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Privacy Policy of Dunapack Rodina JSC

This policy has been issued on the grounds of the Law on Protection of Personal Data, its regulatory acts, and in accordance with the provisions 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.

 1. Details and contact information

1.1. Controller/ Data processor:

Dunapack Rodina JSC

Main activity: Production and sale of corrugated paper and packaging thereof

A company entered in the Commercial Register of the Registry Agency with ID No 115010325

Seat and registered address: Plovdiv, bul. Maritsa 97

Mailing address: Plovdiv, bul. Maritsa 97

Contact phone: +359 32 904 501


1.2. Supervisory authority for personal data protection in the Republic of Bulgaria:


Address: Sofia 1592, bul. Tsvetan Lazarov 2,

Information and contact centre: +359 2 9153518,


2. What is “personal data” and what is “processing of personal data”?:

  • Personal data means any information by which a natural person can be identified, directly or indirectly, by reference to one or more factors specific to the person, such as name, ID/PIN, contact details: location/ postal address, telephone number, e-mail address, online identifier/ IP address, etc. These factors may be part of his or her physical, physiological, genetic, mental, economic, cultural or social identity.
  • Processing of personal data includes all activities performed with personal data or a set of personal data, such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, consulting, using, disclosing by transfer, dissemination, or other means by which data become available, arranging or combining, limiting, deleting or destroying.

3. Collection, storage and processing of personal data by Dunapack Rodina JSC in its capacity of Controller and Personal Data Processor.

 3.1. Purposes of personal data processing:

The main purpose of the processing of personal data of natural persons is directly related to the performance of the statutory activity of Dunapack Rodina JSC.

Personal data shall be processed for the purpose of:

  • Management of employment relationships;
  • Staff recruitment;
  • Contracting of goods and services;
  • Execution of orders;
  • Financial and accounting activities;
  • Other obligations arising in connection with the legal requirements referring to the activities of the Company.

Within this context, the Company shall process personal data of:

  • Full-time employees;
  • Job and internship applicants; 
  • Customers and suppliers of goods and services with which the Company enters into contractual relations within the its statutory powers and obligations.

3.2. Legal grounds to process personal data:
Data processing is carried out on the grounds of legitimate interest of Dunapack Rodina JSC in relation to obligations arising from the Labour Code, the Law on Health and Safety at Work, the Social Insurance Code, the Tax-Insurance Procedure Code, the Insurance Code, the Commercial Act, the Personal Income Tax Act, the Accounting Act, the Law of Obligations and Contracts, etc.

3.3. Types of data processed by Dunapack Rodina JSC:

Depending on the purposes for processing as defined in Article 3.1., and following the principle of data minimization, Dunapack Rodina shall process personal data limited to:

  • Name, telephone number, home address and e-mail address: for the process of contracting goods and services within the scope of activities;
  • Data required by the legislation to carry out employment and non-employment relationships;
  • Data provided in curriculum vitae of applicants for job and/or internship, in a selection procedure;
  • Video recordings from security cameras located at the sites of Dunapack Rodina JSC.
  • Data required by the legislation in connection with the Company’s main activity.

3.4. General principles of protection followed in the processing of personal data:

  • Legality, good faith and transparency;
  • Data processing for specific, explicit and legitimate purposes and prohibition on further processing in a way incompatible with these purposes;
  • Limitation of data to what is necessary in relation to the purposes for which they are being processed;
  • Updating if necessary;
  • Storage in a form that allows the persons concerned to be identified for no longer than it is necessary for the purposes for which they are being processed;
  • Processing of personal data at a high level of security applying appropriate technical and organizational measures.

3.5. Personal data privacy
Dunapack Rodina JSC shall not exchange, transfer or transmit personal information to any third party for any reason without the express consent of the person, except in the cases of its statutory obligations relating to the exercise of the main activity, or, if it is required to disclose any information to the competent authorities by virtue of a law, court decision or other statutory instrument.
3.6. Protection of information
Protection of data on hard copy or in electronic format from unauthorized access, damage, loss or destruction shall be performed and guaranteed by strict technical and organizational measures put in place.
3.7. Maximum period of retention of personal data
Dunapack Rodina JSC shall retain your personal information within the meaning of Article 3.3. for the period required for the implementation of the objectives set out in this Privacy Policy.
4. Rights of the persons whose data are being processed by Dunapack Rodina JSC
4.1. Right of access:
Any person whose data is processed has the right at any time to receive from Dunapack Rodina JSC the following information:

  • Purposes of the processing;
  • Personal data categories;
  • Recipients or categories of recipients to whom they are disclosed;
  • Period of retention of personal data.

4.2. Right to correction and deletion: at any time
Any person whose data is being processed may, at any time, ask Dunapack Rodina JSC for:

  • Correct any inaccurate personal data associated with the person, and fill in any incomplete personal data, if any;
  • Delete the personal data associated with the person in conformity with legal requirements.

4.3. Right to restrict processing:
This right may be exercised in the following cases:

  • Contest the accuracy of personal data provided for the period of verification of their accuracy;
  • If the processing is unlawful, but the subject does not want the data to be deleted, and only to limit their processing;
  • If data is unnecessary to the Controller, but the subject demands them to establish, exercise or protect legal claims;
  • For the period of verification in case of objection to the processing of personal data by the subject;

4.4. Right to data portability:
You have the right at any time:

  • To receive the personal data that concerns you and is given to Dunapack Rodina JSC, in a structured, widely used and machine-readable format;
  • To transfer this data to another controller without obstacles by Dunapack Rodina JSC where the processing is based on consent in relation to particular purposes, or a contractual obligation, and the processing is carried out automatically.

4.5. Right of objection
 You have the right at any time:

  • To object to the processing of personal data referring to you;
  • To ask for the processing of your personal data to be suspended, unless there exist from time to time compelling legal grounds for the processing, or establishment, exercise or protection of legal claims.

4.6. Right to submit a complaint:
If you believe that the processing of your personal data violates your rights or legal regulations, please contact us at the contact details listed in this document.
You have the right to complain to the Data Protection Supervisor in the Republic of Bulgaria in the person of the Commission for Personal Data Protection.
5. Children

Dunapack Rodina JSC does not collect or process personal data of children under the age of 18, except for a specific purpose related to social policy and limited to the maximum possible minimum. Data is collected and stored after the express consent given by the parent/ guardian.