Information about the controller of personal data:
The Website is operated by Emerging Markets Consulting Ltd., with company registration number 201180546, headquartered in Sofia, at the address: 81A Bulgaria blvd, floor 1, office 2, hereinafter referred to as “the Operator”. If needed, you can contact us via the following details:
Address: 81A “Bulgaria” blvd., Sofia 1404, Bulgaria
Phone: +359 2 843 11 80
Fax: +359 2 944 24 95
E-mail: info@emcbg.com
Grounds and purposes for data processing
We process your personal data on the following grounds:
- For processing inquiries (based on your explicit consent);
- our explicit consent – the purpose is specified for each specific case;
- When required by law.
In the following paragraphs you will find detailed information about the processing of your personal data depending on the basis on which we process it.
For processing of inquiries
We process your personal data in order to to process inquiries submitted through the website.
Processing purposes
- establishing your identity;
- communication
Data we process on this basis:
On the basis of the contract concluded between us and you, we process information about the type and content of the contractual relationship, as well as any other information related to the contractual relationship, including:
- personal contact data – contact address, email, phone number;
We do not provide any of the data to third parties.
We delete the data collected on this basis 2 years after the collection.
store information about user behavior. No personal data is stored in this process, i.e. through the “cookies” of the site, we cannot identify you as a person, which is why the Personal Data Protection Act does not apply to the collection of this information. The information collected by “cookies” is usually used in an aggregate form for the purpose of analyzing the user behavior of the Website, which allows us to improve the functionality of the site, user paths and the content used.
To fulfil statutory obligations
It is possible that the law stipulates an obligation for us to process your personal data. In these cases, we are required to carry out the processing, such as:
- Obligations under the Anti-Money Laundering Measures Act;
- Fulfillment of obligations in relation to distance selling, off-premises sales, provided for in the Consumer Protection Act;
- Provision of information to the Consumer Protection Commission or third parties provided for in the Consumer Protection Act;
- Provision of information to the Commission for the Protection of Personal Data in relation to obligations provided for in the normative framework for the protection of personal data;
- Obligations stipulated in the Law on Accounting and the Tax-Insurance Procedure Code and other related legal acts, in connection with the keeping of legal accounting;
- Provision of information to the court and third parties, within the framework of proceedings before a court, in accordance with the requirements of the normative acts applicable to the proceedings;
- Age verification when shopping online.
When we delete personal data collected on this basis
We delete the data collected in accordance with a statutory obligation once the obligation to collect and store is fulfilled or no longer exists.
Upon your explicit consent
We process your personal data on this basis only after your express, unequivocal and voluntary consent. We will not foresee any adverse consequences for you if you refuse to process personal data.
Consent is a separate basis for processing your personal data and the purpose of the processing is stated therein, and is not covered by the purposes listed in this policy. If you give us the relevant consent and until its withdrawal or termination of any contractual relationship with you, we prepare suitable offers for you for products/services, performing detailed analyzes of your basic personal data;
Data we process on this basis:
On this basis, we may process personal data for direct marketing purposes, including website usage data and social network profile data.
Provision of data to third parties
On this basis, we may provide your data to marketing agencies, Facebook, Google or the like.
Withdrawal of consent
Consents may be withdrawn at any time. Withdrawal of consent does not affect the fulfilment of contractual obligations. If you withdraw your consent to the processing of personal data for any or all of the ways described above, we will not use your personal data and information for the purposes specified above. Withdrawal of consent does not affect the lawfulness of processing based on consent given prior to its withdrawal.
To withdraw the given consent, you only need to use our site or simply our contact details.
When we delete data collected on this basis
We delete the data collected on this basis upon your request or 12 months after its initial collection.
How we protect your data
To ensure adequate data protection of the company and its customers, we implement all necessary organizational and technical measures provided for in the Personal Data Protection Act.
The company has established rules to prevent abuse and security breaches, which supports the processes of protecting and ensuring the security of your data.
For the purpose of maximum security during processing, transfer and storage of your data, we may use additional protection mechanisms such as encryption, pseudonymization, etc.
Data subject rights
Each User of the site enjoys all the rights to protect personal data according to Bulgarian legislation and the law of the European Union.
The user can exercise his rights by sending a message to our email.
Each User has the right to:
- Being informed (in connection with the processing of his personal data by the administrator);
- Access to your own personal data;
- Correction (if the data is inaccurate);
- Erasure of personal data (right “to be forgotten”);
- Restriction of processing by the administrator or personal data processor;
- Portability of personal data between individual administrators;
- Objection to the processing of his personal data;
- The data subject also has the right not to be subject to a decision based solely on automated processing, including profiling, which gives rise to legal consequences for the data subject or similarly affects him to a significant extent;
- Right to judicial or administrative protection in the event that the data subject’s rights have been violated.
The user can request deletion if one of the following conditions is present:
- Personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- The user withdraws his consent on which the processing of the data is based and there is no other legal basis for the processing;
- The data user objects to the processing and there are no overriding legal grounds for the processing;
- Personal data has been processed unlawfully;
- 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 the controller;
- The personal data were collected in connection with the provision of information society services to children and the consent was given by the holder of parental responsibility for the child.
The user has the right to limit the processing of his personal data by the administrator when:
- Dispute the accuracy of personal data. In this case, the restriction of processing is for a period that allows the administrator to verify the accuracy of the personal data;
- The processing is illegal, but the User does not want the personal data to be deleted, but instead requires the restriction of its use;
- The Administrator no longer needs the personal data for the purposes of processing, but the User requires them for the establishment, exercise or defense of legal claims;
- Object to the processing pending verification of whether the legal grounds of the administrator take precedence over the interests of the User.
Right of portability
The data subject has the right to receive the personal data concerning him and which he has provided to an administrator in a structured, widely used and machine-readable format and has the right to transfer such data to another administrator without hindrance from the administrator to whom the personal data is provided when the processing is based on consent or a contractual obligation and the processing is carried out in an automated manner. When exercising his right to data portability, the data subject has the right to also obtain a direct transfer of personal data from one controller to another, where this is technically feasible.
Right to object
Users have the right to object to the administrator against the processing of their personal data. The administrator of personal data is obliged to terminate the processing, unless it proves that there are compelling legal grounds for the processing that take precedence over the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. In case of objection to the processing of personal data for the purposes of direct marketing, the processing should be stopped immediately.
Complaint to the supervisory authority
Every User has the right to file a complaint against the unlawful processing of his personal data to the Commission for the Protection of Personal Data or to the competent court.