I. INTRODUCTION
Welcome to www.interhecs.com (hereinafter referred to as “Web site” or “Website”) which is operated by “Study in Bulgaria” Ltd., UIC: 205570561, having its seat and registered address at: Petrich, 7 Pleven Street, telephone: 00359 2 437 3254.
BY USING THIS WEBSITE YOU AGREE TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA IN COMPLIANCE WITH THIS PRIVACY POLICY.
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE AND IF YOU HAVE ANY QUESTIONS ABOUT THIS PRIVACY POLICY, PLEASE CONTACT US AT: 00359 2 437 3254 OR [email protected] . IF YOU DO NOT AGREE TO ANY OF THE CONDITIONS CONTAINED IN THIS PRIVACY POLICY, YOU SHOULD NOT USE THIS WEBSITE.
DATA CONTROLLER
“Study in Bulgaria” Ltd. (hereinafter referred to as “Controller”) is a Bulgarian company with UIC: 205570561, having its seat and registered address at: Petrich, 7 Pleven Street, telephone: 00359 2 437 3254 and website: www.interhecs.com.
SUPERVISORY AUTHORITY
Commission for Personal Data Protection
Address: Republic of Bulgaria, Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.
Telephone: +3592/91-53-518; +3592/ 91-53-515; +3592/91-53-519
Fax: +3592/91-53-525
Е-mail: [email protected]
Web-site: www.cpdp.bg
II. PURPOSE AND SCOPE OF THE PRIVACY POLICY
1.1 The Controller understands the privacy concerns of the visitors to this Website (hereinafter referred to as “individuals”) regarding the protection of personal data and is committed to protect their personal data by applying all the standards for protection of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the 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 (hereinafter referred to as “GDPR”). With this Privacy Policy, the Controller respects the privacy of individuals and undertakes every effort to protect the personal data of individuals against unlawful processing by applying technical and organizational measures, which measures are entirely consistent with state-of-the-art technological developments and provide a level of protection that corresponds to the risks associated with the processing and the nature of the data that should be protected.
1.2 With this Privacy Policy and in compliance with the requirements of the GDPR, the Controller provides information on:
– the purpose and scope of this Privacy Policy;
– personal data collected and processed by the Controller;
– purposes of personal data processing;
– period for which the personal data will be stored;
– mandatory and voluntary nature of provision of personal data;
– processing of persona data;
– protection of personal data;
– recipients of personal data;
– rights of individuals;
– procedure to exercise the rights.
III. DEFINITIONS
2.1 For the purposes of the GDPR and this Privacy Policy, the following terms shall have the following meaning:
IV. PRINCIPLES RELATING TO PROCESSING OF PERSONAL DATA
3.1 The Controller observes the following principles relating to processing of personal data:
– The personal data are processed lawfully, fairly and in a transparent manner in relation to the individual (‘lawfulness, fairness and transparency’);
– The personal data are collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
– The personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
– The personal data are accurate and, where necessary, kept up to date (‘accuracy’);
– The personal data are kept in a form which permits identification of individuals for no longer than is necessary for the purposes for which the personal data are processed (‘storage limitation’);
– The personal data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).
V. PERSONAL DATA COLLECTED AND PROCESSED BY THE CONTROLLER
A. Processing of special categories of personal data (“sensitive data”)
4.1 The Controller does not collect and record special categories of personal data from users or visitors of the website, such as: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. Individuals shall not provide such sensitive data to the Controller. If the individual negligently or intentionally provides sensitive data to the Controller, the Controller undertakes to immediately delete such data.
B. Personal data collected directly from individuals
Personal data collected directly from individuals when the Controller is contacted by phone
5.1 Individuals provide personal data to the Controller when they contact the Controller by phone. The telephone number of the Controller is specified in the Controller’s Identification Information in this Privacy Policy and on the website where the contact details of the Controller are provided. When the individual contacts the Controller by phone, the Controller only collects and processes the name and phone number of the individual, and in some cases also the e-mail address of the individual. These data are processed for the purpose of communicating with the individual. The processing of these personal data is necessary:
– for the realization of the legitimate interests of the Controller, where legitimate interests are answering to the received phone calls and sending emails in connection with inquiries received by telephone.
– for actions preceding the conclusion of a contract and undertaken at the request of the individual, namely providing more information on the services offered by the Controller in connection with a possible conclusion of a contract with the individual.
The Controller uses the services of a telephone service provider located in the Republic of Bulgaria.
Personal data collected directly from individuals when individuals contact the Controller using the form “Apply to study in Bulgaria”
5.2 Individuals provide personal data to the Controller when they use the form “Apply to study in Bulgaria” on the Controller’s website at: https://www.interhecs.com/ . When the individual fills the “Apply to study in Bulgaria” form, the Controller collects and processes the name of the individual, the e-mail address, and the chosen study program. These personal data are processed for the purpose of communication with the individual and record keeping. The processing of these personal data is necessary:
– for the realization of the legitimate interests of the Controller, whose legitimate interests are sending the received messages, as well as saving the received messages.
– for actions preceding the conclusion of a contract and undertaken at the request of the individual, namely providing more information on the services offered by the Controller in connection with a possible conclusion of a contract with the individual.
The Controller uses the services of an e-mail service provider to store received emails on a server that is located in the Republic of Bulgaria.
Personal data collected directly from individuals when individuals contact the Controller by e-mail
5.3 Individuals provide personal data to the Controller when they contact the Controller by sending an e-mail. The e-mail address of the Controller is specified in the Controller’s Identification Information in this Privacy Policy and on the Controller’s website. When the individual sends an e-mail to the Controller, the Controller collects and processes the e-mail address of the individual and the other information that the individual provides in the sent message, such as the address. These personal data are processed for the purpose of communication with the individual and record keeping. The processing of these personal data is necessary:
– for the realization of the legitimate interests of the Controller, whose legitimate interests are sending the received messages, as well as saving the received messages.
– for actions preceding the conclusion of a contract and undertaken at the request of the individual, namely providing more information on the services offered by the Controller in connection with a possible conclusion of a contract with the individual.
The Controller uses the services of an e-mail service provider to store received emails on a server that is located in the Republic of Bulgaria.
Personal data collected directly from individuals when individuals contact the Administrator by sending a message using the Facebook platform
5.4 Individuals provide personal data to the Controller when they contact the Controller by sending a message using the Facebook platform via the Facebook messaging service available through the Facebook administrator page at: https://www.facebook.com/interhecs. When the individual sends a message to the Controller using the Facebook platform via the Facebook messaging service, the Controller collects and processes the individual’s name, as well as the other information the individual provides in the sent message. This data is processed for the purpose of communication with the individual and record keeping. The processing of such personal data is necessary for the realization of the legitimate interests of the Controller, whose legitimate interests are to reply to the received messages, as well as to keep the received messages. The administrator uses the Facebook services, an independent US service provider, to receive messages via the Facebook platform. This means that the personal data provided will be stored on Facebook servers in the United States. For the transmission of such personal data outside the European Economic Area, appropriate safeguards should be provided in accordance with Article 46 of Regulation (EC) 2016/679. Facebook confirms that it adheres to the principles of the “EU-US Privacy Shield”. Facebook has its own Privacy Policy and individuals are advised to get acquainted with it in order to get more information. The Facebook Privacy Policy is posted at https://www.facebook.com/policy.php .
Personal data collected directly from individuals when individuals subscribe to a newsletter
5.5 Individuals provide their e-mail addresses when they want to subscribe for receiving of a newsletter. When the individual subscribes to receive newsletters containing publications and useful information about the services offered by the Controller and the like, the Controller collects and processes the e-mail address of the individual. This data is processed for the purpose of sending of newsletters to the individual. The reason for processing of the provided personal data is the consent of the individual. The Controller uses the services of MailChimp, an independent US service provider, to send newsletters and manage the email list. This means that the provided e-mail addresses will be stored on the servers of MailChimp in the United States. For the transmission of such personal data outside the European Economic Area, appropriate safeguards should be provided in accordance with Article 46 of Regulation (EC) 2016/679. MailChimp certifies that it complies with the principles of the “EU-US Privacy Shield”. MailChimp has its own Privacy Policy and individuals are advised to get acquainted with it in order to get more information. MailChimp Privacy Policy is posted at https://mailchimp.com/legal/privacy/. Additionally, there is a contract between the Controller and Mailchimp.
C. Personal data collected from third parties
6.1 The Controller usually does not obtain personal data for individuals from third parties. However, in some cases, if the Controller has a reasonable grounds to suspect any individual of infringing Controller’s legal or intellectual property rights, then the Controller will obtain personal data of the suspected individual from public registers or private sources. This data may be processed for the purposes of investigating the infringement and taking legal actions against the infringement. The lawful grounds for processing of the personal data are the legitimate interests pursued by the Controller, which legitimate interests are investigating the infringement and taking legal actions against the infringement.
D. Data collected automatically
7.1 When an individual visits the Web site, the Controller automatically collects the following data, namely:
– The type of device from which the individual accesses the platform (for example, a computer, a mobile phone, a tablet, etc.);
– Type of operating system;
– Type of the browser;
– Concrete actions undertaken, including the pages visited, frequency and duration of visits to the website;
– Date and time of visits.
VI. USE OF COOKIES
What a cookie is?
A cookie is a file that is stored on your computer’s browser directory when certain websites are visited. Cookies enable a website, among other things, to store and retrieve information about users’ browsing habits or their visitors. Depending on what information the cookies have and how you use your computer, cookies are used to recognize the users.
Which type of cookies uses our website?
Depending on the period of time they remain active, the cookies can be:
– Session cookies: they are stored only temporarily during a browsing session and are deleted from user’s device when the browser is closed. They are used to store information that is only needed for the provision of the service requested by the user on a single occasion (for example, a list of products purchased).
– Persistent cookies: these cookies are saved on your computer for a fixed period of time and are not deleted when the browser is closed. For example, we use this type of cookies in the purchase or registration process, to store your preferences, so that they are remembered for the next visit.
When you browse our website, the following cookies can be installed on your device:
– Log cookies: when the user logs on to our website, a temporary cookie that identifies you as a registered user is installed. These cookies are used for identifying users’ account and associated services making browsing easier, without having to enter your details each time. This cookie is maintained as long as you do not leave your account, close the browser or turn off the device.
– Cookies for statistical analysis: they provide information on the browsing user behaviour anonymously. These cookies allow us to quantify the number of users and statistics analysis to control the use that users make of our services. With these cookies, browsing our web can be studied and our range of products and services improved. They can be our own cookies, or third-party cookies, such as those of Google Analytics.
Configuration, consultation and disabling of cookies
You can allow, block or delete cookies installed on your device through the browser settings installed on your computer:
Chrome, from https://support.google.com/chrome/answer/95647?hl
Safari, from http://support.apple.com/kb/ph5042
Explorer, from http://windows.microsoft.com/es-es/windows7/how-to-manage-cookies-in-internet-explorer-9
Firefox, from https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
All the information regarding Google cookies, both analytics and advertising cookies, and also information related with the management and configuration of the cookies is available at the following links:
https://policies.google.com/technologies/types
https://policies.google.com/technologies/ads
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
If you choose to disable cookies, we will not be able to provide you some of our online services.
Updating of cookies
The cookies of our website can be updated, so we encourage you to review our Privacy Policy regularly.
VII. PURPOSES OF PERSONAL DATA PROCESSING
9.1 The Controller collects and processes the personal data of individuals who are provided directly by them solely for the following purposes, namely:
– to provide the services that the Controller offers and identify individuals (future and current clients);
– to contact the individual via e-mail in order to respond to the received inquiries;
– for the execution of obligations of a contract to which the individual to whom such data refer is a party, and for actions at the individual’s request and preceding the execution of a contract;
– for the execution of an obligation of the Controller, stipulated by law;
– accounting purposes;
– statistical purposes.
9.2 The Controller collects and processes the personal data of individuals who are automatically collected for the following purposes, namely:
– improving the efficiency and functionality of the website;
– preparing anonymous statistics on how the website has been used;
The Controller may not use the personal data of individuals for purposes other than those specified in this section of this Privacy Policy. The Controller does not use and process the personal data of individuals for the purposes of profiling.
VIII. PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
10.1 Inquiries and correspondence by email, Facebook: The Controller stores the personal data and the communication received by e-mail and messages sent by Facebook for a period necessary to answer to the received message and to satisfy individual’s request, as well as for two calendar years after the Controller has answered to the received message and satisfied individual’s request.
10.2 Personal data of individuals who have become clients of the Controller: The Controller stores personal data of the individuals who have become clients of the Controller for a period of ten years, which is the term stipulated by law for storing invoices for clients.
10.3 Newsletter mailing list: The Controller stores the personal data provided for newsletter subscription, which is the e-mail of the individual, until the individual remains subscribed for receiving of newsletters or until the Provider ceases sending newsletters, whichever of the two circumstances comes first.
Criteria for determining the retention period for personal data
10.4 In other cases, which are not specified above, the person responsible will retain the personal data of the natural person no more than necessary in the light of the following criteria:
– whether the person responsible undertakes the legal obligation to continue the processing of the personal data of the person to comply with natural person;
– The purpose of the storage of personal data both now and in the future;
– whether a contract has been concluded between the person responsible and the natural person and the person responsible is obliged to continue the processing of the personal data in order to fulfill the contractual obligations;
– Purposes of the use of personal data currently and in the future;
– whether it is necessary to contact the natural person in the future;
– whether the person responsible has a legal basis to continue the processing of the personal data of the natural person;
– all other valid reasons such as the nature of the relationship with the natural person.
IX. MANDATORY AND VOLUNTARY NATURE OF PROVISION OF PERSONAL DATA
11.1 The personal data required to be provided by the individuals are in accordance with the services offered by the Controller. The provision of personal data by individuals is voluntary. In the event that the individual refuses to provide the personal data:
– the Controller will not be able to provide the service requested by the individual;
– the Controller will not receive the e-mail if the individual does not fill the necessary data in the contact form;
X. PROCESSING OF PERSONAL DATA
12.1 The Controller processes the personal data of individuals by means of a set of actions that can be performed by automatic or non-automatic means.
XI. PROTECTION OF PERSONAL DATA
13.1 The Controller undertakes the appropriate technical and organizational measures to protect the personal data against accidental or unlawful destruction, or against accidental loss, unauthorized access, alteration or dissemination, as well as against other unlawful forms of processing, including the following:
– using only secure and protected servers and folders for storing of the personal data;
– verifying and confirming the identification of the individual inquiring access to his/her personal data before granting access to such personal data.
13.2 More information on the technical and organizational measures undertaken by the Controller is available in the Instruction on the Mechanism of Personal Data Processing and their protection in the maintained registers containing personal data with the Controller. In case you would like to receive detailed information about the technical and organizational measures, please do not hesitate to contact us at 00359 2 437 3254 or [email protected].
XII. RECIPIENTS OF PERSONAL DATA
14.1 The Controller has the right to disclose the personal data processed to the following categories of persons, namely:
14.2 The Controller does not sell personal data provided by the individual to third parties.
XIII. RIGHTS OF INDIVIDUALS
Right of access by the individual:
15.1 The individual has the right to obtain from the Controllerconfirmation as to whether or not personal data concerning him or her are being processed. If the Controller processes personal data of the individual the Controller shall provide a copy of the personal data undergoing processing.
Right to rectification:
15.2 The individual has the right to obtain from the Controllerwithout undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the individual has the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (‘right to be forgotten’):
15.3 The individual has the right to obtain from the Controller the erasure of personal data concerning him or her without undue delay and the Controller has the obligation to erase personal data without undue delay where one of the stated in article 17 of the GDPR grounds applies.
Right to restriction of processing:
15.4 The individual has the right to obtain from the Controller restriction of processing where one of the stated in article 18 of the GDPR grounds applies. If the processing has been restricted, such personal data shall, with the exception of storage, only be processed with the individual’s consent or for the establishment, 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 of the Union or of a Member State. The Controllerinforms the individual who has obtained restriction of processing before the restriction of processing is lifted.
Right to data portability:
15.6 The individual has the right to receive the personal data concerning him or her, which he or she has provided to the Controller, in a structured, commonly used and machine-readable format and has the right to transmit those data to another controller without hindrance from the Provided to which the personal data have been provided, if the processing is based on consent or on a contract.
Right to object:
15.7 The individual has the right to object on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. According to Article 21, Paragraph 4 of the GDPR the right to object shall be explicitly brought to the attention of the individual and shall be presented clearly and separately from any other information. For compliance of this obligation, more information about the right to object, can be found in the section below titled “Right to object to processing of personal data”.
Profiling rights:
15.8 The individual has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
Right to be informed about the personal data breach:
15.9 The individual has the right to be informed without undue delay about the personal data breach when the personal data breach is likely to result in a high risk to the rights and freedoms of individual.
Right to judicial and administrative protection:
– Right to lodge a complaint with a supervisory authority
15.10 Without prejudice to any other administrative or judicial remedy, the individual has the right to lodge a complaint with the supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the individual considers that the processing of personal data relating to him or her infringes the GDPR.
– Right to an effective judicial remedy against a supervisory authority
15.11 Without prejudice to any other administrative or non-judicial remedy, the individual or legal person has the right to an effective judicial remedy against a legally binding decision of a supervisory authority concerning them. Proceedings against a supervisory authority shall be brought before the courts of the Member State where the supervisory authority is established.
– Right to an effective judicial remedy against the Controller or processor
15.12 Without prejudice to any available administrative or non-judicial remedy, including the right to lodge a complaint with a supervisory authority, the individual has the right to an effective judicial remedy where he or she considers that his or her rights under the GDPR have been infringed as a result of the processing of his or her personal data in non-compliance with the GDPR. Proceedings against the Controlleror a processor shall be brought before the courts of the Member State where the Controller or processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the individual has his or her habitual residence.
Right to compensation and liability:
15.13 Individual who has suffered material or non-material damage as a result of an infringement of the GDPR has the right to receive compensation from the Controller or processor for the damage suffered. Court proceedings for exercising the right to receive compensation shall be brought before the courts of the Member State where the Controlleror processor has an establishment. Alternatively, such proceedings may be brought before the courts of the Member State where the individual has his or her habitual residence.
XIV. PROCEDURE TO EXERCISE THE RIGHTS
16.1 The individual exercises his or her right to withdraw the given consent, right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability, right to object and profiling rights, by submitting a written request to the Controller (either by post at the address specified in the identification of the Controller above or by e-mail), which should contain the following information:
16.2 The request shall be filed personally by the individual. The Controller keeps the requests filed by the individuals in a separate register.
16.3 When the individual exercises the right of access to the personal data relating to him or her the Controller shall verify the identity of the individual before responding to the request. This is necessary to minimize the risk of unauthorized access and identity theft. If the Controller cannot identify the individual from the collected information, then the Controllerhas the right to require a copy of individual’s documentation (such as ID card, driving license, other documents containing personal data that identify the individual) in order to verify the individual’s identity.
16.4 The Controller considers the request and provides the information on action taken on the request of the individual within one month of receipt of the request. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests.
16.5 The Controller informs the individual of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the individual makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the individual.
16.6 In case the Controller does not take action on the request of the individual, the Controller informs the individual without delay and at the latest within one month of receipt of the request of the reasons for not taking action and on the possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
16.7 The Controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The Controllerinforms the individual about those recipients if the individual requests it.
XV. RIGHT TO OBJECT TO PROCESSING OF PERSONAL DATA
17.1 The individual has the right to object on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her. According to Article 21, Paragraph 4 of the GDPR the right to object shall be explicitly brought to the attention of the individual and shall be presented clearly and separately from any other information. For compliance of this obligation, more information about the right to object, will be provided in this section of the Privacy Policy.
17.2 The individual has the right to object on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller or processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the individual which require protection of personal data, in particular where the individual is a child, including profiling based on any of these provisions. The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the individual or for the establishment, exercise or defense of legal claims. The individual can exercise this right by submitting a written request to the Controller, either by post at the address specified in the identification of the Controller above or by e-mail.
17.3 Where personal data are processed for direct marketing purposes, the individual has the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. Where the individual objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. The individual can exercise this right by submitting a written request to the Controller, either by post at the address specified in the identification of the Controller above or by e-mail requiring to stop sending him or her marketing information or by clicking the unsubscribe link contained at the bottom of the e-mail the Controller sends to the individual.
XVI. BUTTONS, TOOLS AND CONTENT FROM OTHER COMPANIES
18.1 The Website contains buttons, which connect to other third party websites such as „Share on Facebook“, „Share on Twitter”, “Share on Linkedin”, as well as а link to the Controller’s profile in Linkedin social media and a link to the website of the developer of Controller’s website. All websites of such companies that can be accessed through this website are independent and the Controller assumes no responsibility for any damages and losses incurred as a result of the use of these sites. Individuals use these sites on their own responsibility and it is recommended that they familiarize themselves with the relevant Privacy Policy of the respective company for more information.
XVII. CHANGES TO THE PRIVACY POLICY
19.1 This Privacy Policy may be updated at any time in the future. When this happens, the revised Privacy Policy will be posted on this Website with a new “Last Updated” at the top of this Privacy Policy and will be in force from the date of publication. It is therefore advisable to periodically check this Privacy Policy to make sure that you are familiar with any changes. Using the Website after publishing the updated Privacy Policy, you will be deemed to agree with the changes made.
XVIII. CONTACTS
20.1 If you have additional questions about this Privacy Policy, please do not hesitate to contact the Controller at: 00359 2 437 3254 or [email protected].
Last updated: May 23, 2018.