Privacy Notice

GOTMAR Ltd., 115076001 (“GOTMAR”, “We”, “The Company”) provides information about your personal data that can be processed upon start of employment, upon entering into a civil contract and on performance of a labour or a civil contract with GOTMAR.

This notice complements the GOTMAR Human Resource Management Privacy Policy, which defines procedures and activities for the processing of personal data in the selection of candidates for employment, signing and administering employment and civil contracts.

This notice is intended to help you understand why and how we can use your information. The lists and examples below are illustrative, non-exhaustive and not fully representative of any employee within the Company.


What kind of personal data do we process?

“Personal Data” means any information about you from which you could be identified, including information that may be protected under applicable national and European laws.

“Sensitive personal data” means data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or membership of trade unions, and the processing of genetic data, biometric data for the sole purpose of identifying an individual, health data or data about the sexual life or the sexual orientation of the individual. In relation to them, GOTMAR applies special protection measures and treats them on the basis of its legal obligation as an employer.

The personal data of employees and entities under contracts that GOTMAR usually processes are the following:

Categories of personal data



Grounds for processing

Information about you


Name, Surname, family name, Date of Birth, Photo, Driving License, Personal Identification Number


Performance of a labour / civil contract




Email, address, and phone


Performance of a labour / civil contract




Educational and / or qualification degree


Legitimate interest


Acquired professional experience, length of service and skills


Performance of a labour / civil contract


  Information related to performance evaluation


Attestation, performance evaluations from previous employers, certificates for completed training


Legitimate interest
Data needed to access our buildings and systems


Access card logs, video and photos


Legitimate interest
Health data and other special categories of personal data


Information from sick leave cards, TEMC and NEMC decisions, information provided by the Occupational Health Service, results of alcohol tests


Implementation of legal obligations in the field of labour law and social security and protection law.
Location data


GPS dataLegitimate interest
Information about court records


Criminal records for the financially liable persons appointed by order


Performance of a labour / civil contract


For what purposes will we use your data?

The personal data you provide will be used for the purposes of administering the employment (civil) contracts, including but not limited to:

  • Conclusion, amendment and termination of employment or civil contracts;
  • Payment of salaries, bonuses and incentives as well as remuneration under a civil contract;
  • Accountability and control of the work under civil contracts;
  • Provide additional benefits to employees, which depending on GOTMAR policy, could be health insurance, sports and transport cards, food vouchers, etc .;
  • Use of video surveillance records to ensure security in the buildings where you perform your work duties;
  • Use of access card records for both security purposes and control of compliance with labour discipline;
  • Providing healthy and safe working conditions;
  • Managing and developing human resources, improving working conditions, continuing education, annual performance evaluations, certification of employees and service providers;
  • Training on products and services provided by GOTMAR;
  • Treatment of health data for the purpose of administering holidays, accidents at work, providing special working conditions for people with disabilities and others according to the current labour and social insurance legislation;
  • Administration and planning of budgets of GOTMAR;
  • Processing of information to comply with legislative requirements, including avoidance of conflict of interest and corrupt practices;
  • Establishment and exercise of legal claims in connection with employment or civil contracts.

With whom can we share your personal data?

GOTMAR respects and protects the confidentiality of your personal data. Subject to legal requirements, GOTMAR may disclose your personal data to the following persons:

  • Service Providers: When using service providers related to human resources management, technical support for internal information systems, and operational support for our operations, GOTMAR may disclose personal data. Such disclosure only occurs when there is good reason to do so and, on the basis of a written agreement that the recipients provide an adequate level of protection.
  • Additional Benefits of Employees: In order to provide social benefits to its employees, GOTMAR may disclose your personal data to companies providing such services, including pension insurance companies, companies providing sports and transport card, food vouchers, etc.
  • Government and Municipal bodies: In fulfilling its legal obligations, GOTMAR may be obliged to disclose personal data to employees or persons under civil contracts at the explicit direction of the state or municipal authorities. When disclosing personal data to government bodies, we will seek to assist these authorities in their inquiries, but we will also strive to respect the rights and privacy of our employees as far as possible.
  • Other companies in the GOTMAR Group: For administrative purposes (e.g. financial management, IT infrastructure management, security management, Law on Safety and health at Work) as well as human resources management, including organizing in-house and external training or setting up a system of incentives for employees, GOTMAR may share your personal data with other companies in the GOTMAR Group on the territory of Bulgaria. Such disclosure of personal data is subject to the applicable Bulgarian and European legislation.
  • Partners for the purpose of organizing business trips: Your personal data may be disclosed to hotels and travel agencies.

 For what period do we store your personal data?

GOTMAR stores your personal data in accordance with the Data Storage Policy and the applicable law. Your personal data will only be stored by the Company for the period necessary to meet the purposes for which the personal data are originally collected unless there is a legal obligation or other legal basis for storage for a longer period of time.

GOTMAR keeps the individual documents it administers for labour / civil contracts purposes as follows:

  • Lick leave cards – 5 years from 1 January of the year following the year in which they were issued.
  • Payroll records – 50 years.
  • Documents related to a civil contract – 5 years after termination of the civil contract, unless a longer period is provided according to the applicable legislation.


For more detailed information on the terms of storage of all documents that GOTMAR processes for the purposes of employment or civil contracts, you can contact GOTMAR and ask for a copy of the Storage and Destruction of Documents Policy.

Security and privacy of personal data

GOTMAR maintains appropriate administrative, technical and organizational measures designed to help protect the security and privacy of employees’ personal data and protect them against accidental or unlawful destruction, accidental loss, unauthorized correction, disclosure or access, abuse and any other illegal form of processing.

Access to workers’ and employees’ personal data is give only to employees who are in charge of the work processes and employees of the Payroll Department and the Head of Information and Communication Technologies Department.

Access control and video surveillance are used throughout the entire enterprise;

The premises where personal data are processed and stored are restricted to the employees handling this data only;


In order to fulfill its obligations to protect the personal data of its employees, GOTMAR has provided secure servers located on the territory of the company, to which only a specialist and the Head of Information and Communication Technologies Department have access.

GOTMAR holds training of its employees on policies and procedures for the protection of personal data.

Cross-border transfers of personal data

At present, GOTMAR does not transfer your personal data to non-EU and EEA countries. GOTMAR undertakes to inform you in due time in the event of significant changes to the list of international partners who may have access to your personal data.

Your rights with respect to your personal data

Subject to Bulgarian law, you have the following rights with respect to your personal data processed by GOTMAR:

  1. access your personal data that GOTMAR processes and get a copy thereof;
  2. in case of incompleteness or inaccuracy in the data that GOTMAR processes, your personal data will be corrected;
  3. request that your data be deleted when there are reasons for this. Such cases are when the purpose for which the data is collected is achieved; you have withdrawn your consent when the processing is based on consent and there is no other legal basis for processing; your data is being processed unlawfully, etc.;
  4. In the cases specified by the law, require the processing of your personal data to be restricted;
  5. In the cases specified by the law, object to the processing of your personal data;
  6. Exercise your data portability rights and request that your data be provided in a structured, widely used and machine-readable format;
  7. withdraw your consent when processing your personal data is based on consent.

Detailed information on the terms and conditions under which you can exercise your rights can be found in the GOTMAR Privacy Policy on our website  and in our office

You also have the right to file a complaint with the Personal Data Protection Commission when there are good reasons for this.

 How to contact us?

If you have any questions or complaints about this privacy notice or the ways and purposes for which we use your personal data, you may contact our Data Protection Officer at: BULGARIA, Plovdiv, Saedinenie, gr. Saedinenie 4190, ШИПКА No 3, or on e-mail:

Updating the privacy notice

This notification may be updated periodically to reflect changes in GOTMAR Employees’ Privacy Practices. The Company undertakes to notify you of all material changes to this notice.