Data Protection

This Personal Data Processing Policy has been prepared and is based on the current Bulgarian legislation in the field of personal data protection. All amendments and additions to the Policy will be applied only after publication of its current content, available through our website asclub.org

The Personal Data Processing Policy applies to your personal data if you are a natural person or representative of a legal entity that is a client of “AS CLUB” Ltd. It will explain what personal information we process when carrying out our activities, in connection with the application of Ordinance No. 3 of 25.01.2008 on the conditions and procedure for carrying out the activities of occupational health services /issued by the Minister of Health and the Minister of Labor and Social Policy, published in the State Gazette, No. 14 of 12.02.2008/, to monitor, analyze and assess health status in relation to working conditions of all served workers, including those with increased sensitivity and reduced resistance, and when conducting health and safety training; for what purposes we use it and what your rights are as a data subject.

Who processes and is responsible for your personal data

“AS CLUB” Ltd. is the commercial company registered in the Commercial Register with the Registry Agency with UIC 175373128, which collects, processes and stores your personal data under the conditions of this Privacy Policy.

“AS CLUB” Ltd. is registered in the public register of the Ministry of Health as a company providing services as an Occupational Health Service; performs control/measurements of workplace environment factors and is Accredited by the Bulgarian Accreditation Service (BAS) – registered in the BAS register; organizes preventive medical examinations; conducts health and safety training, provides consultations and coordinates activities for managing health and safety systems

“AS CLUB” Ltd. is a personal data controller within the meaning of the Personal Data Protection Act (PDPA) and is a Data Processor for clients of “AS CLUB” Ltd., according to Regulation (EU) 2016/679.

You can contact us at our management address:
Sofia 1302, “Stefan Stambolov” Blvd. No. 42, floor 1, apt. 2, tel: +3592/9719056
And/or by filling out the electronic contact form on our website asclub.org/kontakti

1. What data, for what purposes and on what legal basis we process

1.1. Depending on the specific purposes and grounds, “AS CLUB” Ltd. processes the data specified below independently or in combination:

a) Data provided by you, necessary for identification and fulfillment of the contractual obligations of “AS CLUB” Ltd. and the client:

  • three names, personal identification number or personal number of a foreigner, address, telephone and/or email address for contact with you, or a contact person designated by you;
  • three names, personal identification number, address and other data of your authorized representative or contact person, specified in the document with which you have authorized them to represent you before “AS CLUB” Ltd.;
  • data collected when concluding a contract with a client who provides data of their employees, including: three names, personal identification number, health status/diagnosis specified in medical certificate for employment, TELK decisions, card of performed preventive medical examinations, production characteristics;
  • data from your profile – history of requests/orders and history of contracts;
  • delivery address;

b) Data prepared and generated by “AS CLUB” Ltd. in the process of providing services:

  • service number, client number, detailed statements for monthly bills/invoices and amount of obligations contained therein;
  • traffic data – type of service provided, quantity of services provided to determine the value of the service; location for service provision;
  • data necessary for preparing client bills and/or invoices for services performed, as well as for proving their authenticity – type of service used; value of services used; information about your chosen payment method, payments made and due; information about changes in service usage and service restoration after signing an amendment;
  • information about the type and content of the contractual relationship, as well as any other information related to the contractual legal relationship, including data of client employees – names, personal identification numbers, health status/diagnoses;

1.2. Purposes and legal grounds for processing personal data:

a) Data processing that is necessary for concluding or performing a contract for service provision, a contract for occupational health service (OHS) maintenance.
b) In fulfillment of its legal obligations, “AS CLUB” Ltd. processes your data for the following purposes:


2. Categories of third parties who receive access and process your personal data:

2.1. Personal data processors who, based on a contract with “AS CLUB” Ltd. – process your personal data on behalf of “AS CLUB” Ltd. or have direct/indirect access to your personal data

  • Transport/courier companies for the purpose of fulfilling our contractual obligations for delivery of contracts on paper and/or prepared documents in connection with contract performance;
  • Medical centers and health facilities, doctors for the purpose of conducting preventive examinations and medical tests of workers, employees of “AS CLUB” Ltd. clients;
  • Persons who, on behalf of “AS CLUB” Ltd., maintain equipment and software used for processing your personal data;
  • Persons providing service support services for end devices;
  • Persons carrying out installation and/or maintenance activities at the service provision address;
  • Banks servicing payments made by you;
  • Security companies holding a license for private security activities, processing video recordings from “AS CLUB” Ltd. facilities and/or maintaining other registers in the process of ensuring access control in the same facilities;
  • Persons providing services for organizing, storing, indexing and destroying archives on paper and/or electronic media;
  • Persons performing consulting services in various fields.

2.2. Other personal data controllers to whom “AS CLUB” Ltd. provides your personal data, processing your data on their own basis and on their own behalf

Competent authorities who, by virtue of a normative act, have the power to require “AS CLUB” Ltd. to provide information, including personal data, such as: Bulgarian court or court of another state, various supervisory/regulatory bodies, Consumer Protection Commission, Communications Regulation Commission, bodies with powers for national security and public order protection;

3. For what period your personal data is stored

The duration of storage of your personal data depends on the processing purposes for which it was collected:

Personal data processed for the purpose of concluding/amending and performing a service provision contract is stored for the duration of the contract and until final settlement of all financial relations between the parties;

Personal data processed for the purpose of issuing accounting/financial documents for tax-insurance control, including but not limited to – invoices, debit notes, credit notes, acceptance-delivery protocols, service provision contracts, is stored for at least 5 years after the expiration of the limitation period for extinguishing the public claim, unless applicable legislation provides for a longer period.

“AS CLUB” Ltd. may store some of your personal data for a longer period until the expiration of the respective limitation period, for the purpose of protection against potential client claims in connection with contract performance/termination for service provision, as well as for a longer period in case of an already arising legal dispute in connection with the above until its final resolution with a final court/arbitration decision.

4. What are your rights in connection with the processing of personal data by “AS CLUB” Ltd.

As our client and regarding your personal data, you have the following rights:
4.1. To receive access to your personal data and information of the type we have included in this Privacy Policy regarding the data in question. You may request from “AS CLUB” Ltd. information whether and for what purposes we process your personal data with a written application with the content specified in Art. 29 PDPA;

4.2. To request that your personal data be deleted, corrected or blocked when it is inaccurate or should be supplemented, or its processing does not meet the requirements of the PDPA;

4.3. To object to “AS CLUB” Ltd. at any time against the processing of your personal data when there is a legal basis for this;