PRIVACY POLICY OF PETYA NOYCHEVA & PARTNERS LAW OFFICE

PRIVACY POLICY OF PETYA NOYCHEVA & PARTNERS LAW OFFICE

I. WHO WE ARE
Petya Noycheva & Partners Law Office /”we”, “us”/, BULSTAT 175202718, registered address: 15, Doyran Str., Entr. B, 4th floor, office 9, Sofia, is a Controller according to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on 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 /GDPR/).
As a Controller we commit ourselves to process and protect your personal data as a natural person subject to the GDPR requirements and this Privacy Policy. Please read it carefully and become familiar with your rights.

II. DATA PROVISION
You provide us with your data:
1. when you visit our website
When you visit our website, by means of cookies, some data of the device you use are sent automatically to the server of our website, e.g. your IP address (“IP address”), browser type and language you use and the date and time of visiting our website, which helps us improve the operation and efficiency of our website without allowing us to identify you directly or to draw some other conclusions about you and your identity.
2. when you contact us
When you contact us by e-mail or the contact form on our website, we use your provided e-mail, and any other information that you have decided to provide freely in your inquiry, only to reply to your inquiry.
3. when you subscribe for our newsletter
When you subscribe for our newsletter, you agree freely that we will use your e-mail only and solely to send you our newsletter of current news and articles on legal issues.
4. for the purpose of providing services on our part
When you enter into contractual relationships with us, you provide us freely with your data in order to be able to render our legal services to you and to fulfill the legal requirements imposed to us as an obligation, such as identification of our clients.

III. WHAT PERSONAL DATA ABOUT YOU WE PROCESS
To be able to render our professional services to you, and for fulfillment of our legal obligations, while contacting you we may collect and process the following categories of personal data about you:
1. personal information about you such as your name, personal ID number (or other personal identification number), marital status, educational degree, occupation, professional experience, etc.
2. your contact details such as address, e-mail, phone number, LinkedIn profile, etc.
3. other data about your individualization and identification for the purpose of fulfillment of our legal obligations, without which we would not be able to enter into contractual relationships with you and to render our services to you.
4. information collected during the use of our website, such as your IP address, browser type and language you use, and the date and time of visiting our website, etc.
5. any other information that you have provided us with freely in and by reason of rendering our legal services to you.

IV. WHAT ARE OUR GROUNDS TO PROCESS YOUR PERSONAL DATA
We process your personal data on any of the following legal grounds:
1. On the basis of your consent, including sending you our newsletter /Art. 6(1), letter a) GDPR/.
2. For the performance of a contract we have concluded with you, or to take steps at your request prior to signing a contract with you /Art. 6(1), letter b) GDPR/.
3. For compliance with our legal obligations /Art. 6(1), letter c) GDPR/.
4. When processing is necessary for protection of our legitimate interests and exercise or defense of legal claims, including for the purpose of preparation, exercise and defense in administrative and court actions and proceedings, and in enforcement proceedings, and when there is no reason to accept that our legitimate interests are overridden by the right your personal data not to be provided and disclosed to third parties /Art. 6, paragraph 1, letter f) GDPR/.

V. WHAT ARE THE PURPOSES FOR WHICH WE USE THE INFORMATION PROVIDED BY YOU
We collect, process and use the information provided by you:
1. To be able to render our legal services to you for which you have engaged us, including to communicate with you and to keep you update on the progress of your order. If you refuse to provide us with the information necessary for the performance of your order, we will not be able to render our services to you.
2. To comply with our legal obligations, including accounting, tax, in the area of employment and social law, and for the purposes of individualization and identification of our clients and other legal obligations we are imposed by law.
3. To protect our legitimate interests, including for the purpose of preparation, exercise and defense in administrative and court actions and proceedings, and in enforcement proceedings, and when there is no reason to accept that our legitimate interests are overridden by the right your personal data not to be provided and disclosed to third parties.
4. To send you our newsletter on the basis of your consent. You may withdraw your consent at any time by clicking on the link to unsubscribe at the bottom of each e-mail that you receive from us or by contacting us at newsletter@pnp.bg.
5. To maintain and improve our website and to optimize its use so as to make it suitable and useful for you.
In this reference please be informed that our website uses „cookies”.
Cookies are small text files, in most cases letters and numbers, which are placed and stored on the browser or the hard disc of your device when you visit a given website, including ours.
As we informed you in section II, 1. above, we use our cookies in order our website to be able to operate more efficiently and to be more convenient and useful for you, including to ensure its security and protection against harmful attacks.
The cookies placed by us on your device do not allow us to identify you directly or to draw other conclusions about you and your identity and they do not cause any harm to your device, in particular, they do not contain any viruses, Trojan horses or other malware.
Cookies of Third Parties:
Our website allows third parties, analyzing the traffic or providing contents to our website, to place on your device their own cookies and to have access to them.
To make it as easy as possible, our website uses the service “Google Maps/Google Earth” in order to display our location on the map embedded in our website and to help you easily find us, including if you need some instructions how to get to us as quickly as possible. For this purpose, Google Maps/Google Earth places its own cookies on your device to collect and process our data while using the map embedded in our website and its related functions as a scheme for route planning.
Please note that the cookies placed by Google Maps/Google Earth will not be deleted when you close the browser, but after a given period of time. You can read more about the cookies used by Google Maps/Google Earth in the Terms of Use of Google Maps/Google Earth .
You may avoid the use of Google Maps/Google Earth by disabling JavaScript in your browser before opening our website. Besides, you may set your browser to block cookies as we have explained hereinafter.
Our website also uses the service Google Analytics to assess the traffic to our website and its use, and in this reference please be informed that Google Analytics does not provide your identifying information, including access to IP addresses. Google Analytics provides information in anonymous form to Google that uses it to assess the ways of using our website and to report us about the actions carried out on our website subject to the terms of use of Google Analytics.
You can learn more about the use of cookies by Google Analytics here, and here, respectively, about the use of cookies by Google.
You may avoid the use of cookies by Google Analytics by downloading and installation of the application Google Analytics Opt-out Browser Add-on. This application connects with Google Analytics JavaScript setting out that the information about the visit on the website should not be sent to Google Analytics.
We insist on emphasizing the fact that the use of cookies by third parties is subject to their own privacy policies and we do not have access to the information stored by these third parties about you.
Although most browsers are set by default to accept cookies automatically, as a conclusion we would like to inform you that you can control, including block and/or delete cookies whenever you like by the settings of your browser.
Most common current browsers – in the menu “preferences/options”, allow you to change their settings with respect to the cookies. Further information about the settings of some of the most used browsers with respect to the cookies is available as follows:
For Chrome – here
For Mozilla Firefox – here
For Internet Explorer – here
For Safari – here
For iOS – here
For Opera – here
For further information about cookies and how to control and delete them please visit this website.
By using our website without changing your browser settings, you agree with the use of cookies from our website.
Please note that if you choose the option to delete or block the cookies, a lot of websites, including ours, will not operate properly or may stop functioning, and therefore, we do not recommend you delete or block the cookies while using our website.

VI. WHO WE PROVIDE YOUR PERSONAL DATA WITH
We may disclose your personal data to our employed external processors to process them by our instructions and on our behalf, in implementation of our activity and our legal obligations to achieve the purposes of processing, such as our employed accountants. Our service providers, incl. IT services, have been carefully selected for the purpose of protection of your data.
Your personal data will not be provided by us to third parties, except:
1. On the basis of your consent /Art. 6(1), letter a) GDPR/.
2. For the performance of a contract we have concluded with you, or to take steps at your request prior to signing a contract with you /Art. 6(1), letter b) GDPR/.
3. For compliance with our legal obligations /Art. 6(1), letter c) GDPR/.
4. When processing is necessary to protect our legitimate interests, including for the purpose of preparation, exercise and defense in administrative and court actions and proceedings, and in enforcement proceedings, and when there is no reason to accept that our legitimate interests are overridden by the right your personal data not to be provided and disclosed to third parties. /Art. 6(1), letter f) GDPR/.
Pursuant to item 2 and for the purpose of providing our services, we may disclose your personal data to tribunals, including arbitration courts, to government and private enforcement agents, prosecutor’s office, government and municipal authorities and other institutions without limitation to this list.
VII. HOW LONG WE PROCESS YOUR PERSONAL DATA
We process and store your personal data only to the extent it is necessary to achieve the purposes for which we have collected them and you have provided us with – to render our services, except in the case where by law we are under the obligation to store them for a longer period and after its expiry we will destroy them.
For the purpose of sending our newsletter, we will use your e-mail until you refuse to receive our newsletter, as explained in section V., item 4 above.

VIII. WHAT ARE YOUR RIGHTS
Subject to the GDPR you have the following rights:
1. Right of access /Art. 15 GDPR/
You have the right to obtain information from us as to whether or not your personal data are being processed, and, where that is the case, to receive information from us about: purposes of processing; categories of personal data concerned, recipients to whom the personal data have been or will be disclosed; the period for which the personal data will be stored, and if not possible, the criteria used to determine that period; existence of the right to request from us rectification or erasure of personal data or restriction of their processing, or to object to such processing; right to lodge a complaint with a supervisory authority; any available information for their source, when personal data are not collected from the data subject; existence of automated decision-making, including profiling, as well as the significance and the envisaged consequences of such processing for the data subject, without this right to affect adversely the rights and freedoms of other parties.
2. Right to Rectification /Art. 16 GDPR/
You have the right to request from us rectification of incorrect personal data.
3. Right to Erasure (“right to be forgotten”) /Art. 17 GDPR/
You have the right to request your personal data to be erased by us, unless their storage is necessary for:
a) exercising of the right to freedom of expression and right to information;
b) compliance with a legal obligation, requiring processing prescribed in the Union or Member State law, which we are subject, or for the fulfillment of a task of public interest or in exercising of official authorities provided to us;
c) for reasons of public interest in the field of public health;
d) for the purposes of keeping records in the public interest; or
e) for the establishment, exercising or defense of legal claims.
4. Right to Restriction of Processing /Art. 18 GDPR/
You have the right to request from us restriction of processing, where any of the following grounds apply:
a) the accuracy of your data is contested by you for a period enabling us to verify their accuracy;
b) the processing is unlawful, but you oppose the erasure of personal data and request restriction of their use instead;
c) we no longer need your personal data, but you require them for the establishment, exercise or defense of legal claims;
d) you have objected to processing pursuant to Article 21(1) GDPR.
5. Right to Data Portability /Art. 20 GDPR/
You shall have the right to receive from us your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller to whom the personal data have been provided by your consent or on the basis of a contract concluded with you and the processing is done automatically.
6. Right to Object /Art. 21 et seq GDPR/
You shall have the right to object to the processing of your personal data which is based on Article 6(1), letter e) or letter f) GDPR, including profiling. We will no longer process your personal data, unless we demonstrate that there are compelling legitimate grounds for such processing overriding your interests, rights and freedoms, or for establishment, exercise or defense of legal claims.
7. Right to Withdraw Your Consent /Art. 7(3) GDPR/
You may withdraw your consent for processing of your data at any time if you contact us at office@pnp.bg or at 15, Doyran Str., Entr. B, 4th floor, office 9, Sofia 1680, Republic of Bulgaria.
Withdrawal of your consent will not affect the lawfulness of processing based on consent given before its withdrawal!
8. Right to Lodge a Complaint with a Supervisory Authority /Art. 77 GDPR/
For Bulgaria the supervisory authority is the Commission for Protection of Personal Data, more information about it is available here.
To exercise your rights, you can contact us at office@pnp.bg or at 15, Doyran Str., Entr. B, 4th floor, office 9, Sofia 1680, Republic of Bulgaria.
We will try to give you information on the basis of your requests within 30 days after receipt of your written inquiry, as we will try to response to your requests for free relating to the above rights, but if your requests are obviously groundless or excessive, especially due to their repeated nature, then we may charge you a reasonable fee to cover the administrative costs for their processing and providing the information to you.

IX. HOW WE PROTECT YOUR PERSONAL DATA
To make sure that your personal data are processed in compliance with GDPR, we have implemented sufficient technical and organizational measures to ensure protection of your personal data against any accidental or illegal destruction and against unauthorized change, disclosure or access.

X. LINKS TO WEBSITES OF THIRD PARTIES
Our website, our newsletters and the information and messages e-mailed to you sometimes may contain links to the websites of third parties. Personal data that you provide by visiting these websites are not subject to this Privacy Policy and the processing of your personal data by these websites is not our responsibility.
If you follow the link to other websites, please be aware that these websites have their own privacy policies which set out how your information is collected and processed while visiting these websites.

XI. MINORS AND UNDERAGE
We do not collect information from persons under 18 years old, except by the consent of their parents or guardians.

XII. AMENDMENTS TO OUR PRIVACY POLICY
Any amendments we make to our Privacy Policy will be posted on our website and thus will be accessible for you.

Last updated: 21/05/2018