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Privacy Notice

Sopharma AD, UIC 831902088 („Sopharma“, „We“, „the Company“) provides hereby information about your personal data that could be processed in relation to share acquisition, participation in General Assemblies of Sopharma’s shareholders and exercising your rights as shareholders in the Company.

This Notice is intended to help you understand why and how we may use your information. The lists and examples below are illustrative, incomplete and not fully representative of each shareholder or his/her proxy in the Company.

What personal information of yours we process?

„Personal data“ means any information about you, sufficient to identify you, including information subject to protection according to the applicable national and European legislation.

Personal data of shareholders and their proxies, which Sopharma usually processes, are as follows:

Personal data categories

Types

Reason for processing

Information about you

Name, father’s name, family name, date of birth, personal ID No

Implementation of a legal requirement

Contacts

Address

Implementation of a legal requirement

Information about shares

Type, nominal and issue value, amount and number of the possessed shares

Implementation of a legal requirement

Bank information

Information about the bank account

Implementation of a legal requirement

Data from the power-of-attorney

Name, father’s name, family name, date of birth, personal ID No, ID card number, date of issue, expiry date, authority issuing the ID document

Implementation of a legal requirement

 

For what purposes shall we use your personal data?

Personal data submitted by you shall be use for the purpose of administration of a Book of Shareholders, including but not limited to:

-           convening, organization and participation in Shareholders’ General Assemblies of the Company;

-           participation in procedures on capital increase/decrease, adoption of other corporate decisions within the competence of the Shareholders’ General Assembly;

-           dividend distribution and payment;

-           admission of proxies to participation in Shareholders’ General Assemblies;

-           preparation of financial statements and consolidated financial statements about the Company;

-           processing of information aimed at compliance with legal regulations, including those related to: monitoring of shareholders’ structure of company capital, avoidance of conflict of interests and corruption practices, abuse of insider information.

Whom can we share your personal data with?

Sopharma respects and protects the privacy of your personal data. In complying with legal requirements, it is possible that Sopharma discloses your personal data to the following persons:

-           Service providers: When we use providers of consultancy services, auditor’s and accounting services etc., it is possible for Sopharma to disclose some personal data. Such disclosure of data shall be made only in the presence of a good reason and on the basis of a written agreement with the recipients to provide an adequate level of protection.

-           Commercial banks: For the payment of dividend to the shareholders, Sopharma signs agreements with banking institutions to which it discloses information required for dividend payment. Such disclosure of personal data shall take place on the basis of signed written agreement with the recipient for provision of an adequate level of protection of the provided personal data.

-           Governmental authorities, Central depository: In performance of its legal obligations, Sopharma could be obliged to disclose personal data to governmental authorities or Central Depository. In disclosing personal data to governmental authorities we shall strive at cooperation with these authorities in their inquiries but we shall also strive at respecting the rights and privacy of our shareholders and their proxies as much  as possible.

How long shall we keep your personal data?

 Sopharma shall keep your personal data in compliance with the Document Retention, Archiving and Destruction Policy of Sopharma AD and the applicable legislation. Your personal data shall be kept by the Company only for the period required for accomplishment of the purposes, for which personal data have been collected initially, unless the law requires by the Company to keep them for a longer period.

For example, documents on the payment of dividend, related to performance of fiscal supervision shall be kept for 5 years after expiry of the limitation period for repayment of the relevant public debt.

Security and privacy of personal information

Sopharma shall maintain adequate administrative, technical and organizational measures intended to assist in protecting shareholders and their proxies’ personal data security and privacy and to prevent any accidental or illegal destruction, accidental loss, unauthorized correction, disclosure, access, abuse and any other illegal form of processing.

In performance of its obligations for personal data protection of its shareholders and their proxies, Sopharma duly takes into account the achievements of the technical progress.

Sopharma carries out trainings of its employees with respect to policies and procedures of personal data protection.

Your rights regarding your personal data

In consideration of Bulgarian legislation, you have the following rights regarding your personal data processed by Sopharma AD:

  1. to have access to your personal data processed by Sopharma and to receive a copy of them;
  2. to correction of your personal data processed by Sopharma in case of incompleteness or inaccuracy in such data;
  3. to ask for deletion of your personal data whenever such conditions occur. Those are the cases of achieved purpose for which the data have been collected; when the processing is based on consent and there is no other legal grounds for processing; your data have been processed illegally etc.;
  4. to request restricted processing of your personal data in the cases specified by law;
  5. to submit an objection against the processing of your personal data in the cases specified by law;
  6. to exercise your right to data transfer and to request your data to be submitted to you in a structured, generally used and machine-readable format;
  7. to withdraw your consent when the processing of your personal data is based on consent.

Detailed information on the terms and procedure for exercising your rights, you can find in Sopharma's Policy for exercising data subject rights on our website http://www.sopharma.us/rules-for-exercise-of-rights-of-data-subjects.html.

You are also entitled to file a complaint with the Commission of Personal Data Protection whenever relevant prerequisites exist.

How to contact us?

If you have any questions or complaints on this Privacy Notice or about the methods and purposes for which we use your personal data, you can contact us at the following address: Sofia 1220, Nadezhda District, 16 Iliensko Shosse Str, e-mail: personaldata@sopharma.bg.

Our Data Protection Officer is Ernst & Young Lawyers Office e-mail: personaldata@sopharma.bg.

Update of privacy notice

This notice may be updated from time to time to reflect the changes in the practices for protection of personal data of Sopharma’s shareholders and their proxies. The Company shall inform you of any significant changes in this notice.