DATA PRIVACY POLICY OF "CIELA NORMA" AD

INTRODUCTION

This privacy policy has been duly approved by "Ciela Norma" AD and is effective as of May 25, 2018. Please note that the privacy policy will be regularly updated to reflect changes in the way we process your personal data and any changes in applicable laws.

This privacy policy tells you everything you need to know about how "Ciela Norma" AD, UIC 130199580, with headquarters and management address: Sofia, p. k. 1510, 9 Vladimir Vazov Blvd. ("Ciela Norma", "we", "administrator"), in the role of administrator, protects the personal data it processes in relation to you as a personal data subject ("Your Personal Data") Additional information about Ciela Norma can be found here.

This privacy policy provides an overview of the most common activities of Ciela Norma in processing your personal data. Please note that some specific processing activities may be subject to a separate and individual privacy statement.

1. HOW DO WE PROCESS YOUR PERSONAL DATA?

Ciela Norma attaches great importance to your right to privacy and the protection of the privacy of your personal data. We want you to feel confident that when you communicate with Ciela Norma, your personal data is in good hands.

Ciela Norma protects your personal data in accordance with applicable laws and our information security and privacy policy. Ciela Norma implements appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction or damage.

1.1. What categories of personal data do we collect?

As a personal data administrator, in our activities we collect personal data of customers, suppliers, business partners, experts, website users, visitors to our offices and retail outlets, participants in events organized by us, etc. If the data we collect is not listed in this privacy policy, we will provide individuals (where required by law) with appropriate notice of what other data will be collected and how it will be used.

In particular, the personal data we collect includes the following categories of personal data:

- common personal data, such as name and surname, email address, telephone, delivery address, position/employer, bank card, date of birth, education/professional development (e.g. if you are an expert in participating in public procurement), etc.;

- audio visual material – such as photographs and images/frames captured on CCTV or other video systems, and voice recordings;

- data for accessing systems and applications - when you access Ciela Norma's systems, the administrator may collect the information necessary to access Ciela Norma's systems and applications, such as system ID, LAN ID, email account, instant messaging account, other ID, system passwords, activity logs, and electronic content produced through Ciela Norma's systems,

as well as any other categories of personal data referred to in this privacy policy or in other statements you have received.

The categories of personal data specified in this privacy policy are obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a website forum, or shop on our websites), or indirectly from certain third parties (e.g. through the website technology, from our partners – personal data administrators). These third parties may include public authorities, public websites and social media, as well as suppliers. For more up-to-date information about third parties, you can contact our Data Protection Officer.

You provide us with your personal data voluntarily and you will not be subject to any adverse consequences if you do not wish to provide us with your personal data. Please note, however, that if you do not provide certain information, we may not be able to achieve some or all of the purposes set out in this privacy policy, and you may not be able to use certain tools and systems that require the use of such personal data.

In addition to you, as the data subject, we may also receive your personal data from the following sources:

o your employers;

o subcontractors, suppliers and partners;

o public authorities;

o public websites, public registers and social media.

1.2. For what purposes and on what legal basis do we use your personal data?

Ciela Norma only uses your personal data when required for specific purposes as explained in this privacy policy. The purposes for which we use your personal data are related to:

- Providing our products and services, and managing Ciela Norma's business operations (including security);

- Facilitating communication with you;

- Financial and accounting activities;

- Compliance with legal requirements, such as mandatory filings, record keeping and reporting obligations, audits, statutory inspections and other requests from government or other public authorities, administrative and judicial proceedings, such as subpoenas, exercising legal rights and remedies, conducting investigations and complying with internal policies and procedures, protecting, enforcing or defending legal rights, privacy, the safety or property of Ciela Norma, its employees, agents and subcontractors (including enforcement of relevant agreements and terms of use), protect the safety, privacy and security of users of Ciela Norma products or services, or the public, or protect against fraud, or for risk management purposes;

- Ensuring business continuity, protecting the health and safety of employees and visitors, safeguarding IT infrastructure, office equipment and other property;

- IT and communication systems operations and management, IT security operations, facility access control, Ciela Norma asset management, business continuity and disaster recovery, compiling audit trails and other reporting tools, maintaining records related to business activities and organizing Ciela Norma events/seminars;

- Reuse and combination of public sector information, in accordance with the law;

- Applying analytics to business operations and data to describe, predict, and improve business performance in Ciela Norma and/or provide a better user experience. Specifically, the areas of analysis include descriptive analytics, predictive analytics, analytics involving individuals (customers, business contacts), use of personal data, marketing-driven analytics.

Ciela Norma processes personal data for the above purposes on the following legal grounds:

- your freely given consent;

- performance of a contract to which you are a party, including preliminary steps at your request (processing inquiries, making offers);

- compliance with a legal obligation of Ciela Norma;

- our legitimate interests.

When we state that we rely on our legitimate interests for a given purpose, we consider that our legitimate interests do not override your interests, rights or freedoms, as:

a) we provide full transparency regarding processing activities;

б) we apply a privacy-friendly approach;

в) we conduct regular privacy monitoring and

г) we respect the rights you have in relation to processing activities.

We will not use your personal data for purposes that are incompatible with the purposes for which you have been informed, unless this is required or permitted by law, or is in your vital interest (e.g. in the event of a medical emergency).

1.3. Who will we provide your personal data to? Will we share your personal data with third countries?

We may transfer personal data to the following persons, in accordance with the specified processing purposes:

Professional advisors

o accountants, auditors, lawyers, insurers, bankers and other external professional advisors in all countries where Ciela Norma operates.

Ciela Norma Suppliers

o persons who provide products and services to Ciela Norma, such as suppliers and support of information systems, trade organizations and associations, and other service providers.

Public authorities

o persons who regulate or have jurisdiction over Ciela Norma, such as regulatory authorities, law enforcement authorities, public authorities and judicial authorities.

Corporate/commercial transaction

o third parties - in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or a portion of Ciela Norma's business, assets or cash (including in connection with any bankruptcy or similar proceedings).

o third parties - in connection with any proposed or actual client project.

These third parties may be located in other countries. Before doing so, we will take the necessary steps to ensure that your personal data will receive adequate protection as required by relevant data protection laws and Ciela Norma's internal policies.

Currently, the personal data we collect is processed primarily in the Republic of Bulgaria and within the European Economic Area (EEA) and is not provided to third parties outside the EEA.

Unless you are notified otherwise, any transfer of personal data from the European Economic Area (EEA) to third countries outside the EEA will be based on an adequacy decision or governed by standard contractual clauses. Any transfer of your personal data outside the EEA will be in accordance with appropriate international data transfer mechanisms and standards.

Regardless of whether Ciela Norma acts as a controller who assigns personal data to a processor, or as a processor of personal data for another controller or joint controller, in any case the relevant terms shall be objectified in a written contract (agreement) pursuant to Article 26 or Article 28 of the GDPR.

1.4. How we treat “special personal data“?

The term "special personal data" refers to data revealing racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, trade union membership, biometric or genetic data, data concerning health or data concerning a natural person's sex life or orientation.

We do not generally collect sensitive data (special categories of data) through our sites or otherwise. In the limited cases where we may collect such data, we will do so in accordance with the requirements of the law and/or we will ask for your consent, for example when we collect health/medical information such as disability status and dietary requirements/allergies as part of events we organize or sponsor.

1.5. What data security measures do we apply?

We implement organizational, physical and technical security measures for all personal data we process. We will implement organizational, physical and technical security measures for all personnel data and process.

We implement leading security measures to protect your personal data, which includes (but is not limited to) the fact that Ciela Norma holds an ISO 27001 certificate, which confirms that we adhere to the highest and most stringent information security standards. This is a security standard recognized by the Bulgarian Institute for Standardization (BIS), which serves as international certification that Ciela Norma adheres to the highest and most stringent standards.

With regard to your use of our websites, please note that the free nature of the internet implies that information and personal data are distributed over networks that can be accessed and used by people other than those for whom the data is intended.

1.6. How long will your personal data be retained?

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected. We maintain specific policies and procedures for managing and storing records so that personal data is deleted after a reasonable period of time, in accordance with the following retention criteria:

o We retain your data for as long as we have an ongoing relationship with you;

o We will retain your data for as long as necessary to provide you with services;

o We retain your data for as long as necessary to comply with our legal and contractual obligations.

1.7. What rights do you have regarding the processing of your personal data?

You have the right (under the circumstances and under the conditions, and subject to the exceptions set out in applicable law) to:

o Request access to the personal data we process about you: This right enables you to know whether we process personal data about you and, if we do, to receive information about it and a copy of that personal data.

o Request correction of your personal data: this right gives you the opportunity to correct your personal data if it is inaccurate or incomplete.

o Object to the processing of your personal data: this right gives you the opportunity to request that Ciela Norma not process your personal data.

o Request deletion of your personal data: This right enables you to request the deletion of your personal data, including when such personal data is no longer necessary to achieve the purposes.

o You request restriction of the processing of your personal data: this right enables you to request that Ciela Norma process your personal data only in limited circumstances, including with your consent.

o Request the portability of your personal data: This right enables you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Ciela Norma, or to request that Ciela Norma transmit such personal data to another administrator.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting Ciela Norma's Data Protection Officer in writing (and electronically). Please note that this will not affect Ciela Norma's right to process personal data obtained before your consent was withdrawn, or its right to continue to process some of the data based on other legal grounds, regardless of your lack of consent.

There are also cases in which you may receive partial assistance from us within the framework of the law in exercising your rights (for example, in correcting personal data that we are obliged by law to maintain strictly in the form in which we received it from third parties, including those obtained from public registers, in accordance with the law) as current at the time we received it, and accordingly we will only be able to direct you to these third parties to exercise your rights against them.

If, despite our commitments and efforts to protect your personal data, you believe that your rights have been violated, Ciela Norma will consider any inquiry or complaint in this regard. You have the right at any time to register a complaint directly with the relevant supervisory authority - the Commission for Personal Data Protection, or to file a claim against Ciela Norma before the relevant competent court.

2. HOW DO WE USE PERSONAL DATA WHEN YOU VISIT THE CIELA NORMA WEBSITES?

In addition to the information listed above, the following sections describe how we use personal data when you visit Ciela Norma websites:

o What personal data do we collect?

o Do we include (links to) third-party websites and programs?

o How do we use the personal data we collect from our websites?

2.1. What personal data do we collect?

Ciela Norma collects personal data through its websites in two ways:

o directly (for example, when you provide personal data to create an account, sign up for a newsletter, or register to comment on a website forum) and

o indirectly (for example, through the technology of our website).

We may collect and process the following personal data:

o Personal data that you provide by filling in forms on our websites (regular personal data, such as name and surname, email address, telephone, delivery address, bank card). This includes registering to use the website, subscribing to services, newsletters and notifications, registering for a conference or additional information, or making online purchases. Sites that collect this type of personal data may provide additional information about the reasons why your personal data is needed and how it will be used. It is entirely up to you whether you want to provide them.

o If you contact us – by phone, fax, or email, we may keep a record of the conversation.

o We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

o Any posts, comments or other content that you upload or post to a Ciela Norma website.

o Our website collects personal data about your computer, including (where available) your IP address, operating system and browser type, for system administration, traffic filtering, user domain lookup and statistical reporting.

o Details of your visits to our websites, the pages you view, and the resources you access or download, including, but not limited to, traffic data, location data, web logs, and other communication data. Please see the Cookie Policy below for more information.

2.2. Do we include (links to) third-party websites and programs?

Our websites may include:

o links to and from the sites of our affiliate networks and advertisers;

o certain third-party programs (widgets and applications). In such cases, please note that these third parties may process your personal data collected through such programs for their own purposes.

We make no warranty or assume any responsibility for such third-party websites or programs. Please check the terms of use and privacy statements (policies) of third parties before using and providing information to those third party websites and programs.

2.3. How do we use the personal data we collect from our websites?

We use personal data for the purposes described in the section For what purposes and on what legal basis we use your personal data above, for example:

o to carry out your order;

o to fulfill your requests for articles, newsletters or other content;

o for surveys and questionnaires;

o to personalize your access to our website;

o to contact you for marketing purposes.

We analyze your IP and browser information to determine which one is most effective for our website to help us find ways to improve it and make it more effective. Please see the Cookie Policy below for more information.

3. POLICY ON COOKIES AND SIMILAR TECHNOLOGIES

This section provides information on how Ciela Norma uses cookies and similar technologies on its websites.

3.1. What are cookies?

Cookies are text files containing a small amount of information that are downloaded to your computer or mobile device when you visit a website and allow a website to recognize your device.

3.2. Why do we use cookies and similar technologies?

Cookies perform many different tasks, such as allowing you to navigate between pages efficiently, to remembering your preferences and improving your user experience. They can also help ensure that the advertisements you see online are more relevant to you and your interests.

3.3. Does Ciela Norma use “cookies” for marketing and analysis?
         We may use the data collected from our “cookies” to identify user behaviour and to show content and offers based on your profile - and for the other purposes described below - to the extent permitted by law.
       Some of the “cookies” we use do not collect information that can identify visitors. For example:
• Performance cookies;
• Targeting cookies - when you are not a registered user.

        In other cases, we may associate cookie information (including information from cookies placed via our ads on third-party websites) with an identifiable individual. For example:
• If we send you a targeted email that includes pixel markers (web beacons), cookies, or other similar technologies, we will know whether you open, read, or delete the message.
• When you click on a link in a marketing message you receive from Ciela Norma, we may use cookies to record which pages you view and what content you download from our websites, even if you are not registered or logged in to our website.

Combining and analyzing personal data
            As described above, we may combine data from publicly available sources and from various emails, websites, and personal interactions with you (this includes information collected from various websites such as career and corporate sites, and information gathered when you register or log in to our websites or contact our sites using your social media identification data from Facebook, LinkedIn, and Xing). We combine this data to better assess your experience with Ciela Norma and to carry out the other activities described in our privacy policy.

3.4. Do we use “cookies” from third parties?
            Some of the cookies we use are provided by third-party companies such as Adobe Analytics, Facebook, Google, and LinkedIn Analytics to supply us with web analytics and intelligence data for our websites. These companies use programming code to collect information about your interaction with our websites, such as the pages you visit, the links you click, and how long you remain on our sites. This code is active only while you are on a Ciela Norma website. For more information about how these companies collect and use information on our behalf, please see their privacy statements (Adobe, Facebook, LinkedIn, Google, etc.).

3.5. Does Ciela Norma use tracking technologies without “cookies”?
            We may also use pixel markers (so‐called web beacons, including conversion pixels) or other similar technologies for similar purposes, as mentioned above, and we may include them on our websites, in our marketing messages, or in our newsletters, on affiliated websites to determine whether messages have been opened or clicked on. Web beacons do not place information on your device, but they can work together with cookies to monitor website activity. The information provided below regarding “cookies” also applies to pixel markers and similar technologies. The so-called conversion pixels are small pieces of code placed on a specific webpage that are triggered when someone visits that page, thereby increasing their count.

3.6. What should I do if I do not wish to receive “cookies”?
           By using our website, you agree that we may place cookies on your device as explained below.
           If you wish to remove existing cookies from your device, you can do so by using your browser’s options. If you want to block future cookies from being placed on your device, you can change your browser settings accordingly. Please, note that deleting and blocking cookies may affect your ability to use the website effectively, as parts of it may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email we send you, even if you have deleted our cookies.

3.7. What types of “cookies” exist and which ones do our websites use?
           The cookies used on Ciela Norma’s websites are categorized based on the classifications found on the European Commission’s website (http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm) and other public sources.
      It is important to note, however, that not all cookies can be used on all websites. A list of cookies used by our websites, categorized by type, is provided below. Within these four categories, cookies are classified as session cookies or persistent cookies.

Session cookies are temporary and are deleted from your device once you close your browser window.

Persistent cookies remain on your device for a longer period and are used by the website to recognize your device when you return. More information about cookies can be found at: http://www.allaboutcookies.org/ and http://www.youronlinechoices.eu/.

           The cookies used by https://www.ciela.net/ fall into the following categories:

Strictly functional/necessary cookies:
          • PHPSESSID – the current user session cookie for the PHP scripting language on our server.
          • cookieconsent_dismissed – a cookie that indicates your consent or dissent with the Cookie Notice.
          • resolution – a cookie that stores the screen resolution of your monitor.
          • nlet.ciela.net, PHPSESSID – the current user session cookie for PHP related to our email newsletter system.

Optional/marketing/analytical cookies:
         • _fbp, Facebook Pixel – stores advertising and analytical information for the social network Facebook.
         • _ga, Google Analytics – stores analytical/statistical information for Google Analytics.
         • _gid, Google ID – stores your unique user number from Google (if available) for ciela.net.

Third-party cookies:
• Google.com, NID – similar to _gid, but for Google.
• YouTube.com, Cache Storage, Database storage, Local storage – session cookies used by YouTube to store video information.
• YouTube.com, VISITOR_INFO1_LIVE – stores information about the speed of your internet connection.
• YouTube.com, YSC – stores your YouTube player settings; this cookie is stored only while the current browser window is open.

4. HOW DO WE USE PERSONAL DATA WHEN YOU VISIT OUR OFFICES AND/OR PHYSICAL POINTS OF SALE?
            In the section Ciela Norma Data Privacy Policy for Visitors, we explain how we use your personal data when you visit our offices and/or physical points of sale (including bookstores and other locations) operated by Ciela Norma (this section also applies to the processing of your personal data through video surveillance and access control systems, in cases where such systems are active, available, and under the control of Ciela Norma).
            You may contact our Data Protection Officer (DPO) by phone at 02/903 00 26 or by email at dpo@ciela.com to obtain further details on how we process your personal data when you visit our offices and/or physical points of sale (including bookstores and others).

5. HOW DO WE USE PERSONAL DATA FOR MARKETING PURPOSES?
            In addition to the information provided above, this section describes how we use personal data for marketing purposes, including:
– What are the sources of our marketing data?
– Do we send targeted emails?
– Do we maintain customer relationship management databases?
– Do we combine and analyze personal data?
– Do we share personal data with third parties?
– What are your rights regarding marketing communications?

5.1. What are the sources of our marketing data?
           Most of the personal data we collect and use for marketing purposes is related to individual employees of our clients and other partners, with whom we have existing business relationships. We may also obtain contact information from public sources, including content published on social media, in order to make an initial contact with the respective individual in a client or other company.

            5.2. Do we send targeted emails?
            We send commercial messages to individuals in client or other companies, with whom we wish to develop or maintain business relationships in accordance with applicable marketing laws. Our targeted email messages typically include pixel markers, cookies, and similar technologies that allow us to know whether you open, read, or delete the message and which links you click on. When you click on a link in a marketing message you receive from Ciela Norma, we will use cookies to record which webpages you view and what content you download from our websites, even if you are not registered or logged in to our website.
            Targeted emails from Ciela Norma may include additional information about data privacy as required by applicable laws.

5.3. Do we maintain customer relationship management databases?
            Like most companies, Ciela Norma uses customer relationship management technology to manage and track our marketing efforts. Our customer relationship databases include personal data belonging to individuals from our clients and other companies with which we already have business relationships or wish to develop such relationships. The personal data used for these purposes includes relevant business information such as contact details, publicly available information (e.g., board memberships, published articles, press releases, social media posts, email addresses, including web activity following links from our emails), the activity of the website of registered users, and other business information.
If you wish to be excluded from our databases, you can use our Subject Access Request template or contact our Data Protection Officer by phone at 02/903 00 26 or by email at dpo@ciela.com.

5.4. Do we combine and analyze your personal data?
            We may combine data from publicly available sources and from various emails, websites, and personal interactions with you (this includes information collected on our various websites, such as our career and corporate sites, as well as information collected when you register or log in to our websites through your identification data on social media such as LinkedIn and Xing). We combine these data to better assess your experience with Ciela Norma and to carry out the other activities described in our privacy policy.

5.5. Do we share personal data with third parties?
            In addition to the third parties mentioned in the section “To Whom Will We Provide Your Personal Data? Will We Share Your Personal Data with Third Parties?”, we may share your personal data with marketing agencies in accordance with the law.

5.6. What are your rights regarding marketing communications?
            You may exercise your right to object to receiving future marketing communications by checking specific fields on the forms we use to collect your personal data or by using the opt-out mechanisms provided in the emails we send you. You may also exercise your right to cease marketing communications or remove your personal data from our customer relationship management databases at any time by contacting our Data Protection Officer by phone at 02/903 00 26 or by email at dpo@ciela.com. In such cases, we will retain minimal personal data to record that you have opted out, so that we do not contact you again in the future. Additionally, from time to time, we may provide you with the opportunity to inform us of your preferences through our websites.

6. CIELA NORMA DATA PRIVACY POLICY FOR VISITORS

            6.1. What categories of personal data does Ciela Norma process?
            Ciela Norma will collect personal data about you to achieve the purposes stated in this policy.
            Ciela Norma processes the following categories of personal data from visitors:
– ordinary personal data, such as first name and last name, email address, telephone number, job title/employer, bank card details, etc.;
– audiovisual materials – such as photographs and images/frames captured by video surveillance via CCTV or other video systems.

The purposes for which we use your personal data are related to:
– providing our products and services and managing Ciela Norma’s business operations (including security);
– facilitating communication with you;
– financial and accounting activities;
– ensuring business continuity, protecting the health and safety of employees and visitors, safeguarding IT infrastructure, office equipment, and other assets.

6.2. Why does Ciela Norma process your personal data?
            Ciela Norma may collect, use, transfer, disclose, and otherwise process your personal data in the context of facilitating communication with you (including in emergency situations), operating and managing Ciela Norma’s business operations and systems, and complying with legal requirements.
            Ciela Norma will not use your personal data for purposes that are incompatible with the purposes stated in this privacy policy, except where necessary or permitted by law, or when it is in your personal interest (for example, in cases of emergency medical assistance).

6.3. On what legal basis does Ciela Norma process your personal data?
            Ciela Norma processes your personal data as permitted by applicable data protection laws and internal policies.
            Ciela Norma processes your personal data for the purposes outlined in this privacy policy for one or more of the following reasons:
           a) Ciela Norma is required to do so to comply with a legal obligation;
           b) such information is necessary for the performance of a contract to which you are a party;
           c) processing is necessary for the purposes of the legitimate interests pursued by Ciela Norma or a third party; or
           d) where necessary, to protect the vital interests of any individual.

Ciela Norma has a legitimate interest in collecting and processing personal data, for example: (1) to ensure the security of Ciela Norma’s networks and information; (2) to administer and generally conduct business; and (3) to prevent fraud.
             Furthermore, Ciela Norma may make automated decisions regarding you when this is permitted by applicable law and/or with your prior consent and for the purposes stated in this privacy policy. When any of the aforementioned purposes involves automated decision-making, Ciela Norma will implement such decision only with your prior consent and after providing you with understandable information about the logic involved, as well as the significance and intended consequences of such automated decision for you.

6.4. Who has access to your personal data?
            Access to your personal data at Ciela Norma is restricted to those employees who need to know the information for the purposes described in this privacy policy. This may include personnel in the areas of Security, Human Resources, IT, Compliance, Legal, Finance and            Accounting, Corporate Investigations, and Internal Audit.
            Additionally, when necessary, Ciela Norma may share your personal data with third parties such as service providers and public authorities. Before doing so, Ciela Norma takes steps to protect your personal data. All third-party service providers and professional consultants to whom your personal data is disclosed are required to safeguard the confidentiality and security of your personal data and may use it only in accordance with applicable data protection laws.

6.5. How does Ciela Norma protect your personal data?
            Ciela Norma implements organizational, physical, and technical security measures for all personal data it processes. Ciela Norma has rules, policies, procedures, and guidelines that have been developed with consideration of the risks associated with the categories of personal data.
            Ciela Norma applies leading security measures to protect your personal data and maintains an ISO 27001 certification, which confirms that we adhere to the highest and strictest information security standards.

6.6. How long does Ciela Norma retain your personal data?
            Ciela Norma retains your personal data only for as long as is necessary to achieve the purposes for which it is processed. Ciela Norma maintains specific policies and procedures for the management and storage of archives so that personal data is deleted after a reasonable period according to the following retention criteria:
• Ciela Norma retains your personal data as long as there is an existing relationship with you;
• Ciela Norma retains your personal data for as long as necessary to comply with applicable legal requirements;
• Ciela Norma retains your personal data when it is appropriate to ensure legal protection for Ciela Norma (for example, in connection with statutes of limitations, legal disputes, or investigations).

CONTACT US:
You can contact our Data Protection Officer by phone at 02/903 00 26 or by email at dpo@ciela.com if:
• You have a question about how Ciela Norma processes your personal data;
• You wish to exercise your rights regarding the processing of your personal data, as described in the section “What rights do you have regarding the processing of your personal data?” (you may use our Subject Access Request template);
• You wish to file a complaint regarding the manner in which your data is processed by Ciela Norma.

This Ciela Norma Data Privacy Policy is last updated on December 14, 2022.