Privacy Policy for the Clients of "BANNY" Holding
1. Who We Are and Scope
"BANNY" Holding, a limited liability company with NUIS M51930030K, with its registered office in Tirane, Qendra "Condor Center", kati i trete, zyra nr.67, Rruga e Kavajes, Tirane, operates as a Holding company, holding shares in other companies and providing assistance and coordination services (technical, administrative, financial, organizational) to its Group.
This Policy applies to the processing of personal data of:
- Direct Clients: Individuals or representatives of entities who sign contracts directly with "BANNY" Holding for assistance and coordination services.
- Indirect Clients (Group Clients): Individuals whose data are transmitted to us by the Group Companies (subsidiaries) to allow the Holding to perform its functions of control, centralized management, and coordination.
2. Personal Data We Process
Depending on the nature of the relationship, we may collect the following categories of data:
- Contact and Identification Data: Name, surname, address, email, telephone number.
- Contractual/Commercial Data: NUIS/Tax ID, data related to the service contract, products or services purchased from the Group.
- Payment and Billing Data: Bank details (IBAN), information related to payments and invoices.
- Legal Representative Data: Name, position, power of attorney, signature (if the client is a legal entity).
This data is collected directly from you or from the Group Companies with whom you have a relationship.
3. Purposes and Legal Basis of Processing
We process your personal data only when there is a valid legal basis, for the following purposes:
- Service Execution: We use the data to fulfill contracts and provide the requested assistance or coordination services. The legal basis is Contractual Performance.
- Administrative and Accounting Management: We process the data for billing, accounting, tax declarations, and compliance required by Albanian (and international) law. The legal basis is a Legal Obligation.
- Group Coordination: The data is processed for centralized management, internal control, and financial and strategic planning of the Holding. The legal basis is our Legitimate Interest in managing the Group efficiently.
- Dispute Management: We use the data for the defense of the legal rights of the Holding or the Group. The legal basis is Legitimate Interest or Legal Obligation.
4. Sharing of Personal Data (Recipients)
Your personal data may be shared with the following categories of recipients:
- Group Companies (Subsidiaries): To fulfill the purposes of coordination and management that constitute the corporate object of the Holding.
- External Service Providers: Legal consultants, auditors, IT hosting companies, banking services, who act as Data Processors on our behalf.
- Public Authorities and Institutions: When required by a legal provision or a judicial order (e.g., Tax Authorities, Judicial Authorities, the Commissioner for Personal Data Protection).
5. Data Retention and Security
We retain your personal data only for the time strictly necessary to pursue the purposes for which they were collected and to fulfill our legal obligations (e.g., accounting documentation is retained for the periods provided by Albanian law). We have implemented adequate technical and organizational security measures to protect personal data from unauthorized access, disclosure, alteration, or destruction.
6. Your Rights (Data Subject Rights)
As data subjects, you are entitled to the following rights in accordance with the applicable legislation (including the Albanian Law on Personal Data Protection):
- Right of Access: To obtain confirmation as to whether or not personal data concerning you are being processed, and to receive a copy thereof.
- Right to Rectification: To obtain the modification of inaccurate or incomplete data.
- Right to Erasure ("Right to be Forgotten"): To request the deletion of your data, subject to legal exceptions.
- Right to Object: To object to processing based on legitimate interest.
- Right to Lodge a Complaint: To file a complaint with the relevant Data Protection Authority (e.g., the Commissioner for Personal Data Protection in Albania).
7. Contact Information
For any questions or to exercise your rights, you can contact us:
- Data Controller: "BANNY" Holding
- E-Mail: corporate@banny.group
- Mailing Address: Tirane, Qendra "Condor Center", kati i trete, zyra nr.67, Rruga e Kavajes, Tirane.