The Website is property of Gugushev & Partners Law Office, a law office registered under the Bulgarian Bar Act (bulg. Закон за адвокатурата) under Company file No. 813 of 2010 at the Sofia City Court, BULSTAT: 176026301, VAT reg. number: BG 176026301, with seat and address of management at No. 130 Georgi Sava Rakovski Str., floor 2, ap. 4, Sofia City Province, Republic of Bulgaria (hereinafter "Gugushev & Partners", "We" or "Us").
I. WHAT IS PERSONAL DATA AND WHY WE PROCESS IT
Whenever Website visitors browse the Website contents and/or use the Website features including to make inquiries via the Website We collect personally identifying information ("Personal Data") about visitors via digital tracking technologies (such as cookies) as well as Personal Data manually entered in the Website for the purposes of establishing contact with the visitor and providing information regarding the legal services provided by Gugushev & Partners, analysing visitor behaviour and interests with regards to the articles, news and other information published on the Website, for the purposes of subscribing for the Gugushev & Partners and/or the PONTES newsletters.
The types of Personal Data that We collect whenever visitors of the Website manually enter it in the course of newsletter subscription include name, IP address, phone number, email address, data regarding the interests and behavior of the visitor on the Website. Please find information regarding the processing of Personal Data of Job Applicants collected via the Privacy Notice for Job Applicants.
II. HOW PERSONAL DATA IS PROCESSED
III. LEGAL GROUNDS FOR THE PROCESSING
Through the Website, different types of Personal Data are collected and processed, for different purposes and on different legal grounds. More precisely:
(a) Personal Data related to browsing collected via cookies is processed on grounds of the legitimate interest of Gugushev & Partners;
(b) Personal Data provided manually by visitors in the contact form in the Website may be processed for organizing a meeting with the visitor and/or his representatives on grounds of assisting the visitors in exercising their interests/rights as well as for taking steps at their request for the conclusion and performance of legal assistance contracts if the information concerns a legal issue;
(c) Personal Data provided manually by visitors in the course of providing feedback, digital communication or the subscription to Our newsletters is processed on grounds of the legitimate interest of Gugushev & Partners insofar as permitted by the applicable data protection laws for digital marketing purposes as well as the explicit consent of the visitor.
IV. RETENTION PERIODS
Unless provided otherwise by the applicable laws consent-based processing of Personal Data such as data provided for marketing activities shall be retained as long as mandatory for the particular processing considering the interest demonstrated by the visitors to be updated on Our services. Visitors subscribing to Our newsletter will be asked to renew their consent no later than 2 (two) years after the initial subscription or after their previous consent renewal. Personal Data of visitors who have not renewed their consent and where Gugushev & Partners cannot demonstrate any other legal grounds for the processing shall be deleted without undue delay.
Personal Data linked to the execution of legal assistance agreements if such has been provided over the Website shall be stored for the duration of the agreement and 6 years after its termination unless provided otherwise by the applicable laws.
V. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
Gugushev & Partners discloses the Personal Data collected over the Website only as permitted by law. Personal Data shall be processed and disclosed to:
(i) consultants and contractors of Gugushev & Partners such as IT support specialists, system administrators, Website developers and marketing companies acting in their capacity of data processors and providing Gugushev & Partners with specific technical and organizational services in relation to the Website or the marketing of Our products;
(ii) law firms within the PONTES: The CEE lawyers and Lexwork International legal networks for the purposes of developing Our newsletters or drafting internal reports, for example with regards to Website views and visitor engagement;
(iii) police and judicial authorities, in compliance with the law and upon their request, or in case there are good reasons to believe that such disclosure is reasonably mandatory to (1) investigate, prevent or take initiatives in relation to suspected unlawful activities, or assist national supervisory authorities; (2) prepare a defence against third-party claims or charges, protect the security of its own website and of the company; (3) exercise or protect the rights, property or security of Gugushev & Partners, its affiliates, customers, employees and third parties.
Gugushev & Partners process Personal Data using its servers located within the European Union. In the cases when Gugushev & Partners transfer Personal Data outside the European Economic Area it shall ensure that the relevant country has been established to have an adequate level of Personal Data protection or Gugushev & Partners shall require its partner to conclude the Standard Contractual Clauses in order to protect the transferred personal data.
VI. RIGHTS OF VISITORS WITH REGARDS TO THE PROCESSING OF THEIR DATA
A visitor always has the right to obtain confirmation whether or not Personal Data concerning him/her exists, even if it is not yet recorded, and to have it communicated to him/her in an intelligible form.
A visitor also has the right to obtain information about the source of Personal Data; the purposes and methods of processing it, the logic applied in the event of processing that is performed with the aid of electronic instruments; the identification details of the controller and data processors; and an indication of the persons or categories of persons whose Personal Data may be communicated, or who could end up being known by, for example, data processors or agents as data supervisors or data processors.
A visitor also has the right to request an update, correction or, when s/he has an interest in doing so, the inclusion of Personal Data, deletion, conversion to an anonymous form or the blocking of personal data, that has been processed in violation of the law, including data which it is not mandatory to keep in relation to the purposes for which it was collected or subsequently processed; a statement that the above operations were disclosed, including in terms of their content, to those parties to whom the data was communicated, except in the case in which such performance proves impossible or entails the use of methods that are clearly disproportionate to the right protected. The visitor can also ask for the portability of his/her data.
A visitor nevertheless has the right to object, in part or in full, for legitimate reasons, the processing of Personal Data concerning him/her, even if it is pertinent to the scope of the collection, the processing of Personal Data concerning him/her for the purposes of sending advertising or direct marketing materials or to conduct market research or commercial communications and he has the right to ask restriction of processing concerning itself. The right to object may also be exercised specifically with regard to one or more methods of sending marketing communications.
The visitor also has the right to lodge a complaint with a data protection authority (please find more information below) as well as the right to withdraw the consent previously given.
VII. FINAL PROVISIONS
Changes in the applicable laws including the GDPR might require Us to amend this policy from time to time. We shall inform you of any such changes to this policy to the email address provided by you for receiving communications from Gugushev & Partners.
In case you need any information or assistance with regards to the processing of your data or to exercise your legal rights as a data subject please contact Us at the e-mail address: office[at]gugushev.com
Depending on your place of living you might also be able to refer to another Data Protection Authority (DPA) within the European Union. Please find a list of DPAs within the EU and their contact details here: https://edpb.europa.eu/about-edpb/board/members_en.