PRIVACY POLICY
By notifying you of this privacy policy, we meet the requirements of art. 13 and art. 14 of Regulation (EU) 2016/679 (“Regulation 2016/679” or “GDPR”) to inform you about the data processing activities carried out by PANEV & PARTNERS LAW FIRM, the grounds for collecting personal data, the purposes for which the data are processed, the measures and guarantees for the protection of the processed data, your rights and the way you can exercise them in accordance with the requirements of the GDPR and other applicable acts of EU and the national legislation of the Republic of Bulgaria.
ADMINISTRATOR CONTACT DETAILS
The administrator is PANEV & PARTNERS LAW FIRM, BULSTAT 177135218, hereinafter referred to as “the Law Firm“, PANEV & PARTNERS LAW FIRM is a legal entity established under the Bar Act, which operates on the territory of the Republic of Bulgaria.
The headquarters and registered address of the Law Firm are: 133 Todor Alexandrov Blvd., fl. 1, office 3, 1309 Sofia, Bulgaria
Other ways to contact the Law Firm:
By e-mail: office@panevpartners.com
Phone: 02 996 35 14 (from 9 am to 5 pm on working days)
Manager and contact person of the Law Firm is Hristo Panev
CASES OF DATA PROCESSING
The Administrator processes personal data in the following cases:
- In relation to conclusion, development and termination of employment relationships, personnel selection and in the cases of work under civil contracts or contracts under art. 76 and art. 77 of the Bar
- In relation to commercial contracts between the Law Firm and third parties.
- In relation to concluding a contract for legal services with a client of the Law Firm and in relation to the provision of legal services to clients.
- When visiting the Law Firm’s office.
- When visiting the Law Firm’s website using the contact form and in case of interactions in social networks.
- In relation to video surveillance in the office of the Law Firm.
In the cases under items 1, 2, 3 and 6, the provision of data is a condition for concluding a contract and providing services as the data is collected and processed on the grounds of fulfillment of a legal obligation of the administrator or based on protection of legitimate interests of the administrator. If a data subject does not wish his or her data to be collected and processed, the Law Firm will have no other choice but to refuse to enter into relations with the data subject.
PURPOSES AND GROUNDS FOR DATA PROCESSING
In relation to conclusion, development and termination of employment relationships, personnel selection and in the cases of work under civil contracts or contracts under art. 76 and art. 77 of the Bar Act, the Law Firm processes data on the following grounds:
- Processing is necessary for compliance with a legal obligation to which the administrator is subject.
- Processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract.
- The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
The purposes of personal data processing in the above cases are:
- Individualization of employment and civil contractual relations.
- Fulfillment of the regulatory requirements of the Labor Code, the Social Security Code, the Accountancy Act, the State Archives Act and other specific requirements regulated by law or regulation.
- For facilitating all activities related to the existence, amendment and termination of employment and civil relationships – drafting of any documents of the persons in this connection (contracts, additional agreements, documents certifying work experience, official notes, references, certificates, etc.).
- To contact the subject by phone, to send correspondence related to the fulfillment of his obligations under employment or civil contracts.
- For keeping accounts regarding the remuneration of the above-mentioned persons under employment and civil contracts.
- Analysis of the qualities of job candidates in view of the possibility of their employment.
- Selection of candidates with which to conduct personal meetings and oral interviews.
- Selection of candidates with which to be concluded employment or civil contracts.
- To establish contact with the subject by phone, to send correspondence related to the procedure for applying for a job in the Law Firm.
- Proper performance of accounting activities for operations related to employment.
- Proper conduct of human resources management, including calculation of remuneration with the relevant supplements and / or deductions, proper withholding of taxes and social security contributions, charging and payment of benefits, etc.
In relation to commercial contracts between the Law Firm and third parties, the Law Firm processes personal data on the following grounds:
- Processing is necessary for compliance with a legal obligation to which the administrator is subject.
- Processing is necessary for the purposes of the legitimate interests of the administrator – protection of the economic interests of the Law Firm, conducting administrative and judicial procedures against suppliers of the Law Firm in the cases provided for by law.
The purposes of personal data processing in the above cases are:
- Creation and maintenance of an information archive of the Law Firm, necessary for accounting and the legal and administrative activity of the Law Firm.
- Protection of the legal and economic interests of the Law Firm.
In relation to concluding a contract for legal services with a client of the Law Firm and in relation to the provision of legal services to clients the Law Firm processes personal data on the following grounds:
- Processing is necessary for compliance with a legal obligation to which the administrator is subject.
- Processing is necessary for the purposes of the legitimate interests of the controller – protection of the economic interests of the Law Firm, conducting administrative and judicial procedures related to contractors of the Law Firm in the cases provided for by law, meeting the specific requirements for lawyers and law firms of the Bar Act, the Measures Against Money Laundering Act, the Measures Against the Financing of Terrorism Act, the General Data Protection Regulation and other legal acts applicable to the lawyers’ activities carried out by the Firm and the lawyers;
The purposes of personal data processing in the above cases are:
- Creation and maintenance of an information archive of the Law Firm, necessary for accounting and the legal and administrative activity of the Law Firm.
- Creation and maintenance of an information archive of the Law Firm necessary to comply with the specific requirements for lawyers and law firms of the Bar Act, the Measures Against Money Laundering Act, the Measures Against the Financing of Terrorism Act, the General Data Protection Regulation, and other legal acts applicable to the lawyers’ activities carried out by the Society and the lawyers.
- Protection of the legal and economic interests of the Law Firm.
When visiting the Law Firm’s office, the Law Firm processes personal data on the following grounds:
- The processing is necessary for the purposes of the legitimate interests of the administrator – protection of the economic interests of the Law Firm, conducting administrative and judicial procedures related to contractors of the Law Firm in the cases provided for by law, compliance with the specific requirements for lawyers and law firms of the Bar Act, the Measures Against Money Laundering Act, the Measures Against the Financing of Terrorism Act, the General Data Protection Regulation and other legal acts applicable to the lawyers’ activities carried out by the Law Firm and the lawyers.
- The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
The purposes of personal data processing in the above cases are:
- Implementation of admission regime to the premises of the Law Firm.
- To establish contact with the subject by phone, to send correspondence related to compliance with the mandatory rules in the premises of the Law Firm.
- Non-admission to the premises of the Law Firm of persons who have violated the mandatory rules during previous
- Creation and maintenance of an information archive of the Law Firm necessary to comply with the specific requirements for lawyers and law firms of the Bar Act, the Measures Against Money Laundering Act, the Measures Against the Financing of Terrorism Act, the General Data Protection Regulation, and other legal acts applicable to the lawyers’ activities carried out by the Society and the lawyers.
- Protection of the legal and economic interests of the Law Firm.
When visiting the website using the contact form and in case of interactions in social networks, the Law Firm processes data on the following grounds:
- The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
The purposes of personal data processing in the above cases are:
- Presentation of the Law Firm’s services.
In relation to the video surveillance in the premises of the administrator, the Law Firm processes data on the following grounds:
- The processing is necessary for the purposes of the legitimate interests of the administrator – increasing the level of security and ensuring the Law Firm’s office, protecting the legitimate interests of the Law Firm, including those related to possible claims and other claims against the Law Firm.
- The data subject has given consent to the processing of his or her personal data for one or more specific purposes;
The purposes of personal data processing in the above cases are:
- Facilitation of security activities at the Law Firm’s premises.
- Protection of the Law Firm’s property.
- Protection of the legitimate interests of the Law Firm, including those related to possible claims and other claims against the Law Firm.
DISCLOSURE OF DATA TO THIRD PARTIES
The Law Firm does not disclose personal data to third parties and recipients unless there is a legal or contractual basis for obtaining the data or the data is publicly available due to their inclusion in a public register.
Apart from cases of general accessibility of data included in a public register, recipients of data may be:
- State bodies and bodies entrusted with public functions within their powers (NRA, NSSI, MI etc.)
- Banks, for the needs of remuneration payments.
- Courier companies and postal operators – for the purposes of correspondence with individuals.
- Accounting companies – processing personal data under an assignment contract for the needs of the financial and accounting activity of the Law Firm.
- Lawyers and/or law firms – processing personal data for the purposes of administrative and legal provision of the Law Firm’s activity.
DATA RETENTION PERIOD
- The data related to employment and social security relations are stored for a period of 50 years;
- The archive of decisions for imposing disciplinary penalties shall be kept for 15 years;
- Customer data is stored for a period of 5 years after the provision of the service;
- The data for which no period is explicitly stated here and for which there is a statutory retention period will be stored within the minimum required statutory retention period.
- Data for which no explicit period is specified here and for which there is no statutory retention period will be stored for a minimum period according to the purposes of processing in accordance with the principle of storage limitation.
RIGHTS OF DATA SUBJECTS
The measures taken to protect personal data in accordance with the requirements of Regulation 2016/679 are aimed at ensuring the rights of the subjects whose personal data are processed, namely:
- Right of access.
- Right to rectification of inaccurate or incomplete data.
- Right to erasure (the right to be forgotten), if the conditions of Art. 6 para. 17 of Regulation 2016/679 are fulfilled.
- Right to restriction of processing.
- Right to data transfer, if the conditions for transfer under art. 20 of Regulation 2016/679 are fulfilled.
- Right to object, if the conditions of art. 21 of Regulation 2016/679 are fulfilled.
- The right not to be subject to a decision based solely on automated processing, including profiling.
- The right to restrict the processing of personal data, in which case the data will only be stored but not processed.
- Right to withdraw consent to data processing at any time in the event that the data are processed on the basis of consent given by the subject.
If the Law Firm needs to use data for a new purpose that is not covered by the initially notified or given consent to data processing, the subject will be notified of the new purposes of data processing or, if his or her data is processed based on consent given by the subject, he or she will be asked for a new consent.
The above rights may be exercised by sending a request to the Law Firm, in which the subject should indicate its specific request and provide the minimum necessary contact details. The request should be signed and sent to the registered address of the Law Firm with a delivery note or by e-mail to office@panevpartners.com.
RIGHT TO COMPLAIN
If you believe that your rights under Regulation 2016/679 have been violated, you can file a complaint with the Personal Data Protection Commission or the Sofia City Administrative Court.
AUTOMATED DECISION-MAKING
The Law Firm does not use automated decision-making in data processing and profiling.
TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS
The Law Firm does not transfer processed personal data to third countries or international organizations.
DATA SOURCES
The Law Firm collects and processes personal data with a source from the data subject. In cases where personal data of a data subject are from another source, the basis for collection and processing is the fulfillment of a legal obligation of the administrator, and the purpose is to provide services agreed with a client of the Law Firm. In this case, the data retention period is the statutory period, and if there is no statutory period – the minimum necessary period, subject to the principle of storage limitation.
MEASURES INTRODUCED BY THE LAW FIRM TO PROTECT PERSONAL DATA
The Internal Rules of the Law Firm for Processing and Protection of Personal Data adopted by the Law Firm have introduced measures for effective protection of the processed data and the possibility of exercising the rights of data subjects provided for in Regulation 2016/679. The Law Firm has implemented the necessary technical and organizational measures to prevent unauthorized access, loss, or unauthorized use of personal data. Their collection and processing is carried out in accordance with the requirements of the Bulgarian and European legislation.
Further information about the personal data protection measures in the Law Firm can be obtained in the event of a legitimate interest from the contact person of the administrator.
