Privacy notice

Genera l information

On May 25, 2018 the new General Data Protection Regulation (GDPR), adopted by the European Union, became effective. This Regulation aims to ensure the protection of data of individuals from all EU Member States and to harmonize the regulations for their processing. As a Personal Data Controller, Soft Data Services EOOD complies with all requirements of the new Regulation by collecting personal data only to the extent necessary for the provision of services, and stores them in a responsible and lawful manner.

Information about the Personal Data Controller

  1. Name: Soft Data Services EOOD
  2. UIC/BULSTAT: 175384854
  3. Address: Sofia, Borovo district, 60A Solun Str., office А1
  4. Financially liable person: Katya Radionova 
  5. E-mail: sales@softdataservices.com
  6. Tel.: 02/872 50 75
  7. Data Protection Officer: dpo@softdataservices.com

Information about the competent Supervisory Authority

  1. Name: Commission for Personal Data Protection
  2. Head office and registered address: Sofia 1592, 2 Prof. Tzvetan Lazarov Blvd.
  3. Correspondence address: Sofia 1592, 2 Prof. Tzvetan Lazarov Blvd.
  4. Tel.: 02 915 3 518
  5. email: kzld@government.bg, kzld@cpdp.bg
  6. website: cpdp.bg

Soft Data Services EOOD 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 natural persons with regard to the processing of personal data and on the free movement of such data.

Grounds for collecting, processing and storing personal data

Article 1. (1) Soft Data Services EOOD collects and processes personal data in connection with the provision of information and services relating to document management, mailing and card technologies on the following bases:

  • Explicit consent provided by you as client;
  • Fulfillment of contractual obligations of Soft Data Services EOOD under a contract with you;
  • Compliance with a legal obligation applicable to Soft Data Services EOOD;
  • For the purposes of the legitimate interest of Soft Data Services EOOD.

(2) Soft Data Services Ltd. is a Personal Data Controller with regard to your data as a user of our services. As regards personal data that you process by using our services, Soft Data Services EOOD acts as Personal Data Processor.

 

Purposes and principles in collecting, processing and storing personal data

 

Article 2. (1) Soft Data Services EOOD collects and processes personal data provided by you for the fulfillment of services, including any of the following purposes:

  • accounting purposes;
  • statistical purposes;
  • information security;
  • to ensure implementation of a contract for provision of the respective service;
  • to send information messages, service modification notices, information about new projects or news concerning real estates or activities of the company;
  • personalized messages with offers appropriate for you as a follow up to our previous communication with you.

(2) Soft Data Services EOOD is follows the following principles when processing of your personal data:

  • legality, acting in good faith and with transparency;
  • limitation of processing purposes;
  • relevance to processing purposes and minimization of data collection;
  • accuracy and updates of the data;
  • restriction of data storage in order to achieve the processing purposes;
  • integrity and confidentiality of the processing; and
  • ensuring an adequate level of security of personal data.

(3) When processing and storing data Soft Data Services EOOD may process and store personal data for the protection of its legitimate interests, as follows:

  • fulfillment of obligations to the National Revenue Agency, Ministry of Interior and other central and local authorities.

What kind of personal data are being collected, processed and stored by Soft Data Services EOOD?

Article 3. (1) Soft Data Services EOOD executes the following operations and processes personal data for the following purposes:

  • to send information messages – the purpose of this activity is to administer the process of sending messages to users in cases where they have asked for opinion or sent an inquiry.
    • to send newsletter – the purpose of this activity is to administer the process of sending newsletters to users who select to receive them.

(2) Soft Data Services EOOD processes the following categories of personal data and information for the following purposes and on the following grounds:

  • Data: Your personal information (name and surname, e-mail, phone number)
    • Purpose of the data collection: 1) for contacting the user and sending information, and as requested – sending newsletters and advertising messages;
    • Grounds on which your personal data is processed: by ordering the service from Soft Data Services EOOD you enter into contractual relationship which is the basis for processing your personal data (GDPR, Article 6, para. 1 (b)).
  • Other data processed by Soft Data Services EOOD: when you access our website, Soft Data Services EOOD collects data about the IP address.
  • Your individual invoice details – if you wish an invoice to be issued to you as a natural person, you need to provide your personal identification number.
    • Purpose of the data collection: issuance of an invoice for payment for services provided.
    • Grounds on which your personal data is processed: By ordering a service from Soft Data Services EOOD you enter into contractual relationship which is the basis for processing your personal data (GDPR, Article 6, para. 1 (b)).

(3) Soft Data Services EOOD does not collect or process personal data relating to the following:

  • racial or ethnic origin;
    • political, religious or philosophical beliefs, or trade union membership;
    • genetic and biometric data, health data or data on sexual life or sexual orientation.

(4) Personal data are being collected by Soft Data Services EOOD from the data subject.

 

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

 

Retention period for data collected

Article 4. (1) Soft Data Services EOOD stores your personal data for a period not longer than necessary for the fulfillment of the contractual relationship. Upon expiry of this period, Soft Data Services EOOD takes the necessary steps to erase and destroy all your data without undue delay.

 

(2) Soft Data Services EOOD will notify you in case the data retention period needs to be extended in order to fulfill the purposes, fulfill the contract, in view of the legitimate interests of Soft Data Services EOOD or otherwise.

 

(3) Soft Data Services EOOD will store the personal data as required by the applicable legislation for the prescribed period which may exceed the term under the contractual relations between the parties.

 

Submission of your personal data for processing

Article 5. (1) Soft Data Services EOOD may, at its own discretion, transfer part or all of your personal data to personal data processors for the fulfillment of the processing purposes in compliance with the requirements of Regulation (EU) 2016/679.

 

(2) Soft Data Services EOOD will notify you if it intends to transfer some 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

Article 6. (1) If you do not want Soft Data Services EOOD to continue to process all or part of your personal data for one or all the purposes of processing, you can withdraw your consent to the processing at any time by sending a request in free-style form.

 

(2) Soft Data Services EOOD may ask you to verify your identity and the identity of the data subject.

 

(3) Upon withdrawal of your consent for the processing of personal data which is required for the performance of the requested service, Soft Data Services EOOD is entitled to refuse performance.

 

Right to access

Article 7. (1) You have the right to request and obtain from Soft Data Services EOOD confirmation as to whether or not personal data concerning you are being processed.

 

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

 

(3) Soft Data Services EOOD will provide you, upon request, with a copy of the personal data undergoing processing and concerning you, in electronic or other appropriate form.

 

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

 

Right to rectification or completion

Article 8. You can rectify or complete any inaccurate or incomplete personal data concerning you by filing a request (in free-stye text) to Soft Data Services EOOD.

 

Right to erasure (“right to be forgotten”)

Article 9.(1) You have the right to obtain from Soft Data Services EOOD the erasure of personal data concerning you, and Soft Data Services EOOD shall have the obligation to erase such personal data without undue delay, where one of the following grounds applies:

  • the personal data are no longer necessary in relation to 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 ground for the processing;
    • you object to the processing of your personal data, including for direct marketing purposes, and there are no overriding legitimate grounds for the processing;
    • personal data have been unlawfully processed;
    • personal data have to be erased for compliance with a legal obligation in Union or Member State law to which Soft Data Services EOOD is subject.

(2) Soft Data Services EOOD shall not be obligated to delete personal data if it stores and processes them:

  • for exercising the right of freedom of expression and information;
    • for compliance with a legal obligation which requires processing by Union or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
    • for reasons of public interest in the area of public health;
    • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes;
    • for the establishment, exercise or defence of legal claims.

(3) In order to exercise your “right to be forgotten”, you must submit a written request to Soft Data Services EOOD, as well as verify your identity and the identity of the data subject whose data were provided to Soft Data Services EOOD.

(4) Soft Data Services EOOD will not delete the data which it has a legal obligation to store, including for protection in case of court claims against it or as a proof of its rights.

 

Right to restriction of processing

Article 10. You have the right to obtain from Soft Data Services EOOD restriction of processing of data concerning you where one of the following applies:

  • the accuracy of the personal data is contested by you, for a period enabling the controller to verify the accuracy of the personal data;
    • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
    • Soft Data Services EOOD no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

Right to data portability

Article 11. (1) You can, by sending an e-mail request, download at any time the data stored and processed for you in connection with the use of services provided by Soft Data Services EOOD.

(2) You can request Soft Data Services EOOD to transmit directly your personal data to another Controller specified by you, where technically feasible.

Right to be notified

Article 12. You can ask Soft Data Services EOOD to notify you about each recipient to whom the personal data for which rectification or erasure or restriction of processing was requested have been disclosed. Soft Data Services EOOD may refuse to provide this information if this proves impossible or involves disproportionate effort.

Right to object

Article 13. You can object at any time to the processing by Soft Data Services EOOD of personal data concerning you, including if they are processed for the purposes of profiling or direct marketing.

 

Your rights in case of personal data breach

Article 14. (1) If Soft Data Services EOOD finds a personal data breach which is likely to result in a high risk to your rights and freedoms, we will notify you of the personal data breach without undue delay, and of the measures taken or proposed to be taken.

(2) Soft Data Services EOOD is not required to notify you if:

  • appropriate technical and organizational protection measures have been implemented with regard to such data affected by the personal data breach;
  • subsequent measures have been taken which ensure that the breach will not result in a high risk to your rights;
  • notification would involve disproportionate effort.

Other provisions

Article 15. In case of violation of your above rights or rights under the applicable data protection legislation, you will be entitled to lodge a complaint with the Commission for Personal Data Protection as follows:

  1. Name: Commission for Personal Data Protection
  2. Head office and registered address: Sofia 1592, 2 Prof. Tzvetan Lazarov Blvd.
  3. Correspondence address: Sofia 1592, 2 Prof. Tzvetan Lazarov Blvd.
  4. Tel.: 02 915 3 518
  5. email: kzld@government.bg, kzld@cpdp.bg
  6. website: cpdp.bg

Article 18. You can exercise your rights regarding the protection of your personal data through any of the forms attached thereto. Surely, these forms are optional and you can submit your requests in any other form containing a statement to that effect and identifying you as the data subject.

Article 19. If the consent regards a transmission, the Controller will describe the possible risks for the transmission of data to third countries in the absence of a decision on adequate protection and appropriate means of protection.