rights regarding the collecting, processing and storage of the provided personal data, you may contact the Personal Data Protection Commission or the competent courts as you have a right to file a complaint in which you can submit your complaints.
3. Changes of the Privacy Notices
This Notices of SHEMHA HEALTH LTD are effective as of 30 June 2022, they could be revised periodically for which you will be notified in due time through an e-mail or in another appropriate way.