This privacy policy has been developed in accordance with the requirements of 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. data (hereinafter "Regulation (EU) 2016/679" or "ORZD").
We understand that your personal data and the protection of the information you share with us is extremely important. That is why our Privacy Policy describes how we process your data and what measures we take to protect it.
This policy applies to you in case you provide us with personal data by phone (by phone or SMS), in online registration form, by mail or by courier, through social networks, on a corporate or promotional website, through a mobile application or other way. Our privacy policy is an expression of our willingness to protect your personal information.
Information about the Personal Data Administrator
Article 1. (1) STUDIO NOMA EOOD (the Company) is a personal data administrator, registered in the Commercial Register at the Registry Agency with UIC: 205831075, with registered office and address of management: Nessebar, district Burgas, municipality Nessebar, 8 Kraybrezhna Str.
(2) This policy aims to clarify and present information and conditions for the exercise of the rights of individuals in connection with the protection of their personal data, which are processed by "STUDIO NOMA" EOOD in connection with the activities of the company.
(3) The policy aims to inform you about the activities for processing your personal data, the purposes for which they are processed, the measures and guarantees for data protection, your rights and the way in which you can exercise them in accordance with the requirements. of the ORD and the relevant applicable legislation of the European Union and the Republic of Bulgaria.
(4) Pursuant to the Personal Data Protection Policy in STUDIO NOMA EOOD and the objectives of the General Regulation on Data Protection and the Personal Data Protection Act (PDPA), the Company processes your personal data in compliance with the following principles:
1. legality, good faith and transparency
2. limitation of objectives
3. minimization of data
4. accuracy
5. storage restriction
6. integrity and confidentiality
Information on the competent supervisory authority
Art.2. 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:
Title: Commission for Personal Data Protection
Headquarters and address of management: Sofia 1592, Blvd. "Prof. Tsvetan Lazarov ”№ 2
Address for correspondence: Sofia 1592, Blvd. "Prof. Tsvetan Lazarov ”№ 2
Telephone: 02 915 3 518
Email: kzld@government.bg, kzld@cpdp.bg
Website: www.cpdp.bg.
Art.3. For the purposes of this policy:
"Personal data" - is any information relating to the customers (individuals and individuals representing legal entities) of "STUDIO NOMA" Ltd., as well as that related to its employees who are identified, or through which they can be identified directly or indirectly by an identification number or by one or more specific features.
"Data subject" means a natural person who can be identified as a result of the processing of his personal data;
"Processing of personal data" - is any action or set of actions that "STUDIO NOMA" Ltd. performs in relation to personal data by automatic or non-automatic means (collection, recording, organizing, storing, adapting or modifying, restoring, consulting, use , disclosure by transmission, distribution, provision, update or combination, blocking, deletion or destruction, etc.)
"Personal data processor" - is a natural or legal person, public authority, agency or other entity that processes personal data on behalf of "STUDIO NOMA" EOOD;
"Recipient" - means a natural or legal person, public authority, agency or other entity to which "STUDIO NOMA" Ltd. discloses personal data, whether a third party or not. Public authorities which may receive personal data in the context of a specific investigation in accordance with Union or Member State law shall not be considered as "recipients"; the processing of such data by those public authorities complies with the applicable data protection rules in accordance with the purposes of the processing;
"Consent of the data subject" - is any freely expressed, specific and informed statement of intent by which the data subject unequivocally agrees to the processing of personal data.
"Violation of the security of personal data" means a breach of security that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to personal data that is transmitted, stored or otherwise processed.
PERSONAL DATA
Art.4. In connection with our activity "STUDIO NOMA" Ltd. we process personal data of the following categories of persons:
Service users.
Visitors to our website.
Recipients of advertising messages.
Art.5. In order to establish and exercise your rights, STUDIO NOMA EOOD processes the following personal data:
1. Data about your identity - your names;
2. Your personal contact details - telephone and e-mail address (permanent address) and another address specified by you;
3. Other information: company, position, business sector, as well as any feedback that you provide to us by mail, phone, email or via messages on social networks;
4. Information about the device or devices you use or have used to access our site (eg make and model of your device, operating system, browser or IP address).
5. Details of the emails and other emails you receive from us, including whether these messages have been opened and whether you have clicked on any of the links in them. We want to make sure that our messages are useful and important to you, so in case you don't open them and click on a link in them, we know we need to improve the information we send you.
6. Information from other sources, such as our partners, specialized companies that provide information about their clients with their consent, in explicit or anonymous form (eg marketing or clinical research companies, financial institutions, social networks, etc.), incl. and information about you that is publicly available.
7. Cookies, as well as other tracking devices
The so-called session (temporary) cookies are used to the extent necessary to ensure the safe and efficient operation of our website and its use. The storage of session cookies on end devices or user application software designed to view information resources (Web browsers) is entirely under the control of the user. The information related to cookies is stored by the server after HTTP sessions in the service logs no longer than the time required to complete the specific purpose being processed, or to the extent provided by law.
8. We use Google Analytics as a monitoring tool (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). Google Analytics uses cookies, which allow us to track the number of visitors to the website, their source and to analyze how often and how the content of the website is used. You can install a opt-out tool that prevents such information from being collected from your visit (https://tools.google.com/dlpage/gaoptout?hl=en)
9. Plug-ins
We use social media to promote the company's activities. Each social media platform has its own privacy policy and processes your personal data.
10. Facebook
When you visit our website, Facebook (Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA) recognizes your account and makes a direct connection between your browser and your Facebook account. In this way, the Facebook platform receives information about your IP address from your visit to our website. For more information, you can find Facebook's privacy policy here: https://www.facebook.com/policy.php Other information that is processed by us and Facebook jointly is that provided to us in connection with our Facebook page. We have access to anonymous statistics about the activities that take place on our Facebook page, and we definitely can not link or identify a specific profile through this data.
Art.6. (1) STUDIO NOMA EOOD does not collect or process personal data, which refer to the following:
reveal racial or ethnic origin
reveal political, religious or philosophical beliefs, or trade union membership
genetic and biometric data, health data or data on sexual life or sexual orientation.
(2) The personal data have been collected by STUDIO NOMA EOOD from the persons to whom they refer.
(3) The company does not perform automated decision making with data.
(4) The company does not process data for persons under 16 years of age, except with the explicit consent of their parents or representatives.
Art.7. Grounds for collecting, processing and storing your personal data
(1) STUDIO NOMA EOOD collects and processes your personal data on the basis of the following:
You have consented to the processing of your personal data for one or more specific purposes
Processing is necessary for the performance of a contract to which you are a party, or for taking steps at your request before concluding a contract between us and you.
Processing is necessary to comply with a legal obligation that applies to us as an administrator
RIGHTS OF INDIVIDUALS
Art.9. (1) As a natural person, whose data STUDIO NOMA EOOD processes, you have the following rights:
1. To receive information about the processed personal data. You have the right to access your personal data that we process for the purposes set out above. If we process this data and receive a request from you (or from a third party authorized by you), we will provide this access free of charge. You also have the right to request a copy of your personal data that we process. Before we provide access to the personal data of you or a person authorized by you, we may request proof of identity as well as details of your relationship with us or our partners so that we can find the data that relates to you.
2. To request correction of the data collected for you, if they are incorrect or have changed
3. To request the deletion ("to be forgotten") of the personal data collected for you, except in cases where "STUDIO NOMA" Ltd. processes your personal data in compliance with obligations arising from the law. You have the right to request that we delete your personal data without undue delay if:
- personal data are no longer needed for the purposes for which they were collected
- when you have withdrawn your consent
- when you have objected to the processing, if it is illegal
- where personal data must be deleted in order to comply with a legal obligation under Union law or the law of a Member State that applies to us as a controller of personal data
- where personal data have been collected in connection with the provision of information society services
- Under certain conditions, we may refuse to delete your personal data in cases provided by law.
4. To request a restriction on the processing of your personal data only for the purposes for which they were collected - in accordance with the requirements of the General Regulation on Personal Data Protection, the Personal Data Protection Act and their implementing acts (only in the cases provided for in the applicable regulations and insofar as this does not contradict our regulatory obligations for the processing of your personal data);
5. Right to portability of your personal data (only in the cases provided for in the applicable legislation, and insofar as this does not contradict our regulatory obligations for the processing of your personal data);
6. To receive copies of the documents with your personal data, after submitting a request in a form in the office of the Company
7. At any time you can object to the processing of your personal data for the purposes of direct marketing, carried out by "STUDIO NOMA" EOOD, by withdrawing your consent.
Art.10. (1) In case of violation of your rights under the General Regulation on Data Protection, LPPD, you have the right at any time to file a complaint to the relevant supervisory authority, namely the Commission for Personal Data Protection;
(2) You can appeal the actions and acts of STUDIO NOMA EOOD and the processors on behalf of the Company and in court before the respective administrative court and before the Supreme Administrative Court.
Art.11. (1) The rights under art. 9 you can do so by filling in a written "Application for the exercise of rights in connection with the protection of personal data" (Application), which we will provide upon request.
(2) The application can be sent personally or through your explicitly authorized person with a notarized power of attorney on paper in each of our offices, as well as electronically, by the order of ZEDEUU. When the application is drawn up as an electronic document, it should be signed with a qualified electronic signature.
(3) When submitting the application by an authorized person, you should enclose the respective explicit power of attorney.
(4) In the cases when during the exercise of your rights under this chapter there is a possibility to disclose personal data for a third party, our respective employee will provide you with access only to the part of them that applies to you.
Art.12. Within 30 (thirty days) from the receipt of a valid application for the exercise of rights in connection with the protection of personal data "" STUDIO NOMA "Ltd. will provide you with written information in connection with the actions performed by us, such as:
1. In case of your right to access personal data - will provide you with information about: the purposes for which the Company processes your personal data; the categories of personal data it processes; the recipients or categories of recipients to whom your personal data are or will be disclosed, in particular recipients in third countries or international recipient organizations to whom it provides them; where possible, the intended period for which your personal data will be stored and, if this is not possible, the criteria used to determine this period; the existence of the right to request from us the correction or deletion of personal data or the restriction of the processing of personal data relating to you, or to object to such processing, your right to appeal to the competent supervisory authorities; where your personal data has not been collected by you - any available information about their source, the existence of automated decision-making, including profiling, in accordance with the General Data Protection Regulation;
2. If you have exercised the right to delete your personal data - will delete without undue delay your personal data, provided that there are prerequisites for exercising your right, provided in the General Regulation on Data Protection, LPPD and acts of their application and insofar as this does not contradict our legal obligations for the processing of your personal data;
3. If you have exercised the right to restrict the processing of your personal data - will limit the processing of your personal data, in the cases provided for in the applicable regulations and insofar as this does not contradict our legal obligations to process your personal data without delete, and we will inform you before the lifting of the processing restriction.
4. If you have exercised the right to portability of your personal data - "STUDIO NOMA" Ltd. will present your personal data in a structured, widely used and machine-readable format and will transfer your data to another administrator, in the cases provided for in the applicable regulations, and insofar as this does not contradict our regulatory obligations for the processing of your personal data.
(2) STUDIO NOMA EOOD will also inform you in writing about any refusal of access, deletion, right to limit the processing of your personal data or request for exercising the right of portability, as well as the reasons for the refusal within the term under para 1. .
(3) When your personal data are deleted or their processing is limited, "STUDIO NOMA" EOOD will notify their recipients, who are responsible for their respective - deletion or restriction.
(4) Our obligation to provide the information under this article may be limited in whole or in part, taking into account your fundamental rights and legitimate interests and in the cases provided for by the applicable regulations.
(5) STUDIO NOMA EOOD has the right to extend the term under para 1 to 60 days, depending on the complexity and the number of the received applications in each separate case. The company will notify you of any extension of the term, as well as the reasons for the extension of the term for response by us within 30 days of receipt of a valid application for the exercise of rights in connection with the protection of personal data.
Art.13. (1) The right to request correction of your personal data can be exercised by filling in a written application for correction of personal data (the application), which we will provide to you upon request.
(2) The application can be sent personally or through your explicitly authorized person with a notarized power of attorney on paper in our office, as well as electronically, in accordance with the Electronic Document and Electronic Certification Services Act (EDESA). When the application is drawn up as an electronic document, it should be signed with a qualified electronic signature.
(3) When submitting the application by an authorized person, you should enclose the respective explicit power of attorney.
Art.14. (1) Within 30 (thirty days) from the receipt of your valid application for correction of personal data, "STUDIO NOMA" EOOD will correct without undue delay the inaccurate personal data related to you or will supplement your incomplete personal data.
(2) STUDIO NOMA EOOD will inform you in writing about any refusal to correct or supplement your personal data, as well as about the reasons for the refusal within the term under para 1.
(3) When your personal data have been corrected or supplemented, STUDIO NOMA EOOD will notify their recipients, who are responsible for their respective correction or supplementation.
(4) Our obligation to provide the information under this article may be limited in whole or in part, taking into account your fundamental rights and legitimate interests and in the cases provided for by the applicable regulations.
Art.15. (1) You can exercise the right to object to the processing of your personal data for the purposes of direct marketing by filling in a written Application for withdrawal of consent for processing personal data for the purposes of direct marketing (the Application), which we will provide upon request. .
(2) The application can be sent personally or through your explicitly authorized person with a notarized power of attorney on paper in each of our offices, as well as electronically, in accordance with the Electronic Document and Electronic Certification Services Act (EDESA). When the application is drawn up as an electronic document, it should be signed with a qualified electronic signature.
(3) When submitting the application by an authorized person, you should enclose the respective explicit power of attorney.
Art.16. Within 30 (thirty days) from the receipt of your valid application for withdrawal of consent for the processing of personal data for the purposes of direct marketing, STUDIO NOMA EOOD will terminate the processing of the personal data provided by you for the purposes of direct marketing and will provide you with written information regarding these actions.
(2) STUDIO NOMA EOOD will inform you in writing about any refusal to respect the application under para 1, as well as about the reasons for the refusal within the term under para 1.
(3) After STUDIO NOMA EOOD terminates the processing of the personal data provided by you, the Company will notify their recipients, who are responsible for the termination of their processing.
(4) Our obligation to provide the information under this article may be limited in whole or in part, taking into account your fundamental rights and legitimate interests and in the cases provided for by the applicable regulations.
(5) STUDIO NOMA EOOD has the right to extend the term under para 1 to 60 days, depending on the complexity and the number of the received applications in each separate case. The company will notify you of any extension, as well as the reasons for the extension of the response period by us within 30 days of receipt of your valid application for withdrawal of consent to the processing of personal data for direct marketing purposes.
Term of storage of your personal data
Art.17. (1) STUDIO NOMA EOOD stores your personal data for a period not longer than the existence of your account on the website. After the expiration of this period, "STUDIO NOMA" Ltd. takes the necessary care to delete and destroy all your data without undue delay. In the general case, unless otherwise specified, your data is stored for a period of 2 (two) calendar years from the date of receipt.
(2) "STUDIO NOMA" EOOD notifies you in case the term for data storage needs to be extended in order to fulfill the objectives, fulfill the contract, in view of the legitimate interests of "STUDIO NOMA" EOOD or other.
(3) “STUDIO NOMA” EOOD stores your data, given on the basis of consent, until its explicit withdrawal, as this does not affect the publications and comments made in order to preserve the semantic integrity of the comments.
(4) STUDIO NOMA EOOD stores the personal data, which it is necessary to keep by virtue of the applicable legislation for the respective envisaged term, which may exceed the term of existence of your registration.
In case of violation of the security of your personal data
Art. 18. (1) If STUDIO NOMA EOOD establishes a breach of the security of your personal data, which may pose a high risk to your rights and freedoms, we shall notify you without undue delay of the breach, as well as of the measures taken or to be taken.
(2) STUDIO NOMA EOOD 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 steps to ensure that the breach does not lead to a high risk to your rights;
notification would require a disproportionate effort.
Persons to whom your personal data is provided
Art. 19. In connection with the conclusion of contracts for purchase and sale and delivery of the services offered by STUDIO NOMA EOOD, STUDIO NOMA EOOD transmits the necessary information to:
- Courier or postal companies that must deliver documents or other items on our behalf
- Printers who need to prepare personalized materials for you
- Companies to send mass emails when you need to receive an email message from us.
Art. 20. The administrator does not transfer your data to third countries.
Data protection
Art. 21. "STUDIO NOMA" Ltd. treats your personal data as strictly confidential. To protect them, a number of measures have been taken, including:
- We restrict access to the premises in which we work only to the people who must be there (for this purpose we use codes and access cards, passwords and other technologies related to restricting access to certain premises);
- We also implement access control to our information technology systems using firewalls, validation of an identification number (ID), logical segmentation and / or physical separation of our systems and information;
- We use methods such as encryption and pseudonymization of information;
- We never ask you to send us your password;
- We advise you never to enter an account number, password or other sensitive information in an email to us.
Additional provisions
§1. This policy has been approved by order of the representative of STUDIO NOMA EOOD
§2. The General Regulation on Data Protection, the Personal Data Protection Act and other normative acts related to the activity of STUDIO NOMA EOOD shall apply to the issues not settled in this Policy.
§3. Taking into account current trends, the current privacy policy may change. The update date is indicated at the end of the document. Any changes to this Privacy Policy will be effective after they are announced in the future.
This policy has been prepared by the team of Advocatus.bg