Boyanov & Co. Law Firm, entered into the Registry of Law Firms at Sofia City Court under company file No. 3762/2005, BULSTAT 131403089, having its seat in Sofia, Bulgaria and its address of management at: 82, Patriarch Evtimii Blvd., 1463 Sofia, Bulgaria (“we”, “us”, “our”), is committed to protecting and respecting your privacy.
This Policy sets out the basis on which we process your personal data in our capacity as personal data controller, as defined in the General Data Protection Regulation (EU) 2016/679 (the “GDPR”). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We may collect personal data from you when you use our website, when we enter into a legal services agreement, as a result of your legal relationship with us or contact with our staff or clients, or otherwise in the course of our business activities.
In the context of provision of our professional services or otherwise in the course of our professional activity we may process the following categories of personal data:
• General information about you, such as your name, unified civic number (or other personal identification number, as applicable), industry, company data, position, education and/or professional experience, legal relationship to an organization, power of representation, etc.
• Contact details, such as your e-mail address, phone number, postal address, Skype / Viber / WhatsApp ID, LinkedIn profile, etc.
• Information regarding our contractual relationship, including details about received instructions, performance, accounting and payment data
• Know-your-client identification data
• Personal data provided by or on behalf of our clients in relation to a legal assignment (which may include “sensitive” or “special” categories of personal data)
• Information collected in the course of your usage of our website
• Any other information that you have provided to us
We collect and otherwise process your personal data for different purposes and in different manners, primarily in relation to the provision of our professional services. In particular, we use personal data:
a) To provide the legal services requested from us
b) To maintain a contractual relationship with you and our clients
c) To communicate with you and to provide information requested by you
d) To fulfil our legal obligations
e) For the establishment, exercise or defence of legal claims
f) To send you legal news, publications, and event invitations
g) For recruitment or internship purposes
h) To provide and improve our website, and to monitor its use
We process personal data in the course of and in relation to the legal services contractual relationships with our clients. We process information on our clients and their representatives in compliance with our “know-your-customer”, accounting, tax and other legal obligations. We also process personal data provided to us by or on behalf of our clients in performance of our legal assignments.
If you have provided your consent, we may send you non-business communications such as legal news, publications, and event invitations. We will only process personal data that you have provided to us in the course of our work together or by following a link for subscription to our mailing list. You can always withdraw your consent by clicking the unsubscribe link in any non-business communication from us or by writing to email@example.com.
Cookies and usage of our website
Cookies are small text files that are placed on your device when you visit a website. Cookies are widely used by website owners in order to make them work, or to work more efficiently, as well as to provide reporting information.
You may refuse to accept cookies or withdraw your consent at any time by selecting the appropriate privacy settings on your internet browser. As the ways in which you can do this vary from browser to browser, please visit your browser’s help menu for further details. Please note that if you choose to reject cookies, doing so may impair some of our website functionality. For more information on cookies, including how to manage and delete them, please visit www.allaboutcookies.org
By using our Website without changing your browser privacy settings, you consent to the usage of cookies by us in the manner described above.
We use your personal data on the following legal grounds:
a) To enter into and perform a contract, such as a legal services agreement
b) To comply with our legal obligations
c) Consent, for example to send you non-business communications
d) Our legitimate interests, such as to carry our business activities, provide our legal services, as well as for the establishment, exercise or defence of legal claims or proceedings
V. Who do we share your personal data with?
We may disclose your personal data to personal data processors acting on our behalf and assisting us with achieving the purposes of processing outlined above, such as providers of certain services (e.g. IT firms or translation agencies, etc.). These entities will be under contractual obligation for protection of your personal data.
We do not intend to disclose your personal data outside the European Union or the European Economic Area.
We may otherwise disclose your personal data to third parties only if we are under a duty to do so in order to comply with a legal obligation.
In the context of provision of our professional services we may also disclose relevant personal data to courts or arbitration panels or relevant governmental authorities when necessary or recommendable in our professional judgement for protection of your interests.
We comply with the principle that the period for which the personal data are stored is limited to a strict minimum and personal data are not kept longer than necessary for achieving the purposes of processing. We will keep your personal data for the duration of the respective legal services agreement, and for an additional period according to our internal rules and our legal obligations as attorneys on data retention.
We may continue to process your personal data for direct marketing purposes and send you non-business communications until you withdraw your consent.
You have the following rights in accordance with the GDPR:
a) Access to personal data
You have the right to obtain confirmation from us as to whether or not your personal data are being processed and if so, to access the data and information on our processing activities. The right to obtain a copy of your personal data, however, shall not adversely affect the rights and freedoms of others.
b) Right to rectification
You have the right to obtain from us the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.
c) Right to erasure (”right to be forgotten”)
You have the right to obtain from us the erasure of your personal data and we have the obligation to erase your personal data without undue delay where certain legal grounds apply (e.g. when the personal data are no longer necessary in relation to the purposes for which they were collected).
There could be cases, in which your right to erasure could not be exercised and the processing will be necessary:
• for exercising the right of freedom of expression and information;
• for compliance with a legal obligation, which requires processing by European Union or Bulgarian law to which we are subject, or for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us;
• for the establishment, exercise or defence of legal claims.
d) Right to restriction of processing
You have the right to obtain from us restriction of processing where one of the following applies:
• you contest the accuracy of your personal data for a period enabling us to verify the accuracy of your personal data;
• the processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead;
• we no longer need your personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
• you have objected to processing pending the verification whether our legitimate grounds override yours.
e) Right to data portability
You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another controller without our hindrance insofar the processing is carried out by automated means and is based on your consent or on a contract.
f) Right to object
You have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data. We will no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
g) Right to withdraw your consent
You can always withdraw your consent related to direct marketing by clicking the unsubscribe link in any non-business communication from us or by writing to firstname.lastname@example.org. The withdrawal of your consent will not affect the lawfulness of processing based on consent before such withdrawal.
h) Right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority if you consider that we have infringed the GDPR in processing your personal data (for Bulgaria the supervisory authority is the Commission on Personal Data Protection – www.cpdp.bg).
We will act on your requests in relation to your abovementioned rights free of charge. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, then we may either charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request.
In order to exercise your rights in relation to the processing of your personal data, or if you have any comments, questions and requests related to the processing of your personal data, please contact us at email@example.com or 82, Patriarch Evtimii Blvd., 1463 Sofia, Bulgaria.
We will provide information on the action taken based on your requests within 30 days of receipt of your written request. That period may be extended by two months where necessary, taking into account the complexity and number of the requests. In this case, you will be informed of any such extension within one month of receipt of your request, together with the reasons for the delay.
IX. How do we protect your personal data?
We will take all steps reasonably necessary to ensure that your personal data are treated securely and in accordance with the GDPR.
We have implemented sufficient technical and organizational measures to ensure that your personal data will be safe from accidental or unlawful or unauthorised destruction, loss, alteration, disclosure or access.
Last updated: 9 May 2018.