TRANSPARENCY IN INFORMATION PROCESSING

“MOTION ARTS” Ltd., in its capacity as a personal data controller within the meaning 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR), informs you what to expect when processing your personal information and how to exercise your rights in the event of unlawful processing of personal data.

SECURITY AND DATA PROTECTION

MOTION ARTS Ltd. applies the necessary technical and organizational measures to protect your personal data from any unlawful actions, including loss and unauthorized access. These include limiting access to personal data, strictly following the adopted Internal Rules for the measures and means of protecting personal data processed by MOTION ARTS Ltd., appropriate training of the persons responsible for the processing of personal data and compliance with good practices and guidelines for the protection of personal data from the relevant regulatory authorities.

This policy, the Internal Rules, as well as all measures are subject to regular review and are periodically updated. In the event of a breach of the security of your personal data, we will notify you within an appropriate period of time if there is a possibility that the breach of the security of personal data will lead to a high risk to your rights.

1. EACH SUBJECT OF PERSONAL DATA MAY RECEIVE AT LEAST THE FOLLOWING INFORMATION IN CASES WHERE “MOTION ARTS” LTD PROCESSES HIS/HER DATA REGARDING:
   the administrator and his/her contact details;
   the purpose and legal basis for the processing;
   the legitimate interests;
   the possible consequences if the personal data are not provided, in case the provision of personal data is mandatory or a contractual requirement, incl. for the conclusion of a contract;
   the categories of personal data processed;
   the period of storage of the personal data;
   the recipients or categories of recipients (if any) to whom the data are or will be disclosed;
   the intention to transfer personal data to a third country or international organization – information on the way in which “MOTION ARTS” LTD ensures that this is done in a secure manner;
   the means of exercising the rights of access, rectification, erasure, restriction, portability or objection to such processing;
   the means of exercising the right to withdraw consent to the processing of personal data without limitation in time;
   the means of filing a complaint with the Personal Data Protection Commission, as the national supervisory authority in the Republic of Bulgaria;
   the source of the personal data, if they are not collected directly from the data subjects;
   any details and information for automated decision-making, such as profiling.
   ADMINISTRATOR’S DATA AND COMMUNICATION CHANNELS “MOTION ARTS” OOD, registered in the Commercial Register at the Registry Agency with UIC 121446455, has its registered office and management address: Sofia 1172, Iztok district, Dianabad residential complex, 58 Vasil Kalchev Str., entrance 5, ap. 4.To contact MOTION ARTS LTD: Sofia 1784, 111 Tsarigradsko Shosse Blvd., Sofia Tech Park, Incubator Building, 3rd floor.

   E-mail: office@metroreklama.com

   Website: www.metroreklama.com

   INFORMATION THAT MAY CONTAIN YOUR PERSONAL DATA IS PROCESSED FOR THE FOLLOWING PURPOSES:

   for the administration of employment relations (staff and job applicants), the data categories being names, personal identification number, address, with retention periods in accordance with applicable legislation, fulfilling legal and contractual obligations;
   for the sales activities of the company (Clients), the data categories being names, address, contact telephone number, e-mail address, credit card details, with retention periods in accordance with applicable legislation, fulfilling legal and contractual obligations;
   ensuring the company’s deliveries (Counterparties), the data categories being names, address, contact telephone number, e-mail address, with retention periods in accordance with applicable legislation;
   carrying out video surveillance for security purposes, based on the legitimate interests of the administrator (Video Surveillance) in the common premises of the sites managed by the company. The data categories are records, with retention periods of 60 days;
   of special legislation (Special categories of personal data, including health), with retention periods in accordance with applicable legislation.
   In cases where there is no alternative legal basis (e.g. legal obligation, contractual relationship, legitimate interest), the consent of the data subjects is required.

2. PERIOD FOR STORAGE OF PERSONAL DATA “MOTION ARTS” Ltd. stores your personal data for the periods necessary to achieve the purposes for which they were collected. These periods are determined by the periods required to comply with the applicable Bulgarian and European legislation.
   Personal data of contractors based on contractual relationships are stored for a period of 10 years after the end of the relationship or for another period specified by law;
   Accounting documentation is stored for a period of 10 years, in compliance with legal requirements;
   Personal data for the purposes of personnel administration – up to 50 years, according to the current Bulgarian legislation;
   Video recordings from video surveillance for security purposes – 60 days.

   MOTION ARTS Ltd. takes all necessary technical and organizational measures to destroy data that is no longer needed, except in cases where there is a legal basis for processing for a longer period of time.

   DISCLOSURE OF PERSONAL DATA BY MOTION ARTS Ltd. TO THIRD PARTIES MOTION ARTS Ltd. does not provide your personal data to third parties, except when required by law. MOTION ARTS Ltd. does not provide your personal data to a third country or international organization.

   MOTION ARTS Ltd. does not carry out automated decision-making, including profiling, with respect to your personal data.

   The provision of personal data is mandatory in cases where they are necessary to comply with legal requirements or are related to the performance of a contract.

   In cases where personal data are processed on the basis of informed consent, data subjects have the right to withdraw the consent given at any time. Withdrawal of consent has effect going forward.

   USE OF COOKIES The website of “MOTION ARTS” Ltd. does not use HTTP cookies, or simply “cookies”. What are “cookies”

   “Cookies” are small text files that are saved on your computer or mobile device when you visit our website. They allow the website to remember your actions and preferences for a certain period of time so that you do not have to enter them every time you visit the site or move from one page to another, which helps us provide content that we believe will be useful and interesting to users.

   More information

3. More information about how cookies are used on the Internet can be found here: www.aboutcookies.org.

   Links to other websites

   This privacy policy does not cover links on the website of “MOTION ARTS” OOD to other websites. We recommend that you read the privacy statements of the other websites you visit.

   RIGHTS OF NATURAL PERSONS (DATA SUBJECTS) Every individual whose personal data is processed by “MOTION ARTS” OOD has all the rights listed in full below:
   Right to information According to the applicable legislation, every individual whose personal data is processed by “MOTION ARTS” OOD has the rights described below in this Policy. “MOTION ARTS” OOD is obliged to respond to any request for information within one month of its receipt without any fee being due. In the event of factual or technical difficulties in timely execution of requests, the execution period may be extended by another 2 months, of which we will notify you within 1 month of receiving the request.
   Right of accessAny individual whose personal data is processed by “MOTION ARTS” OOD may request confirmation of whether and what personal data about him/her are being processed, information related to their processing, access to these data and a copy of them.
   Right of rectificationAny individual whose personal data is processed by “MOTION ARTS” OOD may request correction or completion of these data in the event of processing of incomplete or incorrect personal data by the company.
   Right to erasure (right to be forgotten) Any individual whose personal data is processed by MOTION ARTS OOD may request the erasure of personal data in the following cases:
   the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
   you withdraw your consent on which the processing of the data is based and there is no other legal basis for their processing;
   you consider that the personal data have been processed unlawfully

   You may request the erasure of your personal data, to the extent permitted by law, unless the company proves that there are legitimate grounds for the processing which override the interests of the data subjects, or for the establishment, exercise and protection of the company’s legitimate rights and interests.

   Right to restriction of processingAny individual whose personal data are processed by “MOTION ARTS” OOD may request restriction of processing of such data, to the extent permitted by law, if:
   he contests the accuracy of the personal data, for a period that allows “MOTION ARTS” OOD to verify the accuracy of the personal data;
   the processing is unlawful, but the data subject does not wish the personal data to be erased, but requests, instead, the restriction of their use;
   “MOTION ARTS” OOD no longer needs the personal data for the purposes of the processing, but the data subject requires them for the establishment, exercise or defense of legal claims;
   the data subject has objected to the processing of the data pending verification of whether the legitimate grounds of “MOTION ARTS” OOD for processing the data override his or her interests.

   If you request restriction of processing, MOTION ARTS OOD will inform you before the restriction of processing is lifted.

   Right to data portability Any individual whose personal data are processed by MOTION ARTS OOD may request the data provided by him/her in a structured, commonly used and machine-readable format, when the following conditions are simultaneously met:
   the processing of the specific data is based on consent or on a contractual basis;
   the processing is carried out by automated means
   Right to object Any individual whose personal data are processed by MOTION ARTS OOD has the right, at any time and on grounds relating to his/her particular situation, to object to processing of his/her personal data.
   Rights in automated individual decision-making, including profilingEvery natural person has the right not to be subject to a decision based solely on automated means, if the decision produces legal effects concerning him or her or significantly affects him or her. You may exercise your rights as a data subject* under the General Data Protection Regulation.

   * These data will be used solely for the purpose of processing your request to exercise your rights as a data subject.

   FILING A COMPLAINT WITH THE NATIONAL DATA PROTECTION AUTHORITY As a data subject, you have the right to file a complaint with the supervisory authority:
   Personal Data Protection Commission
   Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
   E-mail: kzld@cpdp.bg
   Website: www.cpdp.bg
   CHANGES TO THE PRIVACY POLICYThe confidentiality and security of your personal data has always been of paramount importance to us. In this regard, “MOTION ARTS” Ltd. informs you that as of