PERSONAL DATA PROTECTION POLICY

This website („the Site“) is managed by Europa Consulenze Eood („E.C.“). E.C. signs a high priority to the protection of personal data and undertakes to comply with the legal provisions for data protection. The purpose of this policy is to inform you what personal data we would collect about you, for what purpose and term and what are your rights.

E.C. and the protection of your personal data

E.C. keeps the highest levels of confidentiality of the Site users’ data. This Personal data protection policy is applied to the personal data which we collect through the Site.

How you can contact

If you have any questions about your privacy rights, you can contact us in the following ways:

• In person or by registered mail: Address Sofia 1504 Sofia, Oborishte Region, 15 Trakiya St., fifth floor, office 6;
• By contacting us on our website http://sixandthecity.net, section “Contacts”
• By contacting us on the following phone +359 882242043;
• By email at: hello@sixandthecity.net.

If you are not satisfied with a response you receive from us, you are entitled to lodge a complaint with the Office of the Data Protection Commission:

• Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
• Tel. +359291-53-518
• Reception hall – working hours 9:00 – 17:30
• Е-mail: kzld@cpdp.bg
• Website: www.cpdp.bg

You can visit the website of the Office of the Data Protection Commission for Republic of Bulgaria at www.cpdp.bg for more details.

How and why we use your personal data

We collect and process personal data only subject to the requirements of local and European legislation. We understand that processing your personal data is for a specific reason and cannot be done without limitation.

We gather and process your personal data for a variety of reasons and rely on a number of different legal bases to use that information, for example, we use your personal data information to provide you with legal advice and legal services, to ensure we provide you with the best service possible, to prevent unauthorised access to your personal data and to meet our legal and regulatory obligations.

This Data Protection Notice is intended to explain to you how and why we process your personal data.

We are required to process your personal information to comply with certain legal obligations, for example:

• For provision of information to the Data Protection Commission in connection with obligations provided by the legislation on the protection of personal data – Data Protection Act, Regulation (EC) 2016/679 of 27 April 2016 and others;
• Obligations stipulated in the Accountancy Act and the Tax and Social Insurance Procedure Code and other related normative acts in connection with the maintenance of proper and lawful accounting;
• Obligations stipulated in the Attorneys Act and the Anti Money Laundering Act;
• Providing information to a court and third parties, in the course of proceedings before a court, in accordance with the requirements of procedural and substantive applicable legal acts;

In some cases, we process your personal data only upon your prior consent. The consent is a separate reason for processing of your personal data and the purpose of the processing is specified therein.

What information we collect

It is possible that we will collect personal data about you when you use our Site. In most cases, you will give us this information choosing and agreeing to send us information about yourself. Depending on the services you use we can collect and process the following information about you when you visit and apply for an open position through the Site:

In online forms of the site: names, telephone number and address, representing your contact data, e-mail, personal identification number (PIN, PNF, etc.).

We will require this information from you through: our website http:// sixandthecity.net, as well as personally by you when you visit us at the following address: Sofia 1504, Bulgaria, 15, Trakiya str.

We collect information also indirectly via the use of cookies, which are outlined below in the Notice.

We do not have clients and do not collect personal data on children aged under 18.

How we use and share your information

We process the collected personal data with the purpose to answer your queries or other correspondence.

All personal data which you provide voluntarily when using our on-line registration forms will be used for assessment of our activity or for provision of specific service you register for.

E.C. uses the services of third parties to support specific activities such as: hosting, website maintenance and communications, collection and processing of personal data through functional cookies. In some cases, those third parties can obtain your data but E.C. shall always control this process and shall provide the highest security of your data.

How long we store your information

We keep the whole information collected about you up to the period of the provided service or within the stipulated in the current legislation time limits.

Security and Confidentiality

E.C. takes measures to protect your personal data from accidental loss and unauthorised access, use, modification or disclosure. Policies and procedures are put in place designed to protect information from loss, misuse and unauthorized disclosure. We also take additional information security measures, including access control, strict physical protection and reliable practices for collecting, storing and processing information.

We use a variety of security technologies and procedures to protect your personal data from unauthorised access, use or disclosure. We also take steps to ensure that only persons with appropriate authorisation can access your personal data.

We have in place systems and procedures to prevent unauthorised access, improper modification or disclosure, misuse or loss of information.

Only staff members who are suitably authorised can access your personal data if that data is relevant to the performance of their duties.

We use internal technical and organisational measures to protect your personal data from unauthorised access, to maintain data accuracy and to help ensure the appropriate use of your personal data.

We will not sell or hire your personal information to third parties for their own use.

Transfer between countries

The transfer, storage and processing of personal data collected through the Site is secured by modern technical means. E.C. shall not transfer your data outside of the European Economic Area (EEA). E.C. can transfer your data to third parties which will process them according to the instructions of E.C. or according to the applicable law.

Access, corrections and withdrawal

You can request from E.C. information about the collected and stored personal data about you anytime. You may also require from E.C. to correct, delete or update such personal data.

You may also withdraw anytime your consent for collecting, keeping and use of your personal data regarding E.C..

We inform you that under the present legislation you have the right to appeal about the way your data are processed to the supervisory body – the „Commission for Personal Data Protection, Sofia 1592, 2, Prof. Tsvetan Lazarov Blvd.“ or www.cpdp.bg.

You can control the personal information you have given to E.C.

When your personal data is processed in connection with our services, you are entitled to rely on a number of rights. These rights allow you to exercise meaningful control over the way in which your personal data is processed. You may execute any of these rights free of charge (in certain exceptional circumstances a reasonable fee may be charged or we may refuse to act on the request) and we may ask you to verify your identity prior to proceeding with your instruction by way of requesting additional information/documentation from you.

You are entitled to:

1. Access your personal data:

You can access the personal data we hold about you by contacting us with a data access request, using our website http:// http:// sixandthecity.net, as well as by visiting us at the following address: Sofia 1504, Bulgaria, 15, Trakiya str., and after we are assured that the request comes from you.

2. Correct/ restrict /delete your personal data

If you believe that certain personal data we hold about you is inaccurate or out of date, you can look for the data to be corrected at any time by visiting us at the following address: Sofia 1504, Bulgaria, 15, Trakiya str, and after we are assured that the request comes from you.

If you dispute the accuracy of information held, you can request that we restrict processing this information while your complaint is being examined.

If you suspect that we are processing certain information without a legitimate reason, or that we are no longer entitled to use your personal data, you can also ask for that personal data to be deleted.

We are not under an obligation to delete your personal data where to do so would prevent us from meeting our contractual obligations to you, or where we are required or permitted to process your personal data for legal purposes or otherwise in accordance with our legal obligations.

There may be cases where the right of deletion cannot be exercised, and processing will be necessary:

• for the exercise of the right to free expression and the right to information;
• when this would prevent us from fulfilling our contractual obligations to you;
• to comply with a legal obligation that is subject to the law of the European Union or the Republic of Bulgaria that applies to us or to fulfil a task of the public interest or in the exercise of any public authority;
• to establish, exercise or protect legal claims.

You can request restricting of the processing data if:

• you object the accuracy of the personal data, for the period necessary for verification of its accuracy; or
• the processing of personal data is performed without a legitimate reason, but instead of deleting them, you want their limited processing; or
• we no longer need this data (for the intended purpose), but you need this data for the establishment, exercise or protection of legal claims; or
• You have objected to your personal data being processed, pending verification that the reasons for the data processor are legal.

We ask that you keep us informed of any relevant changes in your personal data to enable us to keep the data on our systems up to date and accurate.

3. Withdraw your consent

Whenever you have provided us with your consent to process your personal data, you have the right to withdraw that consent at any time through our website http:// sixandthecity.net, as well as by visiting us at the following address Sofia 1504, Bulgaria, 15, Trakiya str. If you withdraw your consent to process (and if there is no other justification for continuing to process your data), you are also entitled to request that your personal data is deleted. Withdrawing consent does not affect the lawfulness of any processing undertaken by us based on your consent before its withdrawal.

4. Objection to the processing of personal data

Our clients have the right, at any time and on grounds related to their particular situation, to object to the processing of personal data related to them.

If you disagree with the way in which we process certain data, you can object to this through our website http:// sixandthecity.net, as well as by visiting us at the following address Sofia 1504, Bulgaria, 15, Trakiya str, and after we ascertain that the request really comes from you. In such cases, we will provide you with details regarding the rationale for processing your personal data.

5. Opportunity your personal data to be transferred in electronic form

You can (in certain cases) request that your personal data is transferred to you or another service provider or another data controller, so that you can store and reuse your personal data. We will not be in any way accountable or liable for any damage, loss or distress sustained, incurred or suffered by you and/or the designated service provider as a result of improper use of the personal data upon and after receipt from us.

6. Right to complain

If you believe that we are breaching the applicable legislation, please contact us to clarify the issue. Of course, you have the right to file a complaint with the Personal Data Protection Commission. After 25 May 2018, you will be able to file a complaint with a regulatory body within the EU.

Changes in this Personal data protection policy

This procedure for personal data protection can be changed over time. Such changes will come into force immediately upon their announcement. The regular review of this site will guarantee that you will always be aware of the kind of information E.C. collects, how and for what purposes  it is used and under what circumstances (if such circumstances occur) we will share this information with other parties.

In order to apply the most up-to-date data protection measures and to comply with the current legislation, we will keep under regular review this Data Protection Notice. If the amendments we make are substantial, we can post a message about the changes on our website.

We invite you to review the current version of this Data Protection Notice, to be constantly informed about how we take care of the protection of the personal data we collect.

This Data Protection Notice has been updated for the last time on ___________________

Do we share your personal information?

We share your personal data with third parties-receivers and our primary purpose is to offer you qualitative, fast and comprehensive service by taking care of the services we offer to meet your expectations. We do not provide your personal data to third parties before we are sure that all technical and organisational measures have been taken to protect this data as we do strict control to meet this goal. In this case, we remain responsible for the confidentiality and security of your data.

Completeness, accuracy and timeliness of the information

The information on this Site is supposed to provide the users with general information on issues that would be of interest to them. The use of the Site is entirely at the discretion of the users The Site can contain references to certain laws and regulations which could change over time and shall be interpreted only for the specific moment.

E.C. shall not bear any responsibility related to errors, omissions or unauthorised changes in the content of this Site.

The whole content of the Site and all services provided on it are without guarantee of completeness, accuracy or timeliness, and in this sense, we cannot be liable for any contractual or non-contractual tangible or intangible damages that have occurred after the use of our Site.

Cookies

What are cookies used for?

We use cookie technology on our website. We use cookies to collect information. A cookie is a small data file that a website stores on your computer’s hard disk to keep records of when you visit the website.

Cookies are also used in the preparation of anonymous statistics that help us understand how a certain user prefers to use our website, allowing us to improve its structure and content, excluding the identification of the personality of the user.

More information about this technology you can find in the section “Cookies”.

INFORMATION AND CONTACTS OF THE PERSONAL DATA CONTROLLER

Europa Consulenze Eood (E.C.), VAT number BG200789099

Headquarters and management address:  15, Ul. Trakiya – Sofia 1504

Telephone: +359 882242043

Website: www.sixandthecity.net

E.C. Data protection officer: Massimo Di Lauro

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