PRIVACY POLICY
NEW I JSC

I. Introduction

This policy describes how we use your personal data that we collect through our website (https://new-i.com/en/) as well as outside it, while explaining your rights regarding your personal data and how you can exercise these rights.
The protection of your personal data is important to us and we therefore follow the resulting commitments to protect the privacy of the personal information you provide us, striving to strictly adhere to the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council from April 27, 2016 year regarding the protection of natural persons in connection with the processing of personal data data and on the free movement of such data and to repeal the Directive 95/46/EO (General Data Protection Regulation or GDPR) and the Bulgarian Personal Data Protection Act.
When we collect personal data, we follow the principles of data minimization, lawfulness, transparency and security. We only process personal data that is essential and appropriate for the purposes of our activity.

II. Controller’s contact details

The controller of personal data is New I JSC, UIC: 200765778, with headquarters: Sofia, 1000, 27 Petar Parcevich St, represented by Dimitar Atanasov Ganev – CEO.
Requests, inquiries and any other information related to the processing of your personal data can be received at the following email address: new-i@new-i.com; by phone: 02/ 937 66 66, as well as by sending a letter to the physical address indicated above.

III. Categories of processed personal data, purposes of processing, legal grounds and data retention terms.

In its capacity of controller, New I JSC processes only that information (categories of personal data) that is necessary and related to its activity, as follows:
• When requesting a consultation through the online form on our website (https://new-i.com/en/contacts/):

Categories of personal data processed: When you contact us through the online contact form, we process the personal data you provide us – names of contact person, telephone, email address.
Regardless of the reason why you share your personal data with us, we recommend that you do not disclose sensitive personal information: such as data about racial or ethnic origin, religion, trade union membership, sexual orientation, health status, etc.
Purpose: We use the data to respond to your inquiry.
Grounds: The basis on which we process your personal data is your consent (art. 6, par. 1, “a” of the GDPR).
Data retention: Your personal data provided when contacting us will be stored by us for the period in which we conduct communication and up to 1 month after its completion.

• When concluding and executing contracts:

Categories of personal data processed: If you conclude a contract for services with New I JSC, we process the following data provided by you: data of a contact person (names, address, telephone, email address), data of a representative/proxy (names, address, phone, email address).
Purpose: Individualization of you as a subject and contact with you in connection with the conclusion and execution of a contract.
Grounds: We process the listed personal data on the basis of the conclusion and performance of the contract between you and New I JSC, as well as for the purposes of our legitimate interest to make legal claims or defend ourselves against such. Part of your data is also processed on the basis of compliance with our legal obligations to issue documents according to the applicable accounting and tax legislation.
Data retention: Your data processed for the purposes of complying with our legal obligations under tax and accounting laws may be stored for the maximum ten-year period established by the Bulgarian Accounting Act, the Bulgarian Added Value Tax Act and the Bulgarian Tax and Social Insurance Procedure Code. Your data, processed for the purposes of fulfilling the contract concluded with us, can be stored in our database until the expiry of the five-year limitation period for the obligations arising from the contract concluded between the parties.

• When subscribing to our electronic newsletter, through our website (https://new-i.com/en/):

Categories of personal data processed: When you contact us through the online contact form and give explicit consent to receive news and messages from us or subscribe to our e-newsletter, in the form specially created for this on our site, we process the personal data you provide us – contact person names, telephone, email address.
Purpose: Carrying out marketing and promotional campaigns (by sending all kinds of messages, using electronic messaging channels: email/SMS/web push, etc.), which contain general and thematic information, information about our services, information about offers and promotions), monitoring or improving the performance of our website, as well as to improve the services we offer.
Grounds: The basis on which we process your personal data is your consent (art. 6, par. 1, “a” of the GDPR).
Data retention: Your data will be stored until you withdraw your consent, which you can do at any time by using the “Unsubscribe” link in the messages we send, or by using the contact details set out in this Privacy Policy.

• When visiting the website of New I JSC:

When visiting the Internet site of New I JSC, we may collect and process your personal data through the so-called “cookies”. For information processed in connection with cookies, please read our Cookie Policy available on our site (https://new-i.com/en/cookie-policy/).

IV. Categories of recipients of personal data outside New I JSC

We will not share or distribute your data for marketing purposes to third parties.

We disclose personal data:

1. To state bodies and bodies charged with public functions, within the framework of their powers, for the purposes of fulfilling legal obligations (Ministry of the Interior, Tax Administration, etc.);
2. To our consultants, for accounting and legal compliance purposes (accountants, auditors, lawyers);
3. In court or in arbitration, for the purposes of legal defense of New I JSC;
4. To the Internet e-newsletter platform Mailchimp (https://mailchimp.com/), owned by The Rocket Science Group LLC, part of the Intuit Inc group, which we use for its proper storage. This data may be used by Mailchimp for important business purposes such as billing, administration, security and product improvement. More details about your rights and how your data is protected by Mailchimp can be found in their Terms of Service (https://mailchimp.com/legal/terms/) and their Global Privacy Policy (https://www.intuit .com/privacy/statement/).
We will never sell your information to third parties or use it for purposes for which we have not notified you and you have not given your prior consent.

V. Your rights

As a data subject, you have the right to receive confirmation and/or detailed information, incl. a copy of the personal data processed for you (right of access).

In addition, you can object to the collection and further processing of your personal data, as well as request that they be corrected (updated) or deleted (when there is no valid legal basis for us to continue processing them).

You also have the right to request restriction of processing, i.e. to require the controller to process them for specific purposes when they cannot delete them due to a legal obligation.

In cases where we process your data on the basis of a legitimate interest, you have the right to object to the processing if you consider that we do not have one.

You have the right to receive the data we process for you in a structured, widely used and machine-readable format, as well as to transfer it to another controller (right to data portability).

Also, it is important to know that when the basis for data processing is your consent, you can withdraw it at any time.

To ask questions about your rights or if you wish to exercise any of them, please contact us at the contact details provided in this policy. We will respond to any of your requests without undue delay within 30 days of receiving the request. If we are unable to do so for reasons beyond our control, we will notify you in a timely manner, including for the reasons for the delay. In case of doubt, we may request additional information to confirm your identity. If you request to exercise any of the above rights and this request is clearly unfounded, or if you express a particularly frequent desire to exercise your right, we may require you to pay a corresponding processing fee or even reject your request.

If you believe that your data protection rights have been violated, you have the right to file a complaint with the Commission for Personal Data Protection: Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd, e-mail: kzld@cpdp.bg.

This Policy may be updated at any time. In the event of significant amendments, we will further notify you by sending a message via email or SMS.

17 October 2022