Privacy Statement according to Article 13 and 14 GDP

Thank you for your interest and visiting our website http://www.kwrbg.eu. We may inform you about our areas of expertise and invite you to learn more about our law firm and our team.
This Privacy Statement 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“) and the Bulgarian Data Protection Act (Закон за защита на личните данни, “ZZLD”).
Thus, we may inform you by this privacy statement about the most important aspects of the processing of data regarding visits of our website, our marketing activities, our consultancy activities, as well as our events. If you have any questions regarding the use of your data, please contact us at office@kwrbg.eu.

I. Controller
Belokonski Gospodinov and Partners, Partnership of Lawyers, registered in the register of the partnerships of lawyers with Sofia City Court under file number 719/2008 of Sofia City Court files, company identification number (EIK) 175579573, with seat in Sofia-1113, Bulgaria and registered address at Alexander Zendov str. 1, 6th floor, Nr. 38, Email: office@kwrbg.eu
(hereinafter “we”, ”us“ or “KWRBG”)

II. General information
Personal data is all data that contain information about personal or factual circumstances, for example name, address, e-mail address, telephone number, etc. but also information with indirect personal reference such as your IP address.
We process your personal data for marketing purposes, regarding our event management and the distribution of our newsletter, in order to be able to provide you with invitations to our events and information as well as legal services and consulting. Further, we collect personal data from you when we enter into a legal services agreement, as a result of your legal relationship with us, when you contact with our staff or clients, or otherwise in the course of our business activities.

III. Processing activities
We may inform you in detail about the scope and purpose of the data processing and about the transfer of your data to third parties.

1. Accessing our website
We may point out that we do not use cookies, plug-ins or other consumer trackers on our website http://www.kwrbg.eu. We do not collect your personal data when you access our website.
Your data, in particular data from the server log files, is transmitted to our hosting provider. “SuperHosting.BG” EOOD. For the operation of our website including hosting, to ensure the security of our IT systems we engage the following service provider who might have access to your personal data in the course of its activities:
Name: “SuperHosting.BG” EOOD
UIC/BULSTAT:131449987
Seat and registered address: Sofia 1797, district Izgrev, Blvd. “Dr. G. М. Dimitrov” Nr. 36
E-mail: dpo@superhosting.bg
Phone: 0700 45 800, 02 81 08 999
This may involve the transfer of your data to third countries, where the data protection standards established in Europe do not apply and therefore the security and protection of your data might not be guaranteed all the time.
Please mind that we have no control over the scope and content of the data that is transmitted to SuperHosting.BG after visiting our website or over any cookies that are set by SuperHosting.BG. Cookies are small text files that are transmitted by SuperHosting.BG via your browser to your terminal or mobile device and are set there. The information collected by these cookies is retrieved during subsequent visits to SuperHosting.BG that allows to recognize your terminal or mobile device. The information stored in the cookies is received, recorded and processed by SuperHosting.BG with direct personal reference.
For further information on the type, extent and purpose of the data collected, we may refer you to the privacy statements of SuperHosting.BG. These can be accessed by visiting
https://www.superhosting.bg/web-hosting-page-terms-and-agreements.php#personal_data

2. Google Maps
We offer you the possibility to calculate and display your individual route to our location with Google Maps. By clicking on the “directions” link, you will be redirected to Google Maps. By clicking on this link, a connection is activated and a connection to the servers of Google is established without any further action. Your data, in particular data from the server log files, is transmitted to Google. This may involve the transfer of your data to third countries, where the data protection standards established in Europe do not apply and therefore the security and protection of your data might not be guaranteed all the time.
Please mind that we have no control over the scope and content of the data that is transmitted to Google after clicking on the link or over any cookies that are set by Google. Cookies are small text files that are transmitted by Google via your browser to your terminal or mobile device and are set there. The information collected by these cookies is retrieved during subsequent visits to Google Maps that allows to recognize your terminal or mobile device. The information stored in the cookies is received, recorded and processed by Google with direct personal reference.
If you do not wish your data to be transferred, please avoid clicking on the link.
For further information on the type, extent and purpose of the data collected, we may refer you to the privacy statements of Google Maps. These can be accessed by visiting https://policies.google.com/privacy?hl=de.

3. Collected personal data in our marketing and professional activity
In the context of provision of our professional services or otherwise in the course of our marketing or 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 contained in your CV, motivational letter and other documents you have provided in the course of your application to work for us;
• Any other information that you have provided to us.
When we request personal data directly from you (e.g. for the purposes of client identification), we kindly ask you to provide us with all categories of requested personal data, as otherwise we would be unable to carry out the processing activities outlined in this Privacy Statement (including, we may be unable to provide you with our legal services).
If you provide us with personal data of other natural persons, we kindly ask you to provide them, prior to such disclosure, with information about the key terms and conditions under which we shall process their personal data in accordance with this Privacy Statement.

4. Usage of the collected personal data
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 answer your questions;
d) To fulfil our legal obligations;
e) For the establishment, exercise or defence of legal claims;
f) For non-business communication of general nature;
g) For direct marketing purposes;
h) For recruitment purposes;

Legal services
We process personal data in the course of and in relation to the legal services contractual relationships with our clients. We also process personal data provided to us by or on behalf of our clients in performance of our legal assignments.

Contractual relationships
We process personal data in relation to the negotiation, entry into, performance and termination of contractual relationships. This may include personal data of our clients and other counterparties such as service providers, their representatives and employees, to the extent relevant.

Answering your questions
When you ask us a question, we would process your personal data in order to be able to answer it. The extent of personal data processing would depend on your request.

Legal obligations
We process information on our clients, counterparties, affiliated entities and their respective representatives and ultimate beneficial owners in compliance with our “know-your-client”, accounting, tax and other legal obligations. In our capacity as law firm, we also have obligations under the Bulgarian Bar Act.

Legal claims
Personal data collected for other purposes, which do not constitute special categories of personal data, will be also processed for our protection against any legal claims by you or by third parties, as well as to establish and exercise our legitimate rights.

Non-business communication
We may send you non-business communications of general nature. Such messages may include news on the latest developments in the legal world, and other expert resources: articles, webinars, discussions, and interviews. You can always unsubscribe from such communication by following the instructions contained therein or by contacting office@kwrbg.eu.

Direct marketing
If you have provided your consent, we may send direct marketing messages in which we offer our services without a specific request for proposal. 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 marketing communication from us or by contacting office@kwrbg.eu.

Recruitment
When you apply for a job with us, you need to provide us with certain information about you so that we can assess whether you meet the requirements for the position and whether you are the most suitable candidate for it.

5. Legal basis for personal data usage
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 direct marketing;
d) Our legitimate interests, such as:
· to carry out our business activities;
· to provide our legal services;
· to communicate with you, for example when you ask us a question, or when we send you non-business communications of general nature;
· for the establishment, exercise or defence of legal claims or proceedings;
· to select the most suitable job applicant in the context of recruitment.

6. Disclosure of personal data
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 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.

7. Storage period
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 until you withdraw your consent. Similarly, we may continue sending you non-business communications of general nature until you choose to object or unsubscribe.

8. Rights of the personal data subject
As data subject of our data processing, you have the following rights. For the enforcement of your rights – with the exception of the right to complain – contact us to office@kwrbg.eu.

a) Right of access
You have the right to request information at any time and in any form about the data related to you that is processed by us as controller – together with further information such as the purpose of processing and the recipients, information about the origin of the data and information about automated decision-making including the logic involved. Furthermore, you have the right to request information on whether your personal data is transferred to a third country or to an international organization, including the right to be informed about the appropriate safeguards in accordance with Article 46 GDPR. 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 and right to restriction of processing
You may request that inaccurate or incomplete data is rectified or completed. You also have the right to request a restriction on the processing of data that may only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest, for example if the accuracy of the data is disputed.

c) Right to data portability
You may request that a copy of the data, if it has been made available to KWRBG, is sent to you or, if this is technically feasible, to a third party that can be determined, in a structured, common and machine-readable format.

d) Right to erasure
You may request the erasure of your personal data in certain circumstances, for example if it is not processed in accordance with the data protection provisions.

e) Right to object
You have the right to object to the processing of your personal data at any time by giving reasons. In this case we will no longer process the personal data relating to you unless we can argue compelling legitimate grounds for the processing which override your interests, or the processing serves the purpose of enforcing, exercising or defending of legal claims.
You can always unsubscribe from receiving non-business communication of general nature by following the instructions contained in the respective e-mail or by contacting office@kwrbg.eu.

f) Right to withdraw your declaration of consent
You have the right to withdraw your consent under data protection law at any time and without giving reasons by sending an e-mail to office@kwrbg.eu. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the withdrawal. We will delete your data unless legal provisions require us to store it.

g) Right to complain
If you are of the opinion that the processing of your data violates your right to confidentiality or your data protection rights have been violated in any other way, you can file a complaint to the competent supervisory authority. In Bulgaria the supervisory authority is the Commission on Personal Data Protection – www.cpdp.bg.
The English and German translations of this privacy statement is provided for your convenience only. Thus, the Bulgarian version of this privacy statement shall prevail and be exclusively effective.
(As of November 2021)

How to reach us
Belokonski Gospodinov and Partners, Sofia 1113, Alexander Zendov str. 1, 6th floor, office Nr. 38, e-mail: office@kwrbg.eu