Privacy Notice
Introduction
This Privacy Notice takes effect on 25th May 2018. It sets out the information summarised in the table of contents below:
1. Who we are
- Prokopieva, Troyanov, Russenov & Partners Law Firm (hereinafter referred to as “PTR&P”, “we” or “us”) is a Law firm which provides Bulgarian and European professional services in the Republic of Bulgaria, the EEA and also services, overseas clients. PTR&P values the privacy of those who provide personal information to us. This privacy policy (the “Policy”) describes how and why we collect, store and use personal information, and provides information about individual’s rights.
- We are:
- authorised and regulated by the Supreme Bar Association and registered in the Sofia City Court with registered number 175667628. Our registered office is at 76а James Bourchier blvd., Sofia, Bulgaria;
- responsible for the www.eu-bg.com website (“Website”);
- for the purposes of the General Data Protection Regulation EU 2016/679 (“GDPR”) and Bulgarian data protection laws, the Data Controller in respect of the processing described in this Privacy Notice;
2. The categories of personal data we collect
- We may collect the following categories of personal data about you:
- your name and contact information such as your home and/or business address, email address and telephone number
How do we collect this category?
This information is collected upon your disclosure to us, through whatever means which that may happen, including but not limited to through e-mail, telephone, mail, in person.
How do we use this category?
For contact and communication purposes: we shall not use your contact information to send you legal updates that we may circulate from time to time, news about any events we are organising or participating in, and/or other information about us and the services that we believe may be of interest to you, unless you specifically request us to.
Making contact details available to our staff – in order for our staff to be able to adequately provide you with the requested services.
Thus, we process this category on the grounds of the adequate performance of a contract with you.
How long are we going to store this category?
Personal Information is retained on our Server for as long as it is necessary for the purposes set out above (being the length of the business relationship). If a business contact requests to be forgotten their contact details will be deleted from our Server. If this information is somehow related to any legal claim or action that we have represented you on we shall be obliged under the Bar Association Act to retain such information for no less than 5 years after the termination or resolution of said legal claim or action.
- identity and biographical information including your nationality, date of birth, tax status, passport / national identity card details and country of domicile, your employment and employment history, job title and role, educational profile, interests and other information relevant to our provision of professional services;
How do we collect this category?
This information is collected upon your disclosure to us, through whatever means which that may happen, including but not limited to through e-mail, telephone, mail, in person.
How do we use this category?
For the purposes of providing adequate legal services to you and in order to comply with AML/FT obligations.
Thus, we process this category on the grounds of the adequate performance of a contract with you and our legal obligations.
How long are we going to store this category?
Personal Information is retained on our Server for as long as it is necessary for the purposes set out above (being the length of the business relationship). If a business contact requests to be forgotten their contact details will be deleted from our Server. If this information is somehow related to any legal claim or action that we have represented you on we shall be obliged under the Bar Association Act to retain such information for no less than 5 years after the termination or resolution of said legal claim or action.
- (if applicable and required for the provision of services) information in relation to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details and other information necessary for processing payments and for fraud prevention purposes;
How do we collect this category?
This information is collected upon your disclosure to us, through whatever means which that may happen, including but not limited to through e-mail, telephone, mail, in person.
How do we use this category?
For the purposes of providing adequate legal services to you and in order to comply with AML/FT obligations.
Thus, we process this category on the grounds of the adequate performance of a contract with you and our legal obligations.
How long are we going to store this category?
Personal Information is retained on our Server for as long as it is necessary for the purposes set out above (being the length of the business relationship). If a business contact requests to be forgotten their contact details will be deleted from our Server. If this information is somehow related to any legal claim or action that we have represented you on we shall be obliged under the Bar Association Act to retain such information for no less than 5 years after the termination or resolution of said legal claim or action.
- (if applicable and required for the provision of services) an understanding of your goals and objectives and other information provided to us in connection with our provision of professional services;
How do we collect this category?
This information is collected upon your disclosure to us, through whatever means which that may happen, including but not limited to through e-mail, telephone, mail, in person.
How do we use this category?
For the purposes of providing adequate legal services to you.
Thus, we process this category on the grounds of the adequate performance of a contract.
How long are we going to store this category?
Personal Information is retained on our Server for as long as it is necessary for the purposes set out above (being the length of the business relationship). If a business contact requests to be forgotten their contact details will be deleted from our Server. If this information is somehow related to any legal claim or action that we have represented you on we shall be obliged under the Bar Association Act to retain such information for no less than 5 years after the termination or resolution of said legal claim or action.
- (if applicable and required for the provision of services) information about our meetings with you, in particular at our offices; and / or
How do we collect this category?
This information is collected upon your disclosure to us, through whatever means which that may happen, including but not limited to through e-mail, telephone, mail, in person.
How do we use this category?
For the purposes of providing adequate legal services to you.
Thus, we process this category on the grounds of the adequate performance of a contract.
How long are we going to store this category?
Personal Information is retained on our Server for as long as it is necessary for the purposes set out above (being the length of the business relationship). If a business contact requests to be forgotten their contact details will be deleted from our Server. If this information is somehow related to any legal claim or action that we have represented you on we shall be obliged under the Bar Association Act to retain such information for no less than 5 years after the termination or resolution of said legal claim or action.
- (if applicable and required for the provision of services) in case you are a business owner or a representative of any corporate or other entity – information about your employees and other natural persons related to said entity, including e-mail, contact data, CVs and any other personal data regarding these employees and other natural persons related to said entity that you might decide to share with us. You certify that where you have provided information regarding any third person besides yourself you have received prior consent from that other person to provide their personal information to us.
How do we collect this category?
This information is collected upon your disclosure to us, through whatever means which that may happen, including but not limited to through e-mail, telephone, mail, in person.
How do we use this category?
For the purposes of providing adequate legal services to you.
Thus, we process this category on the grounds of the adequate performance of a contract.
How long are we going to store this category?
Personal Information is retained on our Server for as long as it is necessary for the purposes set out above (being the length of the business relationship). If a business contact requests to be forgotten their contact details will be deleted from our Server. If this information is somehow related to any legal claim or action that we have represented you on we shall be obliged under the Bar Association Act to retain such information for no less than 5 years after the termination or resolution of said legal claim or action.
- your name and contact information such as your home and/or business address, email address and telephone number
- Оur provision of professional services may also require us to process special category data (including data relating to the racial or ethnic origin, political opinions, religious beliefs, trade union membership, health and sexual life) and/or data relating to criminal convictions and offences (together “sensitive personal data”). Where we process sensitive personal data, other lawful processing grounds may apply, such as that the processing is necessary for the establishment, exercise or defence of legal claims (for example to protect and/or defend our property or rights, or those of our clients) or for reasons of substantial public interest; or where you have given us your explicit consent.
3. Who we may share your data with
- We may share your personal data with:
- your organisation;
- with our client in the particular matter;
- third parties we engage to assist in providing our professional services, such as lawyers (including barristers), other professional services firms, IT and other consultants, public relations advisers, translators and / or couriers;
- intermediaries to whom we introduce you;
- our own legal and professional services providers and insurers, where appropriate;
- courts and other authorities in connection with the enforcement or defence of legal rights and provision of our professional services.
4. Transfer and processing of your personal data outside the European Economic Area
- Where we disclose any of your collected personal information outside EEA to the USA (if applicable), we shall comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework and any other adequacy decision.
- In case personal information is shared with corporate affiliates or third-party Product providers outside the EEA in absence of an adequacy decision, we have – prior to sharing your information with such corporate affiliate or third-party Product provider – established the necessary means to ensure an adequate level of data protection. We will provide further information on the means to ensure an adequate level of data protection on request.
5. Your rights
- You may exercise any of the rights described in this section by sending an email to us. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.
- Managing Your Information.
You have the right to obtain the following:- confirmation of whether, and where, the we are processing your personal data;
- information about the purposes of the processing;
- information about the categories of data being processed;
- information about the categories of recipients with whom the data may be shared;
- information about the period for which the data will be stored (or the criteria used to determine that period);
- information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing;
- information about the existence of the right to complain to any Regulator;
- where the data was not collected from you, information as to the source of the data;
- information about the existence of, and an explanation of the logic involved in, any automated processing.
Additionally, you may request a copy of the personal data being processed.
- Rectification of Inaccurate or Incomplete Information.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you. - Data Access and Portability.
You have the right to:- receive a copy of your personal data in a structured, commonly used, machine-readable format that supports re-use;
- transfer your personal data from one controller to another;
- store your personal data for further personal use on a private device;
- have your personal data transmitted directly between controllers without hindrance. In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.
- Data Retention and Erasure.We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information, you can request that we erase your personal information unless there is another reason which prevents us by law to erase your data. Since the Data Controller is a regulated Law firm, Data Controller is obliged under the Bar Association Act to keep your personal information and all transactions history for a period of 5 years after the termination of the relationship with you. Please note that if you request the erasure of your personal information:
- We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
- Because we maintain our systems to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
- Withdrawing Consent and Restriction of Processing.Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular, where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.
- Objection to Processing.In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
- Lodging Complaints.
- You should in the first place try to resolve the matter by sending an e-mail to:Prokopieva, Troyanov, Russenov & Partners Law Firm, Bulgaria you may contact us at:e-mail: office@eu-bg.comAddress: 76a James Bourchier Blvd., Sofia, Bulgaria
- In case you are not satisfied with the reply or resolution of the Data Controller, you have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities.You have the right to file a complaint with the Data Controller’s lead supervisory authority, the Commission for Protection of Personal Data, Bulgaria:Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, BulgariaTel: 02 91 53 518
e-mail: kzld@cpdp.bg
6. We use cookies on our Website, in accordance with our Cookie Policy.
7. Changes to this Privacy Notice
We may update this Privacy Notice in line with changes to how we process personal data. We will publish any new version of the Privacy Notice on the Website and, where appropriate, will provide you with a copy.