PRIVACY POLICY PRIVACY POLICY

This privacy statement describes the ways in which Bulgariaka NPA collects, holds and uses information about individuals who visit the website http://www.bulgarika.eu or use the services offered by Bulgarika.

We would like to inform you that we have taken the necessary measures for lawful, fair and transparent processing of your private data. This information explains the purposes and legal grounds for the processing of your personal data.

Please, read carefully this Information to learn details about how your personal data will be processed as customer, prospect or other interested party.

Regardless of the purposes and grounds for processing your personal data, we will treat them with equal care. This Information contains your rights and means of protection in accordance with applicable law.

More information about the Bulgarian legislation on the personal data protection can be found on the website of the Commission for Personal Data Protection: www.cpdp.bg.

By using the website of Bulgarika NPA products and services, we offer, you agree to the collection and using of information as set out in this privacy policy. You also confirm that Bulgarika NPA may periodically at its discretion and without notice amend, supplement or revoke or otherwise update this Privacy Policy. We will treat your Personal Data at any time according to the Privacy Policy in force at the time of its collection.

We will publish the amendments to our privacy policy on this website to keep you fully informed about the types of information we collect, how we use this information, and under what circumstances it may be disclosed. Our Privacy Policy is published on our homepage and is available on any page where Personal Data is requested. At the places where data is collected, additional explanations may be provided, if applicable, on the purposes for which the data will be used.

When processing your Personal Data Bulgarika NPA observes the following principles:

– Legality, good faith and transparency;

– Restriction of processing purposes;

– Correlation with the purposes of processing and minimizing the collected data;

– Accuracy and timeliness of data;

– Restriction of storage in order to achieve the objectives;

– Integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.

The following sections explain how and when we will collect Personal Data from you

I. INFORMATION ABOUT THE PERSONAL DATA ADMINISTRATOR

Denomination: Bulgarika NPA;

UIC / BULSTAT: 175668185;

Headquarters and address of management: Varna, 12 Slavyanska Str .;

Correspondence data: Varna, 12 Slavyanska Street;

Email: contact@bulgarika.eu

Phone: 052 609 178; 052 605 430; 0884 58 58 98;

II. INFORMATION ABOUT THE COMPETENT SUPERVISORY AUTHORITY

Title: Commission for Personal Data Protection

Headquarters and address of management: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2

Correspondence data: Sofia 1592, Blvd. “Prof. Tsvetan Lazarov ”№ 2

Telephone: 02 915 3 518

Email: kzld@government.bg, kzld@cpdp.bg;

Website: www.cpdp.bg.

Bulgarika NPA operates in accordance with the Personal Data Protection Act and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of physical persons with regard to the processing of personal data and on the free movement of such data.

III. GROUNDS FOR THE COLLECTION, PROCESSING AND STORAGE OF YOUR PERSONAL DATA

 3.1 Bulgarika NPA collects and processes your personal data in connection with the provision of services and conclusion of contracts with the company pursuant to Art. 6, para. 1, Regulation (EU) 2016/679, and in particular on the basis of the following:

  • Explicit consent received from you as a customer;
  • Fulfillment of the obligations of Bulgarika NPA under a contract with you;
  • Compliance with a legal obligation that applies to Bulgarika NPA
  • For the purposes of the legitimate interest of Bulgarika NPA

 3.2 Bulgarika NPA is an administrator of personal data regarding your data as users of our services. Regarding the personal data that you collect and process using our services, Bulgarika NPA is in its capacity as a processor of personal data.

IV. PRIVACY POLICY

As used in this Privacy Policy, the term “Personal Data” refers to information such as your name, date of birth, unique civil number, e-mail, mailing address or telephone number, occupation, activity, etc., which may be used to identify you.

We will process Personal Data only in accordance with this Privacy Policy, reserving the right to perform additional processing to the extent permitted or required by law or in support of a legal or criminal investigation.

V. PURPOSES OF THE COLLECTION, PROCESSING AND STORAGE OF YOUR PERSONAL DATA

5.1 For most of the services on the website www.bulgarika.eu no form of registration is required, which allows you to visit our site without informing us who you are. For the use of the services we offer and inclusion in the events that we organize, however, it is necessary for you to provide us with Personal Data. In this case, if you decide not to provide the Personal Data requested by us, you will not be able to access certain parts of our site and use the services we offer.

5.2 We collect and use Personal Data to provide you with products or services, to invoice products and services you want, to offer products and services that we believe may be of interest to you, or to communicate with you with another purpose, which is evident from the circumstances or for which we inform you when collecting Personal Data from you.

5.3 Activities for which we collect and use personal data, including but not limited to:

– Creating an account and providing full functionality in providing our services online;

– Individualization of a party to a contract;

– Registration of a participant in a training / event organized by Bulgarika NPA;
– Accounting purposes;

– Statistical goals;

– Information security protection;

– Ensuring the implementation of the contract for the provision of the respective service;

– Sending information messages, messages about changes in services, recommendations for improving the use of the platform, etc.

– Improving and individualizing the service by offering suitable offers for you and other products and services that may be of interest to you;

5.4 In the processing and storage of personal data, Bulgarika NPA may process and store personal data in order to protect the following legitimate interests: Fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal authorities.

VI. WHAT TYPE OF PERSONAL DATA DOES BULGARIKA NPA COLLECT, PROCESS AND STORE?

6.1 Bulgarika NPA performs the following operations with personal data for the following purposes:

6.1.1 User registration on the website and fulfillment of a contract for the provision of services, participation in trainings and/or events organized by Bulgarika. The purpose of this operation is to create an account that is associated with the service used.

6.1.2 Concluding and executing a trade transaction with a client or partner – the purpose of this operation is concluding and executing a contract with a trade partner or client and its administration;

6.1.3 Sending information messages – the purpose of this activity is to administer the process of sending messages to customers that relate to improvements or changes in services, new services, events and more.

6.1.4 Direct marketing of products and services offered by Bulgarika NPA. The consent for the processing of personal data according to this item is provided by the data subject in a special Declaration of Consent of the Client.

6.1.5 Sending a newsletter – the purpose of this operation is to administer the process of sending newsletters to customers who have stated that they wish to receive it.

6.1.6 Sending messages for products and services – Bulgarika NPA processes personal data to send messages about the products and services used by the customer through calls, emails, SMS, letters, etc. The messages refer only to the products and services already used by the customer; The communications are not made for marketing purposes, nor do they contain new offers of services.

6.1.7 Disputes – Creation, exercise or protection of rights of Bulgarika NPA – Bulgarika NPA will process the data of its client in order to protect its rights in court proceedings, in settling claims with the help of external lawyers and others. This applies to situations where personal data are processed in connection with the administration of information related to litigation, court guarantees, applications and court decisions.

6.2 Bulgarika NPA processes the following categories of personal data and information for the following purposes and on the following grounds:

6.2.1 Data: Your personalization data (name, surname, surname, e-mail, address, telephone, profession, activity);

Purpose for which the data is collected: 1) User registration; 2) Making contact with the user and sending information to him, including in case of expressed desire – to send newsletters and advertising messages; 3) Request a service, participation in a training or event offered and/or organized by Bulgarika NPA.

Grounds for processing your personal data – By accepting the general terms and conditions and this Privacy Policy, upon registration on the website and requesting a service/activity, a contractual relationship was created between Bulgarika NPA and you, on which basis we process your personal data – Art. 6, para. 1, b. (b) GDPR.

6.2.2 Other data processed by Bulgarika NPA – When logging in our website or in your profile, Bulgarika NPA collects data on the IP address used.

Purpose for which the data is collected: Improving the security of the service and localization of the interface, statistical and marketing research.

Grounds for data processing: The processing is necessary for the performance of a contract to which the data subject is a party – Art. 6, para. 1, b. (b) of the GDPR. Until the creation of a user profile, the IP address is collected based on the realization of the legitimate interests of the administrator – Art. 6, para. 1, p. (f) of the GDPR.

More information about cookies, internet tags, Google Analytics, links to other sites and more. you can read below in this Privacy Policy.

6.2.3 Your data on the issuance of an invoice to a natural person – If you wish to be issued an invoice in your capacity as a natural person, you should provide your unique civil number.

Purpose for which the data is collected: Issuance of an invoice for making payments under a concluded contract for the provision of services.

Grounds for processing your personal data – By accepting the general terms and conditions, this Privacy Policy and registration on the website, or by concluding a written contract, between Bulgarika NPA and you a contractual relationship is concluded on which basis we process your personal data – Art. 6, para. 1, b. (b) GDPR.

6.2.4 When applying for Certification training for mediators, upgrading training for mediators or training according to Decree No. 12 of 01.09.2016 on the status and professional development of teachers, principals and other pedagogical specialists you should also provide your unique civil number.

Purpose for which the data is collected: Issuance of a certificate for entry in the Unified Register of Mediators at the Ministry of Justice, issuance of a certificate for participation in further training, issuance of a Certificate for participation in training, according to Ordinance 12 of 01.09.2016 of the Minister of Education, etc.

Grounds for processing your personal data – By accepting the general terms and conditions, this Privacy Policy and registration on the website, or by concluding a written contract, between  Bulgarika and you a contractual relationship is created on which basis we process your personal data – Art. 6, para. 1, b. (b) GDPR.

6.3 Bulgarika NPA does not collect or process personal data relating to the following:

– Reveal racial or ethnic origin;

-Reveal political, religious or philosophical beliefs, or membership in trade unions;

– Genetic and biometric data, health data or data on sexual life or sexual orientation.

6.4 The personal data are collected by Bulgarika NPA from the persons to whom it relates or from their parents / guardians.

6.5 Bulgarika NPA does not perform automated decision making with data.

VII. PERIOD OF STORAGE OF YOUR PERSONAL DATA

7.1 Bulgarika NPA stores your personal data for a period not longer than the existence of your account on the website and/or until the completion of the activities of the requested service /training/event. After the expiration of this period, Bulgarika NPA takes the necessary care to delete and destroy all your data without undue delay.

7.2 Bulgarika NPA notifies you in case the data storage period needs to be extended in order to fulfill the objectives, fulfill the contract, in view of the legitimate interests of Bulgarika NPA or otherwise.

7.3 Bulgarika NPA stores the personal data that it is necessary to keep under applicable law for the relevant period, which may exceed the period of existence of your registration.

VIII. TRANSMISSION OF YOUR PERSONAL DATA FOR PROCESSING

8.1 Bulgarika NPA may at its discretion transfer part or all of your personal data to personal data processors for the purposes of processing in compliance with the requirements of Regulation (EU) 2016/679.

8.2 We may disclose your Personal Data to other Bulgarika NPA affiliates worldwide who agree to treat it in accordance with this Privacy Policy. It is also possible for Personal Data to be transferred to third parties acting on our behalf for further processing in accordance with the purpose (s) for which they were originally collected, or to be lawfully processed in another way, such as delivery of services, evaluation of the usefulness of Bulgarika NPA websites, marketing, data management or technical support. These third parties have agreed with us to use Personal Data only for the agreed purpose and not to sell your Personal Information to third parties, and not to disclose them to third parties, except as required by law, permitted by us or specified in this Privacy Policy.

8.3 It is also possible that the Personal Data collected by you to be transferred to a third party in case the activity of Bulgarika NPA or part of it and the customer data related to it are subject to sale, assignment or transfer, in which case we will request by the buyer, successor or acquirer to treat the Personal Data in accordance with this Privacy Policy.

8.4 Personal data may be disclosed to a third party if we are required to do so by applicable law, court order or act of a public authority, or if the disclosure is otherwise necessary in support of a criminal or other investigation or proceeding in country or abroad.

8.5 Bulgarika NPA notifies you in case of intention to transfer part or all of your personal data to third countries or international organizations.

IX. YOUR RIGHTS IN THE COLLECTION, PROCESSING AND STORAGE OF YOUR PERSONAL DATA

  • Non-disclosure of Personal Data.

9.1.1 We will not sell, share or otherwise give your Personal Data to third parties, except as provided in this Privacy Policy.

9.2 Withdrawal of consent for the processing of your personal data

9.2.1 If you do not wish all or part of your personal data to continue to be processed by Bulgarika NPA for a specific or for all purposes of processing, you may at any time withdraw your consent to processing by filling in a form that we may provide on the basis of a request sent to us by you or by a free text request.

9.2.2 Bulgarika NPA may ask you to verify your identity and the identity with the person who is the data subject.

9.2.3 By withdrawing the consent for the processing of personal data, which is mandatory for the creation and maintenance of your registration or for the use of the services, your account will become inactive and your access to products/services will be restricted.

9.3 Right of access, rectification and objection

9.3.1 In any processing of Personal Data, we take steps to ensure that your Personal Data is accurate and current for the purposes for which it was collected. If the processing is not reasonably necessary aming a legitimate purpose as described in this policy or aiming our compliance with the law, we will give you the opportunity to object to the processing of your Personal Data. In the case of electronic direct marketing, we will offer you a way to choose the option to no longer receive marketing materials or a way to choose the option to receive, if required by law.

9.3.2 You are entitled to request and receive from Bulgarika NPA a confirmation wether personal data related to you is processed.

– You have the right to receive an access to data, as well as to information, related to collection, processing and storage of your Personal Data.

– Bulgarika NPA provides you upon request a copy of the processed personal data, related to you, in electronic form or in some other suitable form.

– Providing access to data is free of charge, but Bulgarika NPA reserves its right to impose an administrative fee in case of repetitive or excessive requests.

9.3.3 You may correct or complete inaccurate or incomplete personal data relating to you directly through your account on the Website or by requesting Bulgarika NPA.

9.4 Right to be deleted (“to be forgotten”)

9.4.1 You have the right to request Bulgarika NPA to delete the personal data related to you, and Bulgarika NPA has the obligation to delete them without undue delay when any of the following reasons exist:

  • Personal data are no longer needed for the purposes for which they were collected or otherwise processed;
  • You withdraw your consent on which the data processing is based and there is no other legal basis for the processing;
  • You object to the processing of personal data relating to you, including for direct marketing purposes, and there are no legal grounds for processing to take precedence;
  • Personal data has been processed illegally;
  • Personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State applicable to Bulgarika NPA
  • Personal data have been collected in connection with the provision of information society services.

9.4.2 Bulgarika NPA is not obliged to delete personal data if it stores and processes them:

  • To exercise the right to freedom of expression and the right to information;
  • To comply with a legal obligation requiring processing provided for in EU law or the law of the Member State applicable to the Administrator or for the performance of a task in the public interest or in the exercise of official powers conferred on him;
  • For reasons of public interest;
  • For archiving purposes of public interest, for scientific or historical research or for statistical purposes;
  • To establish, exercise or defend legal claims.

9.4.3 In order to exercise your right to “forget”, you should submit a request sent to Bulgarika NPA as well as verify your personality and identity with the person to whom the data relates before  Bulgarika NPA by presenting your personal card for identification purposes and, if necessary, enter your login details in the account of the person who is a subject of this data before an officer of Bulgarika NPA.

9.4.4 Bulgarika NPA does not delete data that it has a legal obligation to keep, including for protection in connection with legal claims against it or proof of its rights.

9.5 Right of restriction

9.5.1 You have the right to request Bulgarika NPA to restrict the processing of data related to you when:

  • You dispute the accuracy of personal data for a period that allows Bulgarika NPA to verify the accuracy of personal data;
  • The processing is illegal, but you do not want your personal data to be deleted, only their use to be restricted;
  • Bulgarika NPA no longer needs personal data for the purposes of processing, but you require them to establish, exercise or defend your legal claims;
  • You have objected to the processing pending verification that the legal grounds of Bulgarika NPA take precedence over your interests.

9.6 Right of portability

9.6.1 You may at any time receive the data stored and processed for you in connection with the use of Bulgarika NPA services by e-mail request.

9.6.2 You may request Bulgarika NPA to transfer your personal data directly to an administrator designated by you, where technically feasible.

9.7 Right to receive information

9.7.1 You may request Bulgarika NPA to inform you of all recipients to whom the personal data for which correction, deletion or restriction of processing has been requested have been disclosed. Bulgarika NPA may refuse to provide this information if this would be impossible or would require a disproportionate effort.

9.8 Right to object

9.8.1 You may object at any time to the processing of personal data by Bulgarika NPA relating to you, including if it is processed for profiling or direct marketing purposes.

9.9 Your rights in the event of a breach of the security of your personal data

9.9.1 If Bulgarika NPA finds a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, we will notify you without undue delay of the breach and of the measures that have been taken or are to be taken.

9.9.2 Bulgarika NPA is not obliged to notify you if:

– they have themselves taken appropriate technical and organizational protection measures with regard to data affected by the security breach;

– they have subsequently taken measures to ensure that the breach will not lead to a high risk to your rights;

– Notification would require a disproportionate effort.

9.10 Persons to whom your personal data is provided

9.10.1 In order to perform certain activities upon a request submitted by you, including, but not limited to, for the purposes of accounting services for the activity, Bulgarika NPA transmits the necessary information to the respective processor of personal data.

9.10.2 The processor of personal data undertakes to strictly observe this Privacy Policy and is not allowed to transfer your data to third countries.

9.11 Other provisions

9.11.1 In the event of a breach of your rights under the above or applicable data protection legislation, you have the right to lodge a complaint with the Data Protection Commission as follows:

  1. Name: Commission for Personal Data Protection
  2. Headquarters and address of management: Sofia 1592, Blvd. Prof. Tsvetan Lazarov № 2
  3. Data for correspondence: Sofia 1592, Prof. Tsvetan Lazarov № 2
  4. Phone: 02 915 3 518
  5. Email: kzld@government.bg, kzld@cpdp.bg
  6. Website: www.cpdp.bg.

9.11.2 You may exercise all your rights regarding the protection of your personal data through the forms and in the manner described in this Privacy Policy. These forms are optional and you can submit your requests in any form that contains a statement to that effect and identifies you as the data owner.

9.11.3 If the consent concerns a transfer, the Controller shall describe the possible risks for the transfer of the data to third countries in the absence of a decision on adequate protection and appropriate means of protection.

9.11.4 When you assign Bulgarika NPA to process personal data of a third party for the purposes of using the services, Bulgarika NPA acts as a processor of personal data.

9.11.4.1 In the cases under Art. 9.11.4, Bulgarika NPA acts only on your instructions as a user of the services and only to the extent that it can have control over the personal data that you process. Bulgarika NPA has no control over the content and data that you as a user of the service choose to include. Bulgarika NPA also has no role in the process of deciding whether the user uses the personal data processing service, for what purposes and whether they are protected. Accordingly, the liability of Bulgarika NPA in this case is limited to 1) Compliance with the instructions of the user of the service according to the contract and the general conditions and 2) Providing information about the service and functionalities through its interface.

9.11.5 If you wish to contact us regarding our use of your Personal Data or to object to the processing of your Personal Data, write to us at: support@bulgarika.eu. In the message to us, indicate the location of the website or service contract where you provided the information, as well as the specific information you would like us to correct, update or delete, together with proper identification. Requests for the deletion of personal data will be subject to all applicable legal and ethical obligations imposed on us to communicate or to submit or store documents.

X. SECURITY AND CONFIDENTIALITY

10.1 To ensure the security and confidentiality of the Personal Data we collect on paper and online, we use data networks, password protected and a special space, protected against external access in which we store documents containing personal data. When handling your Personal Data, we take measures to protect the information from loss, misuse, unauthorized access, disclosure, alteration or destruction.

XI. COOKIES, INTERNET TAGS, GOOGLE ANALYTICS

11.1 We may collect and process information about your visits to this website, such as the pages you visit, the website you come from, and some of the searches you make. We use this information to improve the content of the site and to collect aggregate statistics for the users of our site for internal purposes in connection with market research. In this process, we may set cookies that collect information about the user’s domain name, your ISP, your operating system, and the date and time of access. A cookie is a small piece of information sent to your browser and stored on your computer’s hard drive. Cookies do not harm your computer. You can set your browser to notify you when you receive a cookie, which will allow you to decide whether you want to accept it or not.

We would like to inform you that if you do not accept cookies, you will not be able to use the full functionality of your browser software. We may also receive services from outsiders who assist us in collecting and processing the information described in this section.

11.2 We may sometimes use Internet tags (also known as “action tags”, “single-pixel GIFs”, “clear GIFs”, “invisible GIFs” and “1-by-1 GIFs”) and cookies on this site, as well as to implement them through a third party – an advertising partner or a web analytics partner who locates and stores the relevant information (including your IP address) in another country. These tags/cookies are placed both in online ads that lead users to this site and on various pages on this site. We use this technology to measure the response of visitors to our sites and the effectiveness of our advertising campaigns (including how many times a page has been opened and what information has been viewed), as well as to evaluate your use of this website. With the help of these tags / cookies the third party-partner or the web analytics partner can collect data about the visitors of our and other sites, prepare reports for us about the activity of the website and provide other services related to the use of the website and Internet. These partners may provide the information collected to others if there is such a legal requirement or if they engage others to process information on their behalf.

11.3 Google Analytics

We use the Google Analytics service to integrate and optimize web pages, if applicable. Google Analytics is a service offered by Google Inc. that provides detailed statistics on website traffic and traffic sources and measures the conversion of users to customers (conversion) and sales. Google Analytics uses cookies stored on your computer to analyze how users use our website.

The information generated by the cookie about your use of our website, including your IP address, will be rendered anonymous using the appropriate settings and transmitted to Google’s servers in the United States. For more information on the process of converting IP to anonymous form, see https://support.google.com/analytics/answer/2763052.

Google will use the information generated by the cookie on our behalf in order to evaluate the use of our website, to compile reports on website activity and to provide us with these reports for analysis purposes. Google may transfer this information to third parties where it has a legal obligation or if a third party processes data on Google’s behalf. Under no circumstances will Google combine or associate your IP address with other data stored by Google.

You can disable or stop the installation and storage of cookies through your browser settings by downloading and installing the free Opt-out Browser Add-on software, available at: https://tools.google.com/dlpage/gaoptout?hl=en. Please note that in this case you will not be able to use all the features of our website.

By using our website, you give your consent to the processing of any personal data that Google will collect about you in the manner or for the purposes set out above.

XII. PERSONAL INFORMATION AND CHILDREN

 

12.1 Most of the services on this site are intended for persons over 18 years of age. For the specialized trainings of persons under 18 years of age, an explicitly agreed person with parental rights (parent or guardian) will be requested. We will not collect, use or disclose Personal Data from a minor without the prior consent of a person with parental rights (parent or guardian) through direct offline contact. We will provide the parent with: (a) a notice of the specific types of personal data that are collected by the minor, and (b) the opportunity to object to the further collection, use and storage of such information. We comply with child protection laws.

XIII. LINKS TO OTHER SITES

13.1 This Privacy Policy applies only to this website, but not to websites owned by third parties. We may post links to other websites that we believe may be of interest to our visitors. However, due to the nature of the Internet, we cannot guarantee the privacy standards of the websites we link to, or be responsible for the content of other sites other than this site. This Privacy Policy is not intended to apply to any linked site that is not owned by Bulgarika NPA.

XIV. CONTACT US

 

14.1 If you have any questions or complaints about our compliance with this Privacy Policy, or if you would like to make recommendations or comments about improving the quality of our Privacy Policy, please email us at: contact@bulgarika.eu.