Security policy

Mandatory information on the individual rights for personal data protection (Privacy notice)

General information

From May 25, 2018. a new General Data Protection Regulation adopted by the European Union is in force. The regulation aims to ensure the protection of personal data of individuals from all EU Member States and to harmonize the regulations for their processing.

As an administrator of personal data for the provision of printing services, Partners Consulting Ltd. meets all the requirements of the new regulation, collecting only personal data to the extent necessary for the provision of the service, and keeps them responsibly and legally.

What is personal data?

Personal data within the meaning of Article 2, paragraph 1 of the Personal Data Protection Act are any information relating to a natural person who is identified or can be identified directly or indirectly by an identification number or by one or more specific features .

Several examples of personal data are: names, PIN, address, telephone, place of birth, passport data of the person (physical identity); marital status and kinship (family identity); professional biography (employment); health status, psychological and / or mental condition, sexual orientation (medical data); racial or ethnic origin, political, religious or philosophical beliefs (public identity); property status, financial condition, participation and / or possession of shares or securities of companies (economic identity), etc.

We collect personal data only for the provision of products and services that you have requested and that you use with us, as well as to fulfill contractual and pre-contractual obligations, and also to offer the highest quality comprehensive service on the market.

Information about the Personal Data Administrator

Name "Partners Consulting" Ltd. UIC / BULSTAT: 204838177 Headquarters and address of management: Varna, p.k. 9000, 26 Stara Planina Str. Address for exercising the activity: Varna, p.k. 9000, 53A G.S. Rakovski Str. Correspondence data:: Varna, p.k. 9000, 26 Stara Planina Str. E-mail: info@partnersconsulting.bg Tel: +359 888 706 908; +359 894 601 383

Information on the competent supervisory authority

Name: Commission for Personal Data Protection Headquarters and address of management: Sofia 1592, Blvd. "Prof. Tsvetan Lazarov ”№ 2 Correspondence data: Sofia 1592, Prof. Tsvetan Lazarov ”№ 2 Phone: 02 915 3 518 Email: kzld@government.bg, kzld@cpdp.bg Website: www.cpdp.bg

Partners Consulting Ltd. 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 individuals with regard to the processing of personal data and on the free movement of such data.

Grounds for collecting, processing and storing your personal data

Art. 1. (1) Partners Consulting Ltd. collects and processes your personal data in connection with the provision of printing services and concluding contracts with the company on the grounds of 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 Partners Consulting Ltd. under a contract with you;

● To take steps on your request for concluding a contract, if you are a candidate for a job with us;

○ To fulfill a contract or take steps to conclude one with a trading partner.

● Compliance with a legal obligation that applies to Partners Consulting Ltd .;

● For the purposes of the legitimate interest of Partners Consulting Ltd.

(2) Partners Consulting Ltd. is an administrator of personal data regarding your data as user of our services. Regarding the personal data that you process as user of our services, Partners Consulting Ltd. acts as a processor of personal data.

Goals and principles in the collection, processing and storage of your personal data

Art. 2. (1) Partners Consulting Ltd. collects and processes personal data that you provide to us in connection with the use of our printing services and to enter into a contract with the company, as well as to register for participation in our events, or by applying for a job in Partners Consulting Ltd., including for the following purposes:

● Sending an inquiry;

● individualization of a party to the contract;

● registration of a participant in an event organized by Partners Consulting OOD;

● accounting purposes;

● statistical purposes;

● protection of information security;

● ensuring the implementation of the contract for the provision of the respective service;

● sending information messages, messages about changes in the service, etc .;

● improving and individualizing the service by proposing suitable for you offers for products, events and other services that may be of interest to you;

● providing customer service through our call center;

● individualization of the candidate;

● making contact with the candidate and conducting communication;

● selection of candidates.

(2) When concluding a contract with a commercial partner, we collect and process personal data for the names of the legal representative of the legal entity - party to the contract, for the purposes of individualization of the party to the contract and its implementation.

(3) The contact details of the legal representative or of a contact employee are official information and as such shall not be considered as personal data.

(4) Upon concluding a contract with a partner - natural person, we collect and process personal data for the three names, unified civil number and data on identity document (number, date of issue, issuer), for the purposes of individualization of the party to the contract. and contract’s implementation.

 (5) Partners Consulting Ltd. observes the following principles in the processing of your personal data:

● legality, good faith and transparency;

● limitation of processing purposes;

● relevance to the purposes of processing and minimizing the collected data;

● accuracy and timeliness of the data;

● limitation of storage time in order to achieve the objectives;

● integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.

(6) In the processing and storage of personal data, Partners Consulting Ltd. may process and store personal data in order to protect its following legitimate interests:

● fulfillment of its obligations to the National Revenue Agency, the Ministry of Interior and other state and municipal bodies.

● Providing information to the Commission for Personal Data Protection in connection with obligations provided for in the legislation on personal data protection - Personal Data Protection Act, Regulation (EU) 2016/679 of 27 April 2016, etc .;

● obligations provided for in the Accounting Act and the Tax and Social Security Procedure Code and other related regulations in connection with the maintenance of proper and lawful accounting;

● provision of information to the court and third parties, within the framework of proceedings before a court, in accordance with the requirements of the procedural and substantive legal acts applicable to the proceedings;

What types of personal data is collected, processed and stored by Partners Consulting Ltd.?

Art. 3. (1) Partners Consulting Ltd. performs the following operations with personal data for the these purposes:

● Sending an inquiry by a user through the website and fulfilling a contract for the provision of printing and other services - the purpose of this operation is to submit an inquiry to be processed by us and accordingly prepared and sent back a specific offer to the client.

● Conclusion and execution of a trade transaction with a client or partner - the purpose of this operation is the conclusion and execution of a contract with a trade partner or client and its administration;

● 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, according to the contract for the provision of the service.

● 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 such;

● Concluding and executing an employment or civil contract: For the selection of job candidates, we process personal data that have been sent to us in the form of a CV and cover letter or other documents certifying education and qualifications.

● Concluding and executing a commercial transaction: For concluding and executing a commercial transaction with a commercial company, we process only the three names of the legal representative or the person authorized by the company, as well as for the natural person-partner under contract.

 (2) Partners Consulting Ltd. processes the following categories of personal data and information for the following purposes and on the following grounds:

● Data: Your personal data (name and surname, e-mail, country, telephone, address, and in some cases a unique civil number or personal number of a foreigner)

○ Purpose for which the data is collected:

1) Sending a request by a user;

2) Making contact with the user and sending information to him, including if desired - to send newsletters and advertising messages;

○ Grounds for processing your personal data - By accepting the general conditions and purchasing a service, a contractual relationship is created between Partners Consulting Ltd. and you, on which basis we process your personal data - Art. 6, para. 1, p. (b) GDPR.

● Other data processed by Partners Consulting Ltd. - When logging in to our website or in your account, Partners Consulting Ltd. collects data about the IP address used.

○ Bank account information or other banking and payment information in connection with payments made to Devnox;

○ Client number, code or other identifier created by Partners Consulting Ltd. for client identification;

○ Other feedback we receive from you.

○ 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 under a contract to which the data subject is a party - Art. 6, para. 1, p. (b) of the GDPR. Until the creation of a user profile, the IP address is collected on the basis of the legitimate interests of the administrator - Art. 6, para. 1, p. (f) the GDPR;

● Your individual invoice details - If you want to be issued an invoice as a natural person, you must 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 of the website, or by concluding a written contract, a contractual relationship is created between Partners Consulting Ltd. and you, on which basis we process your personal data - Art. 6, para. 1, p. (b) GDPR.

(3) Partners Consulting Ltd. does not collect or process personal data that relate to the following:

● reveal racial or ethnic origin;

● disclose political, religious or philosophical beliefs, or trade union membership;

● genetic and biometric data, health data or data on sexual life or sexual orientation.

(4) The personal data is collected by Partners Consulting Ltd. from the persons to whom they refer.

(5) The company does not perform automated decision making with data.

Term of storage of your personal data

Art. 4. (1) Partners Consulting Ltd. terminates the use of your personal data for purposes related to the contractual relationship, after termination of the contract or after its expiration, but we do not delete them before the expiration of one year from termination of the contract or expiration of its term or until the final settlement of all financial obligations and expiration of the statutory obligations for data storage, such as obligations under the Electronic Communications Act for storage and provision of information for the purposes of detection and investigation of crimes, obligations (6 months) under the Act for accounting for storage and processing of accounting data (11 years), expiration of the statute of limitations set in the Law on Obligations and Contracts (5 years), obligations to provide information to the court, competent state authorities and other grounds provided for in the current legislation (5 years).

(2) Partners Consulting Ltd. stores your personal data as a job applicant for a period not longer than the presence of an up-to-date job advertisement, published on our website or elsewhere. After the expiration of the announcement or completion of the selection, Partners Consulting Ltd. takes the necessary care to delete and destroy all your data without undue delay or to anonymize them (ie to bring them in a form that does not reveal your identity), unless you give your explicit consent for your data to continue to be stored and processed in the future.

(3) Partners Consulting Ltd. stores the personal data of the legal representatives of the legal entities - parties to the contract or natural persons-partners under the contract indefinitely, for the purposes of protecting the legitimate interest of Partners Consulting Ltd. and fulfillment of its legal obligations to state authorities and institutions.

Transfer your personal data for processing

Art. 5. (1) Partners Consulting Ltd. may at its own 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.

(2) Partners Consulting Ltd. notifies you in case of intention to transfer part or all of your personal data to third countries or international organizations.

Your rights in the collection, processing and storage of your personal data

Withdrawal of consent for the processing of your personal data

Art. 6. (1) If you do not want all or part of your personal data to continue to be processed by Partners Consulting Ltd. for specific or all purposes of processing, you can at any time withdraw your consent to processing by contacting us through request in a free written form.

(2) Partners Consulting Ltd. may ask you to verify your identity and identity with the person to whom the data relates.

Right of access

Art. 7. (1) You have the right to request and receive from Partners Consulting Ltd. confirmation whether personal data related to you are processed.

(2) You have the right to access the data related to it, as well as the information related to the collection, processing and storage of your personal data.

(3) Partners Consulting Ltd. provides you, upon request, a copy of the processed personal data related to you, in electronic or other appropriate form.

(4) The provision of access to the data is free of charge, but Partners Consulting Ltd. reserves the right to impose an administrative fee in case of recurrence or excessiveness of the requests.

Right of correction or completion

Art. 8. You can correct or fill in the inaccurate or incomplete personal data related to you directly through your profile on the website or by making a request to Partners Consulting Ltd.

Right to be deleted ("to be forgotten")

Art. 9. (1) You have the right to request from Partners Consulting Ltd. deletion of personal data related to you, and Partners Consulting Ltd. has the obligation to delete them without undue delay, when there is any of the following reasons:

● 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 related to you, including for direct marketing purposes, and there are no legal grounds for processing to take precedence;

● personal data have 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 that applies to Partners Consulting Ltd.;

● personal data have been collected in connection with the provision of services to the information society.

(2) Partners Consulting Ltd. 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 a Member State applicable to the Administrator or for the performance of a task in public interest or in the exercise of official powers conferred on him;

● for reasons of public interest in the field of public health;

● for archiving purposes in public interest, for scientific or historical research or for statistical purposes;

● for the establishment, exercise or defense of legal claims.

(3) In order to exercise your right “to be forgotten", you should submit a written request sent to Partners Consulting Ltd., as well as to verify your identity and identity with the person to whom the data relates before Partners Consulting Ltd., by presenting on-site your ID card for identification purposes. (4) Partners Consulting Ltd. does not delete the data that it has a legal obligation to store, including for protection on the occasion of court claims against it or proof of their rights.

Right of restriction

Art. 10. You have the right to request from Partners Consulting Ltd. to limit the processing of data related to you when:

● you dispute the accuracy of personal data for a period that allows Partners Consulting Ltd. to verify the accuracy of the personal data;

● the processing is illegal, but you do not want your personal data to be deleted, but just their use to be restricted;

● Partners Consulting Ltd. no longer needs the personal data for the purposes of processing, but you require them for the establishment, exercise or protection of your legal claims;

● You have objected to the processing pending verification of whether the legal grounds of Partners Consulting Ltd. take precedence over your interests.

Right of portability

Art. 11. (1) You can at any time download the data that is stored and processed for you in connection with the use of the services of Partners Consulting Ltd., with a request by email.

(2) You may request from Partners Consulting Ltd. to directly transfer your personal data to an administrator specified by you, when this is technically feasible.

Right to receive information

Art. 12. You may request from Partners Consulting Ltd. to inform you about all recipients to whom the personal data for which correction, deletion or restriction of processing has been requested have been disclosed. Partners Consulting Ltd. may refuse to provide this information if this would be impossible or would require a disproportionate effort.

Right to object

Art. 13. You can object at any time to the processing of personal data by Partners Consulting Ltd., which relates to you, including if they are processed for the purposes of profiling or direct marketing.

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

Art. 14. (1) If Partners Consulting Ltd. finds a violation 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 violation and the measures taken or to be taken.

(2) Partners Consulting Ltd. is not obliged to notify you if:

● has taken appropriate technical and organizational protection measures with regard to data affected by the security breach;

● has subsequently taken measures to ensure that the breach does not pose a high risk to your rights;

● notification would require a disproportionate effort.

Persons to whom your personal data is provided

Art. 15. (1) Data processors on behalf of Partners Consulting Ltd.:

● companies collecting and / or securing receivables - receivables collection agencies, credit agencies, which through suretyship or other means for servicing and collection of receivables;

● Postal operators and companies for courier services, in view of sending items and the need to verify identity when delivering them;

● Agents of Partners Consulting Ltd., who act as representatives of the company in the sale of services and products;

● persons who by assignment maintain equipment, software and hardware used for personal data processing and necessary for the normal functioning of the company's business and for performing various reporting services, payment for services and products, technical support, etc .;

● bodies, institutions and persons to whom we are obliged to provide personal data under current legislation;

● banks to service the payments made by you;

(2) Persons processing the data on their own behalf

● assignees - a party to assignment agreements by which Mtel transfers (sells) your outstanding liabilities;

● Competent authorities, which by virtue of a normative act have the authority to require the provision of information, including personal data, such as courts, prosecutors, various regulatory bodies such as the Consumer Protection Commission, the Communications Regulation Commission, the Commission on Protection of personal data, bodies with powers to protect national security and public order;

Art. 16. The administrator does not transfer your data to third countries.

Other provisions

Art. 17. 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:

Name: Commission for Personal Data Protection; Headquarters and address of management: Sofia 1592, Blvd. "Prof. Tsvetan Lazarov ”№ 2; Correspondence data: Sofia 1592, Prof. Tsvetan Lazarov ”№ 2 Phone: 02 915 3 518; Email: kzld@government.bg, kzld@cpdp.bg Website: www.cpdp.bg

Art. 18. You can exercise all your rights regarding the protection of your personal data through the forms attached to this information. Of course, these forms are optional and you can submit your requests in any form that contains a statement to that and identifies you as the data holder.

Art. 19. If the consent relates to a transfer, the Administrator 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.

Art. 20 (1). When you assign Partners Consulting Ltd. to process personal data of a third party for the purposes of using the service, Partners Consulting Ltd. acts as a processor of personal data.

(2). In the cases under par. 1, Partners Consulting Ltd. acts only on your instructions as a user of the service and only to the extent that there can be control over the personal data that you process. Partners Consulting Ltd. has no control over the content and data that you as a user of the service choose to upload to the service (including if this data includes or does not include personal data). In this case, Partners Consulting Ltd. has no role in the process of deciding whether the user uses the service for processing personal data, for what purposes and whether they are protected. Accordingly, the liability of Partners Consulting Ltd. in this case is limited to 1) compliance with the instructions of the user of the service under the contract and the general conditions and 2) the provision of information about the service.

Cookie Policy

The website of Partners Cosnulting Ltd. uses cookies, which are important for its correct operation. By visiting our site, you accept the use of cookies.

Grounds for collecting, processing and storing your personal data

Types of cookies we use:

● Mandatory cookies

These cookies are necessary for the proper operation of the website. For example, with these cookies we show you the information on our site in the correct language.

● Analytical cookies

Thanks to these cookies, we monitor the traffic to our site and we can analyze how easily our users work with it (Google Analytics cookies). These cookies do not give us any information about your personal data. They show us which pages of our site you have viewed, whether you have visited our site via a mobile or desktop device and other anonymous data. For Google Analytics, we also use IP anonymization using _anonymizelp. The maximum period in which we store analytical data in Google Analytics is 50 months.

● Functional cookies

These cookies allow you to use the full functionality of our site, watch videos on it and more.

● Precise targeting cookies

These cookies contain information about how you used our site and can be triggered by our advertising partners. They do not store personal information. Thanks to them, you will not be shown information that is irrelevant to you. These are dynamic cookies on Facebook, Google, Adform, Adwise and others.

You can make the settings of cookies that you receive from our site in the browser you use. Keep in mind, that if you restrict certain types of cookies, our site may not work completely correctly and you may not be able to use its full functionality.

What security measures have we taken at Partners Consulting Ltd. regarding the security of the personal data you store on our infrastructure?

The security of any type of information, including personal data, located on our infrastructure is a priority for us as a company. Security is something we cannot compromise on.

In addition to making every effort to fully comply with the new privacy policy, our website and email server structure are protected by our hosting and internet providers. For maximum security in the processing, transmission and storage of your data, we can use additional protection mechanisms such as encryption, pseudonymization, logging of data processing activities in automated processing systems and more. Partners Consulting Ltd. regularly conducts trainings for its employees on personal data protection measures.

In order to implement the most up-to-date protection measures and in order to comply with the current legislation, we will regularly update this Privacy Policy. If the changes we make are significant, we may post a notice of the changes on our website. We invite you to regularly review the current version of this Privacy Policy, to be constantly informed about how we take care of the protection of personal data that we collect.

This Privacy Policy was last updated on 23.05.2018.