Privacy Policy

ACTA PHARMA AD, for the website www.actaph.eu (information provided pursuant to Article 13 of the GDPR) This document provides information regarding the different categories of data we collect from persons who visit this website; the processing, including the collection, recording, storage and use of personal data; the legal bases and purposes applicable to the categories of personal data processed; and the protection of personal data.

Administrator Details

Administrator ACTA PHARMA AD
Address Sofia, Ovcha Kupel 2 Residential Complex, Block 5, Entrance A, Floor 2, Apartment 6
GDPR Contact Point [email protected]​
ACTA PHARMA AD is a licensed wholesale trader of medicinal products, medical devices, food supplements and cosmetics.

Personal Data

Pursuant to 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), personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, psychological, mental, economic, cultural or social identity of that natural person. ACTA PHARMA AD strictly adheres to the principle of processing the minimum amount of personal data possible. This notice aims to explain what personal data we process and what your rights are in this regard.

Categories of Data We Process

The use of the website www.actaph.eu in browsing mode for the general functionalities of the website does not require you to enter any personal data. If you wish to use the full functionalities related to the services provided by ACTA PHARMA AD, the processing of your personal data may be necessary. We may process personal data for the purpose of establishing pre-contractual and contractual relationships, providing information requested by you, for example regarding our business, including our products and services, when you request information through an enquiry form, when applying for a job advertised on the website, and where a legitimate interest exists for you or for us. The legal bases on which we process your personal data are the performance of contractual relationships, consent, compliance with a legal obligation, or the purposes of our legitimate interests. The personal data we may request include:
  • Name;
  • Organisation (which you represent, work for, or on behalf of which you contact us);
  • E-mail address;
  • Address;
  • Telephone number;
  • Preferred language;
  • Your interests, education, professional experience, qualifications, and any other information voluntarily provided by you in documents submitted to us.

Methods of Data Collection

We collect personal data in several ways, including through registration, when you provide data in connection with entering into a contract, when you contact us directly using the contact details provided, through the contact forms on our website – enquiry forms, applications and surveys related to your enquiries – and when you browse our website through the use of cookies. Our website is not intended for persons under the age of 14, and we do not knowingly collect personal data from such persons. If a person under the age of 14 needs to use any of the forms on our website that require the provision of personal data, the website functionalities should be used by a parent or legal guardian on behalf of the child.

Legal Bases for Processing

The legal bases on which we process your personal data are:

Performance of Contractual Relationships

In order to enter into a contract and perform our obligations under it, we need to process certain information, including information provided by you. Some of this information may constitute personal data. We may use the data provided by you for the following purposes:
  • to verify your identity for security purposes;
  • to sell or deliver products offered by us;
  • to provide you with other ancillary services;
  • to send you offers or advice regarding our products and services, including information on how to make maximum use of the available functionalities when using our website.
We will continue to process this information until the relevant pre-contractual and/or contractual relationships have ended (i.e. while your registration remains active). Some personal data may continue to be processed in order to comply with legal and regulatory requirements (e.g. for tax purposes).

Consent

By taking certain actions, for example when browsing the website www.actaph.eu or requesting further information about our business, including our products and services, through direct marketing, you consent to our processing of information that may constitute personal data. For example, when we seek your feedback and collect your opinions, we will request your prior explicit consent. Whenever possible, we seek to obtain your explicit consent to process such information, for example by asking you to accept the use of “cookies” when using the website www.actaph.eu. In some cases, you may provide your consent indirectly, for example when you send us an e-mail to which you reasonably expect us to respond. Except where you have consented to the use of your information for a specific purpose, we do not use your information in a manner that personally identifies you.

Compliance with a Legal Obligation

We may sometimes be required to process your information in order to comply with a legal obligation. We may also be required to provide information to judicial authorities if they request it or if they have a relevant document, such as an authorisation, search warrant or court order.

Legitimate Interests

We may process information on the basis of a legitimate interest pursued by you or by us. For example, we may process your data for the purposes of:
  • maintaining records necessary for the proper and necessary administration of our business;
  • optimising our business processes;
  • responding to unsolicited communications from you where we reasonably believe that you expect a response;
  • protecting our information systems;
  • protecting and enforcing the legal rights of either party;
  • protecting your interests where we consider that we have grounds and an obligation to do so.

Purposes of Processing Personal Data

We may use the data provided by you for the following purposes:
  • to verify your identity for security purposes;
  • to sell or deliver products offered by us;
  • to perform contractual relationships;
  • to provide you with other ancillary services;
  • to provide you with information requested by you;
  • to send you offers or advice regarding our products and services, including information on how to make maximum use of the available functionalities when using our website;
  • to select employees who have applied for positions advertised through the website.
We may also process your data for the purposes of:
  • conducting data analysis for our business purposes, optimising the website, improving communication, and improving our products and services;
  • maintaining records necessary for the proper and necessary administration of our business;
  • optimising our business processes;
  • responding to unsolicited communications from you where we reasonably believe that you expect a response;
  • protecting our information systems;
  • protecting and enforcing the legal rights of either party;
  • protecting your interests where we consider that we have grounds and an obligation to do so.
Your data may be processed in connection with the acquisition, merger, division or liquidation of the company or part of its business by third parties, in which case we rely on our legitimate interest.

Retention Period for Personal Data

Unless otherwise stated in this Privacy Policy, we retain your personal data only for as long as required in order:
  • to provide you with the goods, services or information you have requested;
  • to comply with other laws and legal requirements, including for the period required by tax, medicinal-product or other public authorities;
  • until the relevant pre-contractual and/or contractual relationships have ended; while your registration on the website remains active, noting that some personal data may continue to be processed in order to comply with legal and regulatory requirements (e.g. for tax purposes);
  • in connection with a potential claim or legal proceedings.

Recipients or Categories of Recipients of Your Personal Data

These may include:
  • Employees of ACTA PHARMA AD;
  • Processors acting on behalf of ACTA PHARMA AD;
  • Affiliated entities of ACTA PHARMA AD;
  • Entities maintaining our information systems.
(The categories specified above also include persons who process data on the website where ACTA PHARMA AD customers register.)

Transfers of Data to a Third Country or International Organisation

ACTA PHARMA AD does not transfer your data to a third country or an international organisation. Notwithstanding the above, if our partners and/or companies within the corporate group of the data controller located in a third country, including outside the EU/EEA, obtain access to your personal data, each transfer will be safeguarded by appropriate safeguards provided for under the GDPR, such as Standard Contractual Clauses adopted by the European Commission.

Your Rights in Relation to Your Personal Data

In relation to the personal data you have provided to us, you have the right to request access to, rectification or erasure of your personal data, or restriction of processing, as well as the right to object to the processing of your data and the right to data portability.

Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority. The supervisory authority in the Republic of Bulgaria within the meaning of the applicable legislation is the Commission for Personal Data Protection.

Data Protection and Security

We use appropriate organisational, technical, administrative and physical measures to protect personal data. Unfortunately, no organisation or information-processing system can guarantee absolute information security.

Cookies

The websites of ACTA PHARMA AD use cookies. “Cookies” are text files stored on a computer system through an internet browser. Many websites and servers use cookies. Many cookies contain a so-called “cookie ID”. A cookie ID is a unique identifier of the cookie. It consists of a string of characters that can be assigned by websites and servers to the specific internet browser in which the cookie is stored. This enables visited websites and servers to distinguish the individual browser of the data subject from other internet browsers containing different cookies. A specific internet browser may be recognised and identified through the unique cookie identifier. Through the use of cookies, ACTA PHARMA AD may provide users of this website with more user-friendly services that would not be possible without the use of cookies. With the help of cookies, information and offers on our website may be optimised with regard to the data subject. Cookies enable us to recognise users of our website. The purpose of such recognition is to facilitate users in their use of the website. For example, a data subject using cookies does not need to enter access data every time the website is accessed, as this is handled by the website and the cookie is stored on the data subject’s computer system. The data subject may stop the use of cookies on our website at any time by changing the relevant settings in the internet browser used and thereby permanently refuse the setting of cookies. In addition, cookies already set may be deleted at any time through the internet browser or other software programs. This is possible in all commonly used internet browsers. If the data subject disables the cookie setting in the internet browser used, not all functions of our website may be fully available.

Collection of General Data and Information

The website of ACTA PHARMA AD may collect a series of general data and information whenever a user or an automated system accesses the website. Such general data and information are stored in server log files. The data collected may include: (1) the types and versions of browser used, (2) the operating system used by the accessing system, (3) the website from which the accessing system reaches our website (so-called referrers), (4) sub-pages, (5) the date and time of access to the website, (6) the Internet Protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems. When using this general data and information, ACTA PHARMA AD does not draw any conclusions regarding the data subject. Rather, this information is necessary to: (1) provide the content of our website correctly, (2) optimise the content of our website and its advertising, (3) ensure the long-term viability of our information technology and website technologies, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. Therefore, ACTA PHARMA AD analyses the anonymously collected data and information statistically in order to increase data protection and data security within our company and to ensure an optimal level of protection of the personal data we process. The anonymous data in the server log files are stored separately from all personal data provided by users.

Contact via the Website

The website of ACTA PHARMA AD contains information enabling rapid electronic contact with us, as well as direct communication with us, including the general e-mail address [email protected]. If a data subject contacts the Controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data voluntarily transmitted by the data subject to the Controller are stored for the purpose of processing the request or communicating with the data subject. These personal data are not transferred to third parties.

Routine Erasure and Blocking of Personal Data

The Controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose for which the data are stored, or to the extent required by applicable legislation. If the purpose of storage no longer applies or if a retention period prescribed by law expires, the personal data are routinely blocked or erased in accordance with legal requirements.

Data Protection Provisions Regarding the Implementation and Use of Google Analytics (with Anonymisation Function)

The Controller may integrate the Google Analytics component into this website, including an anonymisation function. Google Analytics is a web analytics service. Web analytics involves the collection and analysis of data concerning the behaviour of visitors to websites. The web analytics service collects, among other data, information about the website from which a person has accessed the website (the so-called referrer), which sub-pages were visited, and how frequently and for how long sub-pages were viewed. Web analytics is primarily used to optimise a website and to perform cost-benefit analyses of internet advertising. The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. For web analytics through Google Analytics, the Controller uses the application “_gat. _anonymizeIp”. Through this application, Google truncates and anonymises the IP address of the data subject’s internet connection when accessing our websites from a Member State of the European Union or another country party to the Agreement on the European Economic Area. The purpose of the Google Analytics component is to analyse traffic to our website. Google uses the collected data and information, among other things, to evaluate the use of our website and to provide us with online reports showing activities on our websites and to provide other services related to the use of our website. Google Analytics places a cookie on the data subject’s information technology system. The definition of cookies is explained above. By setting the cookie, Google may analyse the use of our website. Each time one of the individual pages of this website, which is operated by the Controller and on which a Google Analytics component has been integrated, is accessed, the internet browser of the data subject’s information technology system automatically transmits data through the Google Analytics component for the purposes of online advertising and the settlement of commissions by Google. During this technical procedure, Google obtains knowledge of personal information, such as the IP address of the data subject, which serves Google, among other things, to understand the origin of visitors and clicks. The cookie is used to store personal information, such as the time of access, the location from which access was made, and the frequency of visits to our website by the data subject. Each time our website is visited, such personal data, including the IP address used for internet access, are transmitted to Google in the United States. Google stores these personal data in the United States. Google may transfer the personal data collected through this technical procedure to third parties. The data subject may, as described above, prevent cookies from being set through our website at any time by adjusting the relevant settings of the internet browser used and thereby permanently refuse the setting of cookies. Such a setting in the internet browser would also prevent Google Analytics from setting a cookie on the data subject’s information technology system. In addition, cookies already used by Google Analytics may be deleted at any time through an internet browser or other software programs. Furthermore, the data subject has the possibility to object to the collection of data generated by Google Analytics in connection with the use of this website, as well as to the processing of such data by Google, and to prevent such processing. For this purpose, the data subject must download and install the browser add-on available at https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data or information concerning visits to websites should be transmitted to Google Analytics. Installation of the browser add-on constitutes an objection to Google. If the data subject’s information technology system is subsequently deleted, formatted or newly installed, the data subject must reinstall the browser add-on in order to disable Google Analytics. If the browser add-on is uninstalled by the data subject or another competent person, or is disabled, it may be reinstalled or reactivated. Additional information and the applicable Google data protection provisions may be accessed at https://www.google.com/intl/bg/policies/privacy/ and http://www.google.com/analytics/terms/us.html. Google Analytics is further explained at https://www.google.com/analytics/.

Data Protection Provisions Regarding the Implementation and Use of Google+

The Controller may integrate the Google+ button as a component on this website. Google+ is a social network. A social network is an online social meeting place, generally allowing users to communicate with each other and interact in a virtual environment. A social network may serve as a platform for exchanging opinions and experiences or enable the internet community to provide personal or business-related information. Google+ allows users of the social network to create private user profiles, upload photographs and build networks of contacts through friendship requests. Google+ is operated by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. Each time one of the individual pages of this website, operated by the Controller and containing an integrated Google+ button, is accessed, the internet browser of the data subject’s information technology system automatically downloads the corresponding Google+ button interface from Google through the relevant Google+ button component. During this technical procedure, Google is informed which specific sub-page of our website has been visited by the data subject. Further information about Google+ is available at https://developers.google.com/+/. If the data subject is simultaneously logged into Google+, Google recognises, each time our website is accessed, the person to whom the data relates and, for the entire duration of his or her visit to our website, which specific pages of our website have been visited by the data subject. This information is collected through the Google+ button and associated by Google with the relevant Google+ profile. Through the Google+ button, Google receives information that the data subject has visited our website if the data subject is logged into Google+ at the time our website is accessed. This occurs regardless of whether or not the data subject clicks on the button. If the data subject does not wish to transmit personal data to Google, he or she may prevent such transmission by logging out of the Google+ account before accessing our website. Additional information and Google’s data protection provisions can be accessed at https://www.google.com/intl/bg/policies/privacy/. Further references from Google concerning the Google+ button can be obtained at https://developers.google.com/+/web/buttons-policy.

Updates

This Privacy Policy may be subject to changes and updates. In such a case, we will indicate the date of the change at the beginning of the Privacy Policy, and the changes and updates will apply to you and your personal data from the date of the latest revision. Last updated: 1 September 2026
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