Privacy Policy

Yes HONEST LOGISTICS LTD

I. General Provisions

„Data subject“ means an identified or identifiable natural person (data subject); a natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

„Personal data“ means any information relating to an identified or identifiable natural person („data subject“) in accordance with Regulation (EU) 2016/679 on data protection.

„Administrator“ means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, in accordance with Regulation (EU) 2016/679 on data protection.

„Processing“ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in accordance with Regulation (EU) 2016/679 on the protection of personal data.

In connection with the provision of freight forwarding and transport services, HONEST LOGISTICS EOOD processes the personal data of its clients and subcontractors – natural persons, as well as the personal data of other natural persons, hereinafter referred to as („Data Subjects“), in accordance with the rules and principles set out in this HONEST LOGISTICS EOOD Personal Data Protection Policy („Policy“).

The data subject may address all their requests and queries relating to the exercise of their rights regarding the protection of their personal data as follows:

Email address: info@honestlogistics.bg

Correspondence address:

HONEST LOGISTICS EOOD – 61 Yapadzha St, 1849 Sofia, Bulgaria

II. Data Subjects

Art. 1. Data subjects: HONEST LOGISTICS Ltd. has the right to collect and process information concerning the following categories of data subjects:

  1. Current and potential clients – individuals;
  2. Customer representatives;
  3. Representatives of state and regulatory bodies;
  4. Auditors and consultants;
  5. Attorneys;
  6. Service providers and their representatives;
  7. Subcontractors, drivers and their representatives;
  8. Customs agents;
  9. Insurance brokers;
  10. Loss adjusters;
  11. Solicitors;
  12. Other persons, other than those listed above, who come into contact with HONEST LOGISTICS EOOD or make, directly or indirectly, claims against HONEST LOGISTICS EOOD.

III. Categories of personal data

Art. 2. The categories of personal data that HONEST LOGISTICS LTD processes regarding the Data Subjects in accordance with this Policy may include:

  1. Credentials Identity document names; EGN/LNC/Service number/BULSTAT number (for individuals); address (permanent, current, for correspondence); place of birth; age; identity document details; nationality; driving licence; passport details; IP addresses, etc.;
  2. Contact details: telephone numbers; faxes; email addresses; physical correspondence addresses; other contact/correspondence details provided by the Data Subject, etc.;
  3. Social identity Employment details, certificates, education (degree); position; start and end years, references, work experience, etc.;
  4. Additional information for client representatives, subcontractors and individuals: Information regarding the representative, including information about the represented Data Subject; names, ID card details, address, invoice numbers, debt amount, applications, declarations, position/job title; place of employment; capacity (type of legal representative, authorised person, employee, partner in an unincorporated partnership); changes and history of changes in legal representation; powers of attorney; information on representational authority; information regarding withdrawal or expiry of authorisation, information about the owners of (if the same is a legal entity or unincorporated partnership) – e.g., information about partners/shareholders, number and type of held shares/stakes, etc.;
  5. Contractual and financial information: Contract, number and date of contract conclusion; information on and dates of contract amendment and termination; invoice numbers and content; information on debt amounts; information on instalment payments; executed payments; debt repayment; bank account number (IBAN), customer bank account information; insurance information; information on sums in favour of HONEST LOGISTICS Ltd.;
  6. Information on submitted complaints, damages incurred, applications, requests, petitions, and reports (incl. in free text) and for other correspondence with HONEST LOGISTICS LTD, including information regarding their processing and status, as well as the final result of their processing;
  7. Other information and documents: any other information and documents (declarations; opinions; lists; inventories; schedules; certificates and attestations; applications; minutes; official notes for stolen property issued by competent authorities; orders, certificates, declarations and other acts of competent authorities; contracts (including preliminary contracts, lease agreements, etc.) which the Data Subjects, competent state authorities or third parties provide to HONEST LOGISTICS EOOD or which are respectively generated in the preliminary process and/or within the scope of the conclusion, amendment, performance and termination of contracts with the Data Subject.

IV. PURPOSES FOR PROCESSING PERSONAL DATA

Art. 3. HONEST LOGISTICS EOOD lawfully processes personal data in relation to the following purposes:

  1. Objectives related to compliance with legal obligations of HONEST LOGISTICS LTD;
  2. Objectives related to and/or necessary for the performance of contracts concluded with HONEST LOGISTICS EOOD or for taking steps at the request of the Data Subject before concluding a contract;
  3. Objectives relating to the legitimate interests of HONEST LOGISTICS LTD or third parties;
  4. Purposes for which the Data Subject has consented to the processing of their data.
  5. The purposes for the processing of personal data by HONEST LOGISTICS LTD, related to compliance with legal obligations, include:
    1. Debt collection, owed to HONEST LOGISTICS LTD, including by assignment to third parties;
    2. Activities related to the performance of transport and logistics services;
    3. Legal activities related to the preparation of responses and appeals to a state authority, responses to inquiries from a judicial authority, preparation of legal opinions and documents.;
    4. Other activities for the fulfilment of legal obligations (tax, accounting, regulatory, etc.) of HONEST LOGISTICS EOOD, related to the submission/reporting of information to competent state and judicial authorities and to providing assistance during inspections by competent authorities.

Art. 4. The purposes for processing personal data related to the performance of contracts or for taking steps at the request of the Data Subject before concluding an agreement with HONEST LOGISTICS LTD, include:

  1. Tendering and negotiation, conclusion, amendment and performance of a transport service contract;
  2. Communication regarding the conclusion, amendment, and performance of contracts.
  3. Complaints and claims checks regarding the transport and logistics services provided;
  4. Processing, collection, and rescheduling of amounts due in connection with the provided transport and logistics services.
  5. The purposes of personal data processing necessary for the legitimate interests of HONEST LOGISTICS LTD or third parties include:
  6. Establishing, exercising or defending legal claims of the companies of the HONEST LOGISTICS EOOD group, including through legal proceedings, including the submission of complaints, reports, etc. to the competent state and judicial authorities;
  7. Recovery of debts owed to HONEST LOGISTICS Ltd, including by enforcement;
  8. Delegating debt collection activities to third parties (e.g. collection agencies);
  9. Property security and safety.

Art. 5. The purposes for the processing of personal data for which the Data Subject has given consent include:

  1. Carrying out marketing activities to offer the services of HONEST LOGISTICS LLC.

V. PROVISION OF PERSONAL DATA AND CONSEQUENCES OF REFUSAL TO PROVIDE IT TO HONEST LOGISTICS LTD

Art. 6. HONEST LOGISTICS LTD informs the Data Subjects about the Personal Data Protection Policy and the resulting rights, obligations, and limitations, in accordance with the General Data Protection Regulation and applicable national legislation. It is expressly stated: which data and/or documents are mandatory or a contractual requirement; which requirement is necessary for the conclusion of a contract; which is entirely voluntary, as well as the consequences of refusing to provide them.

Art. 7. Refusal to provide data and documents designated as mandatory may constitute an insurmountable obstacle to the conclusion of a contract with HONEST LOGISTICS EOOD, to the satisfaction and fulfilment of submitted requests, applications, petitions, complaints, damage claims, etc., which exempts HONEST LOGISTICS EOOD from liability for non-performance.

Article 8. Data subjects shall not provide HONEST LOGISTICS LLC with any special categories of data within the meaning of Articles 9 and 10 of the Regulation (namely: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation; and personal data relating to criminal convictions and offences or related security measures).

VI. OTHER SOURCES OF PERSONAL DATA

Art. 9. In some cases, personal data processed by HONEST LOGISTICS Ltd. are not collected or received directly from the Data Subject to whom they relate, but from third parties such as:

  • Clients or client representatives, other than the Data Subject;
  • Official public registers (e.g. commercial register, property register, public registers, etc.).;
  • Specialised online platforms;
  • Witnesses;
  • Service providers;
  • Transport exchange;
  • State and municipal authorities; and
  • Subcontractors and contractors of HONEST LOGISTICS EOOD.

VII. PROCESSING OF DATA SUBJECT INFORMATION BY THIRD PARTIES – PROCESSORS OF PERSONAL DATA

Art. 10. (1) For the purposes stated in this Policy and the General Terms and Conditions applicable to carriage/freight forwarding agreements, HONEST LOGISTICS Ltd. may delegate the processing of personal data of Data Subjects to third parties – personal data processors, in accordance with and within the scope of the requirements of the Regulation and other applicable personal data protection rules.

(2) When personal data concerning Data Subjects is disclosed to and processed by data processors, this shall only be to the extent and scope necessary for the performance of the tasks assigned to them by HONEST LOGISTICS LTD.

(3) Data processors act on behalf of HONEST LOGISTICS EOOD and are obliged to process personal data strictly in accordance with the instructions of HONEST LOGISTICS EOOD, and shall not be entitled to use or otherwise process information concerning Data Subjects for any purposes other than those specified in this Policy.

VIII. Categories of recipients of personal data

Art. 11. HONEST LOGISTICS Ltd. undertakes not to disclose personal data concerning the Data Subject, regarding the services requested or used by the Data Subject, nor to provide the collected information to third parties, except in cases where:

  1. This is necessary for HONEST LOGISTICS EOOD to fulfil a legal obligation:
    1. competent state and municipal authorities;
  2. This is expressly provided for in the Policy and in the General Terms and Conditions applicable to carriage/freight contracts.
  3. this is necessary for the conclusion, amendment, performance or termination of contracts:
    1. banks and payment service providers (e.g. for the purposes of payments made between HONEST LOGISTICS LTD and customers);
    2. Postal operators and couriers;
    3. Ferry operators and agents;
    4. Notaries;
    5. Freight exchange;
    6. insurers;
    7. consultants and auditors;
    8. External subcontractors in the performance of /Contract;
    9. debt collection agencies;
    10. Partners and counterparties of HONEST LOGISTICS LTD.

Article 12. The data subject has given their explicit consent:

  1. Commercial partners of HONEST LOGISTICS EOOD;
  2. third parties expressly provided for in the relevant agreement.

Article 13. For the protection of the rights or legitimate interests of HONEST LOGISTICS EOOD, of third parties or of the Data Subject in other cases provided for by law.

IX.Personal Data Retention Period

Article 14. HONEST LOGISTICS EOOD may process and store information concerning the Data Subject until the achievement of the respective purposes in compliance with the „storage limitation“ principle.

X. Rights relating to personal data

Art. 15. (1) In connection with the processing of personal data relating to him, each Data Subject has the following rights granted to him by the Regulation:

  1. The right to information;
  2. Right of access
  3. The right to correct
  4. The right to erasure
  5. Right to restriction of processing
  6. Third-party notification
  7. The right to data portability
  8. Rights in relation to automated individual decision-making, including profiling;
  9. Right to withdraw consent for processing;
  10. Right to object to the processing of personal data.

(2) The data subject may exercise their rights relating to personal data protection by sending a corresponding written request to the Data Protection Officer – submitted in person by the Data Subject or via a notarised request sent by post.

(3) The data subject may exercise the rights relating to their personal data, either personally or through a person expressly authorised by them (with a notarised power of attorney).

XI. RIGHT OF COMPLAINT TO A SUPERVISORY BODY

Article 16. Every data subject shall have the right to lodge a complaint with a supervisory authority for the protection of personal data, specifically in the Member State (of the EU/EEA) of their habitual residence, place of work, or place of the alleged infringement, if they consider that the processing of their personal data infringes the provisions of the Regulation or other applicable data protection requirements.

Art. 17. This Privacy Policy has been drawn up by HONEST LOGISTICS Ltd. with a view to fulfilling the obligations to provide information to Data Subjects under Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

This Privacy Policy has been approved by the relevant governing body – HONEST LOGISTICS LTD and is effective from 2026.